1.    The Basics

a)      Basic Account Information

You don’t have to create an account to use some of our service features. If you do choose to create an account, you must provide us with some personal data so that we can provide our services to you. On SmuttyFy this includes a display name, a username, a password, and an email address. Your display name and username are always public, but you can use either your real name or a pseudonym. You can also create and manage multiple accounts.

b)     Public Information

Most activity on SmuttyFy is public, including your profile information, your time zone and language, when you created your account, and your Posts and certain information about your Posts like the date and time. You also may choose to publish your location in your Posts or your SmuttyFy profile. The lists you create, people you follow and who follow you, and Posts you Like or re-post are also public. If you like, re-post, reply, or otherwise publicly engage with an ad on our services, that advertiser might thereby learn information about you associated with the ad with which you engaged such as characteristics of the audience the ad was intended to reach.

You are responsible for your Posts and other information you provide through our services, and you should think carefully about what you make public, especially if it is sensitive information. If you update your public information on SmuttyFy, such as by deleting a Post or deactivating your account, we will reflect your updated content on SmuttyFy.com.

By publicly posting content when you Post, you are directing us to disclose that information as broadly as possible, including through our APIs, and directing those accessing the information through our APIs to do the same. To facilitate the fast global dissemination of Posts to people around the world, we use technology like application programming interfaces (APIs) and embeds to make that information available to websites, apps, and others for their use - for example, displaying Posts on a news website or analyzing what people say on SmuttyFy. We generally make this content available in limited quantities for free and charge licensing fees for large-scale access. We have standard terms that govern how this data can be used, and a compliance program to enforce these terms. But these individuals and companies are not affiliated with SmuttyFy, and their offerings may not reflect updates you make on SmuttyFy.

c)       Contact Information and Address Books

We use your contact information, such as your email address or phone number, to authenticate your account and keep it - and our services - secure, and to help prevent spam, fraud, and abuse. We also use contact information to enable certain account features (for example, for login verification), and to send you information about our services, and to personalize our services, including ads. If you provide us with your phone number, you agree to receive text messages from SmuttyFy to that number as your country’s laws allow. SmuttyFy also uses your contact information to market to you as your country’s laws allow, and to help others find your account if your settings permit, including through third-party services and client applications. You can use your settings for email and mobile notifications to control notifications you receive from SmuttyFy. You can also unsubscribe from a notification by following the instructions contained within the notification or here.

You can sign up for SmuttyFy with an account from another service like Google, or Facebook, or connect your SmuttyFy account to these other services. If you do, we will use information from that service, including your email address, friends, or contacts list, to recommend other accounts or content to you or to recommend your account or content to others. You can control whether your SmuttyFy account is discoverable by email through your SmuttyFy settings.

If you email us, we will keep the content of your message, your email address, and your contact information to respond to your request.

d)     Chats and Non-Public Communications

We provide certain features that let you communicate more privately or control who sees your content. For example, you can use Chats to have non-public conversations on SmuttyFy, protect your Posts. When you communicate with others by sending or receiving Chats, we will store and process your communications and information related to them. This includes link scanning for malicious content, detection of spam, abuse and prohibited images, and use of reported issues. We also use information about whom you have communicated with and when (but not the content of those communications) to better understand the use of our services, to protect the safety and integrity of our platform, and to show more relevant content. We share the content of your Chats with the people you’ve sent them to; we do not use them to serve you ads. Note that if you interact in a way that would ordinarily be public with SmuttyFy content shared with you via Chats, for instance by liking a Post, those interactions will be public. When you use features like Chats to communicate, remember that recipients have their own copy of your communications on SmuttyFy - even if you delete your copy of those messages from your account - which they may duplicate, store, or re-share.

e)      Payment Information

You may provide us with payment information, including your credit or debit card number, card expiration date, CVV code, and billing address, in order to purchase advertising or other offerings provided as part of our services and Marketplace.

f)        How You Control the Information You Share with Us

Your Privacy and safety settings let you decide:

·         Whether your Posts are publicly available on SmuttyFy

·         Whether others can tag you in a photo

·         Whether you will be able to receive Chats from anyone on SmuttyFy or just your followers

·         Whether others can find you based on your email or phone number

·         Whether you upload your address book to SmuttyFy for storage and use

·         When and where you may see sensitive content on SmuttyFy

·         Whether you want to block or mute other SmuttyFy accounts

2.     Additional Information We Receive About You

We receive certain information when you use our services or other websites or mobile applications that include our content, and from third parties including advertisers. Like the information you share with us, we use the data below to operate our services.

a)      Location Information

We require information about your signup and current location, which we get from signals such as your IP address or device settings, to securely and reliably set up and maintain your account and to provide our services to you.

Subject to your settings, we may collect, use, and store additional information about your location - such as your current precise position or places where you’ve previously used SmuttyFy - to operate or personalize our services including with more relevant content like local trends, stories, ads, and suggestions for people to follow. Learn more about SmuttyFy’s use of location here, and how to set your SmuttyFy location preferences here. Learn more about how to share your location in Periscope broadcasts here.

b)     Links

In order to operate our services, we keep track of how you interact with links across our services. This includes links in emails we send you and links in Posts that appear on other websites or mobile applications.

If you click on an external link or ad on our services, that advertiser or website operator might figure out that you came from SmuttyFy, along with other information associated with the ad you clicked such as characteristics of the audience it was intended to reach. They may also collect other personal data from you, such as cookie identifiers or your IP address.

c)      Cookies

A cookie is a small piece of data that is stored on your computer or mobile device. Like many websites, we use cookies and similar technologies to collect additional website usage data and to operate our services. Cookies are not required for many parts of our services such as searching and looking at public profiles. Although most web browsers automatically accept cookies, many browsers’ settings can be set to decline cookies or alert you when a website is attempting to place a cookie on your computer. However, some of our services may not function properly if you disable cookies. When your browser or device allows it, we use both session cookies and persistent cookies to better understand how you interact with our services, to monitor aggregate usage patterns, and to personalize and otherwise operate our services such as by providing account security, personalizing the content we show you including ads, and remembering your language preferences.

d)     Log Data

We receive information when you view content on or otherwise interact with our services, which we refer to as “Log Data,” even if you have not created an account. For example, when you visit our websites, sign into our services, interact with our email notifications, use your account to authenticate to a third-party service, or visit a third-party service that includes SmuttyFy content, we may receive information about you. This Log Data includes information such as your IP address, browser type, operating system, the referring web page, pages visited, location, your mobile carrier, device information (including device and application IDs), search terms (including those not submitted as queries), and cookie information. We also receive Log Data when you click on, view, or interact with links on our services, including when you install another application through SmuttyFy. We use Log Data to operate our services and ensure their secure, reliable, and robust performance. For example, we use Log Data to protect the security of accounts and to determine what content is popular on our services. We also use this data to improve the content we show you, including ads and to improve the effectiveness of our own marketing.

We use information you provide to us and data we receive, including Log Data and data from third parties, to make inferences like what topics you may be interested in, how old you are, and what languages you speak. This helps us better promote and design our services for you and personalize the content we show you, including ads.

e)      SmuttyFy for Web Data

When you view our content on third-party websites that integrate SmuttyFy content such as embedded timelines or Post buttons, we may receive Log Data that includes the web page you visited. We use this information to better understand the use of our services, to protect the safety and integrity of our platform, and to show more relevant content, including ads. We do not associate this web browsing history with your name, email address, phone number, or username, and we delete, obfuscate, or aggregate it after no longer than 30 days. We do not collect this data from browsers that we believe to be located in the European Union or EFTA States.

f)        Advertisers and Other Ad Partners

Advertising revenue allows us to support and improve our services. We use the information described in this Privacy Policy to help make our advertising more relevant to you, to measure its effectiveness, and to help recognize your devices to serve you ads on and off of SmuttyFy. Our ad partners and affiliates share information with us such as browser cookie IDs, mobile device IDs, hashed email addresses, demographic or interest data, and content viewed or actions taken on a website or app. Some of our ad partners, particularly our advertisers, also enable us to collect similar information directly from their website or app by integrating our advertising technology. Information shared by ad partners and affiliates or collected by SmuttyFy from the websites and apps of ad partners and affiliates may be combined with the other information you share with SmuttyFy and that SmuttyFy receives about you described elsewhere in our Privacy Policy.

SmuttyFy adheres to the Digital Advertising Alliance Self-Regulatory Principles for Online Behavioral Advertising (also referred to as “interest-based advertising”) and respects the DAA’s consumer choice tool for you to opt out of interest-based advertising at https://optout.aboutads.info. In addition, our ads policies prohibit advertisers from targeting ads based on categories that we consider sensitive or are prohibited by law, such as race, religion, politics, sex life, or health. Learn more about your privacy options for interest-based ads here and about how ads work on our services here.

If you are an advertiser or a prospective advertiser, we process your personal data to help offer and provide our advertising services. You can update your data in your SmuttyFy Ads dashboard or by contacting us directly as described in this Privacy Policy.

g)      Developers

If you access our APIs or developer portal, we process your personal data to help provide our services. You can update your data by contacting us directly as described in this Privacy Policy.

h)     Other Third Parties and Affiliates

We may receive information about you from third parties who are not our ad partners, such as others on SmuttyFy, partners who help us evaluate the safety and quality of content on our platform, our corporate affiliates, and other services you link to your SmuttyFy account.

You may choose to connect your SmuttyFy account to accounts on another service, and that other service may send us information about your account on that service. We use the information we receive to provide you features like cross-posting or cross-service authentication, and to operate our services. For integrations that SmuttyFy formally supports, you may revoke this permission at any time from your application settings; for other integrations, please visit the other service you have connected to SmuttyFy.

i)         Personalizing Based On Your Inferred Identity

When you log into SmuttyFy on a browser or device, we will associate that browser or device with your account for purposes such as authentication, security, and personalization. Subject to your settings, we may also associate your account with browsers or devices other than those you use to log into SmuttyFy (or associate your logged-out device or browser with other browsers or devices). When you provide other information to SmuttyFy, including an email address, we associate that information with your SmuttyFy account. Subject to your settings, we may also use this information in order to infer other information about your identity, for example by associating your account with hashes of email addresses that share common components with the email address you have provided to SmuttyFy. We do this to operate and personalize our services. For example, if you visit websites with sports content on your laptop, we may show you sports-related ads on SmuttyFy for Android and, if the email address associated with your account shares components with another email address, such as shared first name, last name, or initials, we may later match advertisements to you from advertisers that were trying to reach email addresses containing those components.

j)        How You Control Additional Information We Receive

Your SmuttyFy Personalization and data settings let you decide:

·         Whether we show you interest-based ads on and off SmuttyFy

·         How we personalize based on your inferred identity

·         Whether we collect and use your precise location

·         Whether we personalize your experience based on where you’ve been

·         Whether we keep track of the websites where you see SmuttyFy content

You can use Your SmuttyFy data to review:

·         Advertisers who have included you in tailored audiences to serve you ads

·         Demographic and interest data about your account from our ads partners

·         Information that SmuttyFy has inferred about you such as your age range, gender, languages, and interests

We also provide a version of these tools on SmuttyFy if you don’t have a SmuttyFy account, or if you’re logged out of your account. This lets you see the data and settings for the logged out browser or device you are using, separate from any SmuttyFy account that uses that browser or device.

3.    Information We Share and Disclose

As noted above, SmuttyFy is designed to broadly and instantly disseminate information you share publicly through our services. In the limited circumstances where we disclose your private personal data, we do so subject to your control, because it’s necessary to operate our services, or because it’s required by law.

a)      Sharing You Control

We share or disclose your personal data with your consent or at your direction, such as when you authorize a third-party web client or application to access your account or when you direct us to share your feedback with a business. If you’ve shared information like Chats or protected Posts with someone else who accesses SmuttyFy through a third-party service, keep in mind that the information may be shared with the third-party service.

Subject to your settings, we also provide certain third parties with personal data to help us offer or operate our services. For example, we share with advertisers the identifiers of devices that saw their ads, to enable them to measure the effectiveness of our advertising business. The information we share with these partners does not include your name, email address, phone number, or SmuttyFy username, but some of these partnerships allow the information we share to be linked to other personal information if the partner gets your consent first.

b)      Service Providers

We engage service providers to perform functions and provide services to us all over the world. For example, we use a variety of third-party services to help operate our services, such as hosting our various blogs and wikis, and to help us understand the use of our services, such as Google Analytics. We may share your private personal data with such service providers subject to obligations consistent with this Privacy Policy and any other appropriate confidentiality and security measures, and on the condition that the third parties use your private personal data only on our behalf and pursuant to our instructions (service providers may use other non-personal data for their own benefit). We share your payment information with payment services providers to process payments; prevent, detect, and investigate fraud or other prohibited activities; facilitate dispute resolution such as chargebacks or refunds; and for other purposes associated with the acceptance of credit and debit cards.

c)      Law, Harm, and the Public Interest

Notwithstanding anything to the contrary in this Privacy Policy or controls we may otherwise offer to you, we may preserve, use, or disclose your personal data or other safety data if we believe that it is reasonably necessary to comply with a law, regulation, legal process, or governmental request; to protect the safety of any person; to protect the safety or integrity of our platform, including to help prevent spam, abuse, or malicious actors on our services, or to explain why we have removed content or accounts from our services; to address fraud, security, or technical issues; or to protect our rights or property or the rights or property of those who use our services. However, nothing in this Privacy Policy is intended to limit any legal defenses or objections that you may have to a third party’s, including a government’s, request to disclose your personal data.

d)     Affiliates and Change of Ownership

In the event that we are involved in a bankruptcy, merger, acquisition, reorganization, or sale of assets, your personal data may be sold or transferred as part of that transaction. This Privacy Policy will apply to your personal data as transferred to the new entity. We may also disclose personal data about you to our corporate affiliates in order to help operate our services and our affiliates’ services, including the delivery of ads.

e)     Non-Personal Information

We share or disclose non-personal data, such as aggregated information like the total number of times people engaged with a Post, demographics, the number of people who clicked on a particular link or voted on a poll in a Post (even if only one did), the topics that people are Posting about in a particular location, some inferred interests, or reports to advertisers about how many people saw or clicked on their ads.

4.    Managing Your Personal Information With Us

You control the personal data you share with us. You can access or rectify this data at any time. You can also deactivate your account. We also provide you tools to object, restrict, or withdraw consent where applicable for the use of data you have provided to SmuttyFy. And we make the data you shared through our services portable and provide easy ways for you to contact us. Please note, to help protect your privacy and maintain security, we take steps to verify your identity before granting you access to your personal information or complying with deletion, portability, or other related requests.

a)      Accessing or Rectifying Your Personal Data

If you have registered an account on SmuttyFy, we provide you with tools and account settings to access, correct, delete, or modify the personal data you provided to us and associated with your account. You can download certain account information, including your Posts, by following the instructions here.

b)     Deletion

We keep Log Data for a maximum of 18 months. If you follow the instructions on your profile, your account can be deleted. When deleted, your SmuttyFy account, including your display name, username, and public profile, will no longer be viewable on SmuttyFy.com, SmuttyFy for iOS, and SmuttyFy for Android. Keep in mind that search engines and other third parties may still retain copies of your public information, like your profile information and public Posts, even after you have deleted the information from our services or deactivated your account. Learn more here.

c)      Object, Restrict, or Withdraw Consent

When you are logged into your SmuttyFy account, you can manage your privacy settings and other account features here at any time. It may take a short amount of time for privacy settings to be fully reflected throughout our systems.

d)     Portability

SmuttyFy provides you a means to download the information you have shared through our services.

e)     Additional Information or Assistance

Thoughts or questions about this Privacy Policy? Please let us know by contacting us at legal@smuttyfy.com.

You can confidentially contact SmuttyFy’s Data Protection Officer by emailing to legal@smuttyfy.com. If you wish to raise a concern about our use of your information (and without prejudice to any other rights you may have), you have the right to do so.

5.    Children and Our Services

 Our services are not directed to children, and you may not use our services if you are under the age of 18. You must also be old enough to consent to the processing of your personal data in your country (in some countries we may allow your parent or guardian to do so on your behalf). 6

6.    Our Global Operations and Privacy Shield

To bring you our services, we operate globally. Where the laws of your country allow you to do so, you authorize us to transfer, store, and use your data in all countries where we operate. In some of the countries to which we transfer personal data, the privacy and data protection laws and rules regarding when government authorities may access data may vary from those of your country.

When we transfer personal data outside of the European Union or EFTA States, we ensure an adequate level of protection for the rights of data subjects based on the adequacy of the receiving country’s data protection laws, contractual obligations placed on the recipient of the data (model clauses may be requested by inquiry as described below), or EU-US and Swiss-US Privacy Shield principles.

7.    Changes to This Privacy Policy

We may revise this Privacy Policy from time to time. The most current version of the policy will govern our processing of your personal data and will always be at https://SmuttyFy.com/privacy. By continuing to access or use the Services after those changes become effective, you agree to be bound by the revised Privacy Policy.

 

Effective: March 1, 2020