Relevnt is a technology company that builds SaaS-based group chat apps with live, interactive streaming.
PRIVACY POLICY
Effective Date: March 7, 2022
Last Updated: March 7, 2022
This Privacy Policy (the “Policy”) explains how Relevnt, Inc. (“us,” “our,” or “we”) collects, uses, discloses, and protects personal information that we collect through our website, https://relevnt.com/ (the “Website”), the Relevnt mobile application (the “App”), and any other online services that we operate and that include a link to this Policy (collectively with the Website and App, the “Services”).
The Information We Collect
When you use or access the Services, we may collect certain information directly from you that you choose to provide, and other information automatically from your use of the Services
Information We Collect Directly from You
When you use or access the Services, we may collect personal information that you directly provide us, such as the following:
● Profile information, such as your username, tagline, email address, profile picture or gif, links to your profiles on third party social media platforms, your educational institution (if you register with a .edu email address), and other information you may choose to include in your profile.
● Authentication information, such as your username or email address and password, your date of birth, and, if you choose to sign into the App using your account on a third party service or social media platform such as Apple, Facebook, or Google, basic information from that account, such as your name and email address.
● Information about contacts stored on your mobile device, including their names and phone numbers, if you choose to allow the App to access those contacts in order to invite them to join Relevnt or Vibes you have created or joined.
● Information about Vibes you create, such as the name, description, banner image, chatroom background, members, and type and category.
● Messages and other content, such as links, photos, and videos, that you share with other users in Vibes you have joined, and your reactions to the messages and content that other users share.
● Audio and video content collected through the microphone and camera on your device, when you choose to participate in live audio and video conversations, record a Vibecast, or transmit live video or audio broadcasts through the App.
● Messages and other content that you send to, and receive from, other users of the App through private messages.
● Payment information that you provide to purchase subscriptions to Vibes and other content through the App, including payment card numbers, expiration dates, security codes, and your billing address.
● Any other information you submit when you contact us through the Services, including any information you provide in a submission through contact forms.
Information We Collect Automatically from Your Use of the Services
When you access or use the Services, we also automatically collect information about you, your device, and your use of the Services, which may include information from the categories described below:
● Browser and Device Information. Certain information may be automatically collected by most browsers or devices, such as information about user devices (such as IP addresses and MAC addresses), operating systems, and browsers.
● Information Stored in Cookies. The Services may also use cookies. Cookies are pieces of information stored directly on users’ computers or devices. Cookies allow us to collect information such as browser type, time spent on the online services, pages visited, referring URL, and other traffic and usage data. We and other third parties may also use cookies for purposes such as determining what features interest our users, revising our site features or operations, and as further described below. For more information, see the “Your Rights and Choices” section below. Some cookies may be set by third parties, who may use the Services to collect personal information about your online activities over time and across different websites, applications, and other online products or services.
● Pixel Tags and Log Files. The Services may also use other tracking systems such as log files and pixel tags set by us and by third parties with whom we work. For example, pixel tags, sometimes called web beacons, are similar in function to a cookie and can tell us certain information like what content has been viewed.
● Information Collected in Connection with Analytics Technology. We may use various technologies to learn more about how visitors use the Services, such as Google Analytics. Google Analytics uses cookies to help us analyze how visitors use the Services. The information generated by the cookies about your use of the Services includes your IP address. If you so choose, you may be able to opt out by turning off cookies in the preferences settings in your browser. For more information on Google Analytics, including how Google Analytics collects, uses, and discloses information, refer to the following page: www.google.com/policies/privacy/partners/. We may also use other technologies to monitor your activities while using our Services.
● Location Information. When you use the Services, we may automatically collect information about your location, including general location information that may be associated with your device’s IP address, and, if you allow your device to share information about your location with the App, the precise geolocation of the device you use to access the App, which we use to facilitate your participation in local Vibes.
● Usage Data. When you use the App, we will automatically collect information about how you use the App, such as the Vibes you create and join, the conversations you engage in, content you share, features you use, actions you take, people or accounts you interact and connect with, and the time, frequency, and duration of your use.
How We Use Your Information
We may use the information we collect from and about you for the following purposes.
● Providing, developing, maintaining, personalizing, protecting, and improving the Services, including delivering analytics, visualizations, and other reports based on the information you provide to the Services.
● Processing payments for your purchases through the Services.
● Operating, evaluating, debugging, identifying, and repairing errors; effectuating functional enhancements; and improving our Services.
● Understanding how you and other users use our Services, performing analytics, analyzing and reporting on usage and performance of the Services and marketing materials, and determining what features and functionality may interest you and other users.
● Communicating with you and others, including responding to your requests and providing promotional information.
● Offering, marketing, or advertising products, programs, and services from us, our affiliates, our business partners, and select third parties to you, including through targeted advertising.
● Storing information about your preferences, recognizing you when you use the Services, and customizing your experience.
● Creating aggregate or de-identified information.
● For legal and safety purposes, such as maintaining the safety, security, and integrity of our Services, other technology assets, services, and our organization; preserving or enforcing our legal rights and property; protecting our users, our employees, and others; and complying with industry standards.
● Protecting against malicious, deceptive, fraudulent, or illegal activity, and participating in any prosecution or enforcement of laws or agreements meant to prevent or punish such activity.
● Enforcing our policies, Terms of Use, contracts, or other legal rights.
● Evaluating or participating in an actual or potential merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, including as part of bankruptcy, liquidation, or similar proceedings.
● Such other purposes as you may authorize.
● As necessary to perform our obligations pursuant to any contract we have entered into with you, including our Terms of Use.
● For any purposes to which you have consented.
● To comply with applicable law and our legal obligations.
How We Disclose Your Information
When you use the Services, we will disclose your personal information to other parties, including other users at your direction as the basic functionality of the Services, other third parties to accomplish the purposes set forth above.
Information You Share with Other Users
The Services are designed to allow you to communicate and share information with other users, and thus by using the Services, you are directing us to share the information you submit to the Services with them.
● When you establish a Relevnt account, your profile information will be made available to all other registered users of the App. This information includes your profile picture, name, username, and bio; links to social profiles or websites that you add to your profile; lists of users you follow and that follow you; Vibes you have joined and when you joined them; and the posts you have contributed.
● When you create, join, or participate in Vibes, any content or other information that you submit to those Vibes will be made available to other users with access to those Vibes. This content may include messages, comments, reactions, links, photos, and videos, as well as live and recorded audio and video content from conversations in which you participate, Vibecasts that you record, and live broadcasts that you transmit through the App.
● We will share any information and content that you submit through private messages with the recipients of those messages.
Other users may share information that you share through the Services, including audio and video recordings, with other users and with parties outside the App. We are not responsible for, and do not control, how other users of the Services use and disclose information that you share with them.
Other Disclosures
To accomplish the purposes set out in the “How We Use Your Personal Information” section above, we may also disclose your information:
● To our affiliates and subsidiaries.
● To our business partners, such as partners involved in joint business transactions.
● To our contractors, service providers, and other third parties we use to support our organization, which may include support of any of the data uses described above.
● To comply with applicable law, other legal requirements, and industry standards.
● To enforce our policies, Terms of Use, contracts, or other legal rights.
● To investigate or prevent unlawful activities or misuse of the Services.
● To protect against malicious, deceptive, fraudulent, or illegal activity, and participating in any prosecution or enforcement of laws or agreements meant to prevent or punish such activity.
● To operate, evaluate, debug, identify and repair errors, effectuate similar functional enhancements, and improve our Services and offerings.
● To protect the legal rights, property, safety, and security of us, our users, our employees, and others.
● To an actual or potential buyer, successor, or other organization in the event of an actual or potential merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, including as part of bankruptcy, liquidation, or similar proceedings.
● To such other parties as you may authorize.
Storage and Retention of Your Information
We retain personal information for as long as we reasonably need it to fulfill the purposes for which it was collected, including provision of the Services and to comply with law, resolve disputes, and enforce our agreements, as applicable. For example, if you register on our Services, we will store your information for as long as needed to maintain your account, provide you the Services or other functionality as you request it, enforce any applicable terms that govern your use of the Services, and maintain appropriate records to reflect our delivery of Services to you.
Your Rights and Choices
You may choose not to provide the personal information we request through the Services. However, not providing information we request may restrict your ability to use certain features of the Services. For example, we will not be able to provide you with most of the features available through our Services if you do not create an account with us.
You may access, review, and update your Profile Information by visiting your profile within the App and selecting “Edit Profile.”
You may be able to restrict the collection of personal information or functionality through your device’s operating system or by disabling cookies but doing so may prevent you from using the functionality of the Services.
Some Internet browsers have a “do-not-track” feature that lets you tell websites that you do not want to have your online activities tracked. Currently the Services do not respond to browser “do not track” signals.
Privacy laws in your jurisdiction may give you additional rights with respect to your personal information. Where those laws apply to us, you make exercise your rights by contacting us as set forth in the “Contacting Us” section of this Privacy Policy.
Third-party Links and Integrations
The Services may include links to or options to integrate with third-party websites, applications, information, and services provided by third parties. We are not responsible for the privacy policies or practices of those third parties. We encourage you to review the applicable privacy policies of such third parties if you elect to follow the links provided or integrate our Services with third party applications and services.
How We Protect Your Information
We maintain safeguards intended to protect the personal information collected through the Services from unauthorized access. The security of your personal information also depends on you. You should keep your account credentials confidential and make sure your devices and software are up-to-date to ensure the latest security measures are installed. Please note, however, that we cannot and do not guarantee the security of your information, as no method of data storage or transmission is 100% secure. Therefore, you should take special care in deciding what information you send to us via the Internet.
In addition, we cannot control the actions of users, who may seek to use third party apps or devices to record, store, or share content or communication without other users' prior consent. Please keep this in mind when using the App.
International Transfers
We operate internationally and your personal information may be transferred to the United States and other countries outside the jurisdiction you are located. The data protection laws in the United States and in other jurisdictions may differ from the jurisdiction where you are located and may not provide the same level of protection compared to the laws in the jurisdiction in which you are located.
Children and Our Services
Our Services are not directed toward children under the age of 13, and children under the age of 13 are not allowed to create an account or otherwise use the Services. In the event that we learn that we have collected personal information from a child under age 13 without parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us.
Additional Information for Individuals Located in the EEA, UK, and Switzerland
This section applies solely to users of the Services who are located in the European Economic Area (“EEA”), the United Kingdom (“UK”), or Switzerland.
If you are located in the EEA, UK, or Switzerland, you may have additional rights to withdraw consent, request access to, correction of, erasure of, or the transfer of your personal information, or object to or restrict the processing of your personal information. You may exercise these rights, if applicable, by contacting us as described in the “Contacting Us” section of this Policy. Individuals located in the EEA, UK, or Switzerland may also have the right to lodge a complaint with an EEA, UK, or Swiss supervisory authority, as applicable.
As required by applicable law, we collect and process information about individuals in the EEA, UK, and Switzerland only where we have a legal basis for doing so. Our legal bases depend on the Services you use and how you use them. We process your information on the following legal bases:
● We need to process the information to perform the Terms of Use and other agreements with you, including to provide and operate the Services, provide customer support and personalized features, and to protect the safety and security of the Services;
● It satisfies a legitimate interest (which is not overridden by your data protection interests), such as preventing fraud, ensuring network and information security, enforcing our rules and policies, protecting our legal rights and interests, research and development, personalizing the Services, and marketing and promoting the Services;
● You have consented for us to do so for a specific purpose; or
● We need to process your information to comply with our legal obligations.
If we transfer personal information subject to the data protection laws of the EEA, the UK, or Switzerland outside of the EEA, UK, or Switzerland, we will rely on a legal framework that provides appropriate safeguards, which could include the standard contractual clauses, binding corporate rules, or another framework deemed adequate by the European Commission. To obtain more information about the safeguards and to obtain a copy of them, you may contact us as described in the “Contacting Us” section of this Policy.
Additional Information for Residents of California
This section applies only to residents of the State of California and generally describes how we collect, use, and disclose the personal information of California residents and their households (“California Personal Information”). However, California Personal Information does not include, and this section does not apply to:
● Personal information reflecting a communication or a transaction between us and a California resident acting as a representative of an organization that relates to the organization obtaining products or services from us.
● Personal information, emergency contact information, and benefits administration information we collected about a California resident in the course of that California resident acting as our job applicant, our employee, our owner, our director, our officer, our medical staff member, or our contractor to the extent we use that information within the context of that California resident’s role as our job applicant, our employee, our owner, our director, our officer, our medical staff member, or our contractor.
● Other personal information excluded or excepted from requirements of the California Consumer
Privacy Act of 2018 (“CCPA”).
Additionally, this section applies only to the extent we direct the purposes and means of California
Personal Information processing and otherwise qualify as a business subject to the CCPA.
A. California Personal Information We Collect
We may collect, and may have collected in the preceding 12 months, the following categories of California Personal Information, as described in more detail above in “The Information We Collect” section:
● Identifiers, including online identifiers.
● Commercial information.
● Internet and other electronic activity information.
● Inferences drawn from your activity.
● Geolocation data.
● Audio, electronic, visual, thermal, olfactory, or similar information.
● Other categories of personal information described in California law.
B. Sources of California Personal Information We Collect
We collect California Personal Information from the sources described in the “The Information We Collect” section of this Policy.
C. Purposes for Which We Use California Personal Information
We may collect and use the categories of California Personal Information described in the “California Personal Information We Collect” section above for one or more of the business and commercial purposes described in the “How We Use Your Information” section above.
D. Disclosures of California Personal Information for a Business Purpose
In the preceding 12 months, we may have disclosed the categories of California Personal Information listed below to the categories of third parties identified below for a business purpose:
● Identifiers, including online identifiers—with other users, our affiliates, and service providers.
● Commercial information—with our affiliates, and service providers.
● Internet and other electronic activity information—with other users, our affiliates and service providers.
● Inferences drawn from your activity—with our affiliates and service providers.
● Geolocation data—with other users, our affiliates, and service providers.
● Audio, electronic, visual, thermal, olfactory, or similar information—with other users, our affiliates, and service providers.
● Other categories of personal information described in California law—with other users, our affiliates, and service providers.
E. Sales of California Personal Information
In the preceding 12 months, we have not sold California Personal Information. We do not sell California Personal Information, and we do not have actual knowledge that we sell California Personal Information of consumers under 16 years of age.
F. California Personal Information Rights and Choices
The CCPA provides California residents with specific rights regarding their California Personal Information. This section describes those rights and explains how to exercise those rights to the extent we direct the purposes and means of the processing of your California Personal Information processing and otherwise qualify as a “business” under the CCPA.
● Access to Specific Information and Data Portability Rights. California residents have the right to request that we disclose certain information to you about our collection, use, disclosure, and sale of your California Personal Information over the past 12 months. If we receive and confirm a verifiable consumer request from you pursuant to the “Exercising Access, Data Portability, and Deletion Rights” section below, we will disclose to you, depending on the scope of the request:
● The categories of California Personal Information we collected about you.
● The categories of sources for the California Personal Information we collected about you.
● Our business or commercial purpose for collecting California Personal Information about you.
● The categories of third parties with which we share your California Personal Information.
● The specific pieces of California Personal Information we collected about you.
● If we disclosed your California Personal Information for a business purpose, a list of the categories of third parties to whom we disclosed California Personal Information for a business purpose identifying the categories of California Personal Information disclosed to those parties in the preceding 12 months.
● Deletion Request Rights. California residents have the right to request that we delete California Personal Information, subject to certain exceptions. Once we receive and confirm your verifiable consumer request pursuant to the “Exercising Access, Data Portability, and Deletion Rights” section below, we will delete your California Personal Information from our records, unless an exception applies.
● Exercising Access, Data Portability, and Deletion Rights. To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
● Emailing us at: info@relevnt.com
● Visiting https://relevnt.com/contact-us
You may designate an authorized agent to submit requests on your behalf through a signed written permission that authorizes the agent to act on your behalf. We may mandate additional requirements when submitted through an authorized agent, such as requiring you to verify your identity directly with us or to directly confirm the authorized agent’s permission to act on your behalf.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. Your request must provide information sufficient to permit us to reasonably verify you are the person about whom we collected California Personal Information, or an authorized agent of that person. In order to verify your request, we may require you to provide additional information, including account profile information such as your email address and other information elements necessary to verify your identity. Your request also must include sufficient detail for us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with California Personal Information if we cannot verify your identity or authority to make the request and confirm the California Personal Information relates to you.
Making a verifiable consumer request does not require you to create an account with us.
However, if you have a password-protected account with us we consider requests made through that account sufficiently verified when the request relates to California Personal Information associated with that specific account.
Any disclosures we provide will only cover the 12-month period preceding our receipt of the verifiable request. If we cannot fulfill, or are permitted to decline, your request then we will alert you or your authorized agent. For data portability requests, we will select a format to provide your California Personal Information that is readily usable.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision, and we reserve the right to either refuse to act on your request or charge you a reasonable fee to complete your request if it is excessive, repetitive, or manifestly unfounded.
● Non-Discrimination. Subject to certain exceptions, you have the rights to not receive discriminatory treatment for exercising your access, data portability, opt-out, and deletion rights described above.
G. Right to Request Removal for Consumers Under the Age of 18.
Consumers under the age of 18 who are registered users of the Services may request and obtain removal of content or information they post on the Services. Such request for removal does not ensure complete or comprehensive removal of the content or information posted on the Services. To receive instructions on how to request and obtain removal of content or information posted on the Services, please contact us as described in the Contacting Use section below.
Changes to this Policy
We may update this Policy to reflect changes in our privacy practices at any time and without prior notice to you. When we do so, we will update the Last Updated date of the Policy above. We encourage you to periodically review this Policy for the latest information on our privacy practices.
Contacting Us
If you have any questions or comments about this Policy or our privacy practices, or you would like to ask for access to or amendment of deletion of your personal information, please contact us by email at info@relevnt.com.