- Breadcrumb does not itself host the Services – all hosting is done by third party hosting providers that we engage. This means that data you provide us or that we or third parties collect from you (including any Personal Information) is hosted with such third party service providers on servers that they own or control. Regardless of where such third party service providers themselves are based (and some are US-based), their servers may be located anywhere in the world (including the US). Your data may even be replicated across multiple servers located in multiple countries. So please be aware that you are consenting to your data being transferred to various third party service providers around the world.
- Generally speaking, Breadcrumb receives information because:
- you have provided it to us;
- we collect it from you; and/or
- third parties we engage (such as a data analytics provider) collect it from you on our behalf. This happens in cases where we use or deploy third party tracking technology, or where we otherwise give these third parties access to our technology. So where we describe below in Section 4 (Information We Collect From You) the ways in which we collect information from you, you acknowledge that such collection may also be carried out by third parties.
“Personal Information” means information that may be used, either alone or in combination with other information, to personally identify an individual, such as a first and last name, an email address, profile picture, product reviews, phone number, a home or other physical address, and other contact information.
“Anonymous Information” means information which is not Personal Information, including without limitation aggregated or statistical information, and Personal Information that has been de-identified, hashed or otherwise anonymized.
- Information You Provide To Us. Currently, we require you to provide us with certain types of Personal Information in order to use the Services and benefit from some of its features. Here are some examples:
- Account Creation. In order to create an App account (“Account“), you may be required to have, and provide us with, a telephone number. Creating an Account may also require you (or in some cases, may just give you the option) to provide other Personal Information, such as your name, profile picture, birthday and email address.
- ‘Contact Us’. If you send us a ‘Contact Us’ (or similar) request, whether by submitting an online form that we make available, by sending an email to an email address that we display, by using an in-App feedback or reporting feature, or by other means, you may be required to provide us with certain Personal Information, such as your name and email address.
- Purchases. The Apps and the Sites may offer the option of purchasing certain products or services from us or our Affiliates. If you choose to make a purchase we will require sufficient Personal Information from you in order to process the purchase. Such information could include a credit card number and related account and billing information. We may use the products and services of third party service providers to process these purchases, in which case you will be providing the information to them as well.
- Information We Collect From You. We may collect Personal Information and Anonymous Information from you in the following ways:
- Pre-Registration. After you have downloaded the Breadcrumb – Live Video Messenger App, but before you create your profile and provide us with certain Personal Information, Breadcrumb automatically collects certain Personal Information: (a) from your device (for example, retrieving your phone number from your SIM card, and other information from SMS messages stored on your device that enables us to verify your identity); and (b) from your publicly-available profiles on other applications (for example your name, email address, and profile pictures).
- Account Login. If, as part of your use of an App, you connect your App account with an account from a supported social network account, such as Facebook (a “Social Media Account“), we may receive Personal Information from the corresponding social network that relates to your Social Media Account. Such Personal Information may be about you and/or your Social Media Account contacts. Please check the policies of the applicable social network in order to understand what information we receive. Even if you later disconnect your App account from your Social Media Account, we still keep a copy of the Personal Information (such as your Social Media Account profile photo and your contact list) that we received from the connection of the two accounts, so that we may more easily connect you with your Social Media Account contacts who register with the App in the future.
- Address Book Information. We collect information from your device’s address book, which may include the names and contact information of individuals contained in your address book (collectively, “Address Book Information“). Currently, we use Address Book Information for the purpose of enabling you to send invitations and messages, to build a list of your contacts, and to notify you if one of your contacts registers with the corresponding App.
- Invitations. The Apps currently allow you to invite your contacts to download the App. This can be done using different methods. Depending on the method used, by sending an invitation we may collect Personal Information about the recipient, such as their email address, phone number, and Social Media Account information.
- Geolocation. We collect information from your device about your location (“Geolocation Information“). Currently, we only use Geolocation Information for routing optimization and user-search optimization on our messaging platform, as well as for general analytics.
- Log Files; Device and Usage Data. We collect information through server log files, but also by deploying tracking technologies within the Services. We do this to analyze trends, track user movement around the Services, gather demographic information, and to generally collect information that we may find insightful or helpful. The type of information collected may include (but is not limited to) internet protocol (IP) addresses, MAC address, phone number, device type, browser type, operating system type, type of browser, Internet Service Provider (ISP), date/time stamp of Services use, referring/exit pages, and clicked pages.
- To Generally Provide You With Our App; Marketing Campaigns. We will use your Personal Information to: (a) administer and provide the Services to you; (b) further develop and generally improve the Services; (c) send you updates, promotions, offerings, or other news of/about the Apps or Breadcrumb; (d) respond to communications with you; (e) identify or authenticate your access and use of the Services; (f) send you commercial email, text messages and other communications, advertisements or other marketing content, including of third parties; and/or (g) in our marketing campaigns promoting the Apps, Breadcrumb, or our other products or services (for example, using your name, profile picture and reviews in marketing campaigns to encourage people to download the Apps). For our marketing campaigns described in subparagraph (g) of this Section, Breadcrumb will make commercially reasonable efforts to not use Personal Information that Breadcrumb considers, in its sole and absolute discretion, to be especially private or confidential; but, for clarity, Breadcrumb does not consider your name, Account profile picture or product review to be private or confidential for such purposes (and you acknowledge this).
- Enforcement. We may share your Personal Information with any third party if we believe that disclosure of such information is helpful or reasonably necessary to: (a) comply with any applicable law, regulation, legal process, or governmental request; (b) enforce any of the App Licensing Terms, including investigations of potential violations thereof; (c) detect, prevent, or otherwise address fraud or security issues; and/or (d) protect against harm to the rights, property or safety of Breadcrumb, our users, yourself or the public.
- Publicly Available Information. Your public profile and any content that you make publicly available on or via the Services will be publicly available to other users of the Services. If you actively or passively allow your contact information to be public (such as by not opting out of being searchable, by publishing your BreadcrumbID on Twitter, or by joining the Discover People feature in the Breadcrumb – Live Video Messenger App), you may receive unsolicited messages from other users of the Services. We therefore encourage you only to post information that you are sure you want to be publicly accessible. You also assume responsibility for Personal Information of third parties that you publish or share through the Services.
- Anonymous Information. We may use and share Anonymous Information for any purpose whatsoever and with any third parties (such as advertisers and marketing partners), including in exchange for compensation.
Google AdWords remarketing service is provided by Google Inc. You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads
Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/
Twitter remarketing service is provided by Twitter Inc. You can opt-out from Twitter’s interest-based ads by following their instructions: https://support.twitter.com/articles/20170405
Facebook remarketing service is provided by Facebook Inc. You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950
To opt-out from Facebook’s interest-based ads follow these instructions from Facebook: https://www.facebook.com/about/ads/#568137493302217`
Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.
For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation
- Access and Accuracy; Deleting Messages. We would like to maintain accurate Personal Information. If you would like to delete or correct any of your Personal Information that we may be storing, you may use the tools that we make available in the applicable App. Please be aware that in some Apps, communications exchanged with other App users may not be permanently deleted from our servers, even if you delete them from your Account or device. For example, in the Breadcrumb – Live Video Messenger App, any Message (as defined in its App Licensing Terms) you delete (whether directly by you or pursuant to a delete request) may or may not be permanently deleted by Breadcrumb, and may remain stored on our servers. In such cases, the Message will no longer be accessible to you or the recipients to whom you sent the Message. We, in our sole and absolute discretion, decide whether or not to permanently delete communications (including Messages) from our servers.
- Opt-Out. Currently, the Apps do not offer tools that allow you to opt-out of the collection of Personal Information. The Apps may, however, offer tools that allow you to opt-out of being searchable.
- Children’s Privacy. The Services are not designed to attract children under the age of 13. Accordingly, we do not intend to collect Personal Information from anyone we know to be under 13. If we learn that we have collected Personal Information from a child under 13, we will use commercially reasonable efforts to delete that information as quickly as possible. If you believe that we might have any such information, please contact us at email@example.com.
- Security. We use administrative, physical and technical safeguards to protect Personal Information. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we try to use reasonably acceptable means to protect your Personal Information, we cannot guarantee its absolute security or confidentiality. If you have any questions about security on the Apps, you can contact us at firstname.lastname@example.org (for the Breadcrumb – Live Video Messenger App) and info@breadcrumbtech (for the Breadcrumb Companion App).
- Merger, Sale or Bankruptcy. In the event that Breadcrumb is acquired by or merged with a third party entity, we may (and hereby reserve the right to) transfer or assign the Personal Information and other information we have collected or received. In the event of a bankruptcy, insolvency, receivership, or comparable event, we may not be able to control how your Personal Information is treated, transferred, or used.
- California Privacy Rights. California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to email@example.com (for the Breadcrumb – Live Video Messenger App) and info@breadcrumbtech (for the Breadcrumb Companion App). Please note that we are only required to respond to one request per customer each year.
- Our California Do Not Track Notice. We do not currently respond or take any action with respect to web browser “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of Personal Information about that individual consumer’s online activities over time and across third-party web sites or online services. We may allow third parties, such as companies that provide us with analytics tools, to collect Personal Information about an individual consumer’s online activities over time and across different web sites when a consumer uses the Apps.
- Deletion of Content from California Residents. If you are a California resident under the age of 18 and a registered user of an App, California Business and Professions Code Section 22581 permits you to remove content or information you have publicly posted. If you wish to remove such content or information and you specify which content or information you wish to be removed, we will do so in accordance with applicable law. Please be aware that after removal you will not be able to restore removed content or information. In addition, such removal does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require us to enable removal of the content or information.
Last updated: June 26, 2017
Examples Of Third Parties We Engage