Version 1.2 <br>
<br>
Last Revised: June 12, 2018 1.
ABOUT THIS PRIVACY POLICY Thank you for using Slidejoy and its related tools and services, including, without limitation, our mobile application (the “Application”) and our website at http://www.getslidejoy.com (the “Site”) (collectively, the "Services").
The Services are owned and operated by Buzzvil Co., Ltd.
("the Company," "we," "us" or "our").
The Application permits businesses and advertisers (collectively, “Advertisers”) to deliver attractive ads, coupons, deals, and other advertising content (collectively, “Ad Content”) to the mobile lockscreen of consumers who have downloaded and installed the Application (collectively, “End Users”, and each, an “End User”).
Slidejoy compensates End Users with reward points (“Reward Points”), which may be redeemable for cash, products and services, and in some cases may even be converted into charitable contributions.
To effectively offer and manage these highly interactive products and services, Slidejoy collects, stores and shares information about its users.
This Privacy Policy summarizes Slidejoy’s practices in these regards.
This Privacy Policy applies to information collected through the Services, as well as other information provided to us online or offline by End Users, Advertisers and other customers or users of our Site or Application.
however, it does not apply to information collected from our employees, contractors or vendors.
2.
CONSENT By using the Services, you consent to this Privacy Policy.
If you do not agree with this Privacy Policy, you may not use the Services, including, without limitation, our Site or Application.
Information gathered through the Services may be transferred, used, and stored in the United States and in foreign jurisdictions in which we, our agents, service providers, customers and other users of the Services are located.
If you access the Services, you consent to the transfer, use and storage of your Personal Information (as defined below) to and in those jurisdictions.
The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country.
You further agree that all transactions relating to the Services, the Site or the Application shall be deemed to have occurred in the United States.<br> European Economic Area, the United Kingdom, and Switzerland<br> If you are located in the European Economic Area, the United Kingdom, or Switzerland, publishers who would like us to serve you personalized ads must first obtain your consent so that Buzzvil and our partners can process your personal data for this purpose.
If you provide your consent, we will collect, use, share, and otherwise process all of the personal data described above for the purpose of serving you personalized advertising that Buzzvil and our partners believe is most relevant to you.
If you decide that you do not want a personalized advertising experience, we will not process your personal data for this purpose.
For example, we will not collect, use, or share your iOS Identifier for Advertising or Android Advertising Identifier, your precise location data, or your demographic or interest information.
However, we can still serve you contextual ads that are targeted to the content or type of app you are using.
You can withdraw your consent to our personalized lockscreen content experience at any time.
We provide a way for you to withdraw your consent to the Privacy Policy directly from within an app.
If you withdraw your consent from within an app, we will no longer collect, use, share, or otherwise process personal data from that app to personalize your advertising experience.
Even if you do not consent to a personalized advertising experience, or you later withdraw such consent, we will still process your personal data when necessary to comply with law or to support our legitimate interests, as described below.
We will process personal data as necessary to comply with the law.
For example, we will collect your IP address to perform a lookup of your country so that we know whether you are located in the European Economic Area, the United Kingdom, or Switzerland, but we will truncate your IP address before we process it for this purpose.<br> The United States and Other Countries<br> Opt-Out: If you are located in the United States or another country outside the European Economic Area, the United Kingdom, and Switzerland, you can opt out of receiving personalized advertising by using your applicable device settings: On iOS, you may opt out by enabling the “Limit Ad Tracking” setting.
On Android devices, you may opt out by enabling the “Opt out of Ads Personalization” setting.
3.
COLLECTION OF PERSONAL AND NON-PERSONAL INFORMATION We collect Personal Information in connection with our Services.
When we use the term "Personal Information" we are referring to information that can be used to identify an individual and may include, but is not limited to, your first and last name, by itself or combined with your unique user ID, password, gender, date of birth, address, email address, your brand preferences, your Facebook, Twitter or other social media handles, your geographic location if you are accessing the Services from a GPS-enabled mobile device, any other personal profile or account information you choose to submit through our Services, and (if applicable) your company name and business contact information.
Slidejoy or its third party payment transactions services provider may also collect credit, debit or other billing account information.
You may always choose not to provide Personal Information, but this may prevent you from receiving certain Services.
For example, in order to set up an End User account, you must provide a valid email address so that you can login and so that we can contact you pertaining important account activity.
If you do not complete the account signup process, we will not be able to display Ad Content on your lockscreen and you will not be able to collect or redeem Reward Points.
If you choose to use our Site’s social networking function to post information to Facebook, Twitter or another social networking site, we may collect your user ID and password information for that social networking site as necessary to make it easier for you to log in to the Services or interact with your social networks in other ways (for example, to share Ad Content with your friends on those social networks).
Specifically, and without limiting the generality of the foregoing, the Services may allow users to access "Facebook Connect" to interact with friends and to share on Facebook while using Slidejoy.
Should you choose to use the Facebook Connect feature, Slidejoy may collect certain information about you from your Facebook account, which will be specified at the time you first agree to sign in using Facebook Connect.
You can edit privacy settings for posts that appear on Facebook or disconnect the Facebook Connect service by using the privacy tools provided through Facebook.
Slidejoy may also collect your telephone number, which we may use to verify users and prevent duplicative accounts.
Slidejoy may also collect non-Personal Information (aggregate, non-individually identifiable or demographic information).
An example of non-Personal Information is system-related information such as IP addresses, click-through and other Application and Site use information (for example, we typically track each time you click on Ad Content from your mobile device lockscreen), browser and browser speed, bandwidth of your Internet connectivity, general location of your server and the pages of our Site or Application that were viewed during a visit, list of installed apps (the applications and/or processes which are installed or run on your device while the partner app is active or inactive), device sensor information (such as barometric pressure, accelerometer measurements, gyroscope measurements, device orientation, magnetic field measurements, direction of travel, motion activity (e.g.
walking), or other similar sensor measurements), etc.
We use this information to manage End User and Advertise accounts and for internal purposes to help us diagnose problems, monitor traffic patterns and otherwise continually improve our Services.
Please note that the Services may provide links to third party sites, such as links to the websites of Advertisers and other third-party organizations, businesses, and merchants who have agreed to make Ad Content and offers available to End Users through Slidejoy (including, but not limited to Outbrain, Inc.).
We are not responsible for the privacy policies, practices or the content of websites owned by others that you may link to or that may be linked from the Services.
Accordingly, we encourage you to review the privacy policies and terms of service of those websites so that you understand how those websites collect, use and share any Personal Information.
4.
USE OF PERSONAL AND NON-PERSONAL INFORMATION Slidejoy uses Personal Information in marketing products and services to you through the Slidejoy Application.
setting up and managing your End User or Advertiser account.
improving online operations.
processing transactions (for example, any credit, debit or other billing account information collected from you will only be used to process transactions requested by you).
sending text messages to your cell phone to inform you about special offers.
providing customer service.
providing you with newsletters, RSS feeds, and/or other communications or services which you have signed up for or otherwise agreed to receive (for example, messages about special offers).
displaying content that is customized to your interests or preferences (for example, we may target you with select custom ads, messages and offers, basing our selections on information, such as brand preferences, that you provided to Slidejoy at the time you registered or at other times).
sending account- or transaction-related communications such as welcome letters and transaction confirmations.
performing research and analysis aimed at improving our products, services and technologies.
and managing our systems.
We will only use your Personal Information in the way we specified when it was collected (including as described in this Privacy Policy).
We may use your non-Personal Information (including Personal Information that has been de-identified and/or aggregated) for any reason in Slidejoy’s sole discretion.
Any geolocation data will be collected from your mobile device only with your express opt-in consent, and such data will be used for the purpose of delivering customized services, such as displaying Ad Content featuring offers only available to End Users in particular cities or regions, determining the number of Reward Points to offer End Users, or identifying a segment of End Users which Advertisers have requested as an audience for viewing of particular Ad Content.
however, Advertisers will not have direct access to your location and will not be able to view your location on a map.
5.
DISCLOSURE OF PERSONAL AND NON-PERSONAL INFORMATION We work with Advertising Demand Partners, Supported Advertising Mediation Partners, Data Partners, and Fraud and Measurement Partners (collectively, “SlideJoy Partners”) in order to provide the our services.
Unless otherwise noted in our partner list, Slidejoy Partners are each independent controllers of your data.
If you are an End User, in order to effectively manage the Services, your non-Personal Information (including, without limitation, de-identified, aggregated Personal Information) will be disclosed to Advertisers to facilitate such account-related activities and to manage and improve our Services.
We may also disclose your Personal Information to Advertisers, with your express opt-in consent, where such sharing is required to deliver products or services that you have requested (including but not limited to facilitating your receipt or acceptance of offers or fulfillment or redemption of offers).
In addition, we may disclose Personal Information and non-Personal Information to companies, agents, contractors, service providers or others engaged to perform functions on our behalf (such as processing of payments, provision of data storage, hosting of our Site, marketing of our products and services, conducting audits, and performing web analytics).
We may also disclose your Personal Information to third parties when we believe, in good faith and in our sole discretion, that such disclosure is reasonably necessary to (a) enforce or apply the terms and conditions of the Services, including investigation of potential violations thereof, (b) comply with legal or regulatory requirements or an enforceable governmental request, (c) protect the rights, property or safety of us, our users or other third parties, (d) prevent a crime or protect national security, or (e) detect, prevent or otherwise address fraud, security or technical issues.
We may also disclose non-Personal Information to our clients, business partners, merchants, advertisers, investors, potential buyers and other third parties if we deem such disclosure, in our sole discretion, to have sound business reasons or justifications.
We do NOT sell, rent, share or trade your Personal Information to third parties for their own marketing purposes unless you have granted us permission to do so.
Please note also that if you choose to use our social networking function to post information to Facebook, Twitter or another social networking site, anyone who has access to your information through that other site will be able to see your information.
Slidejoy reserves the right to sell or transfer information (including your Personal Information and non-Personal Information) to a third party in the event of a sale, merger, or transfer of all or substantially all of the assets of our company, or in the unlikely event of a bankruptcy, liquidation or receivership of our business, and you hereby consent to any such sale or transfer.
If any such transfer is required, we will make reasonable efforts to notify you in writing in advance by posting a notice on the Site or Application and/or emailing you at your contact email address of record, and we will make reasonable efforts to ensure that the transferee will continue to use any Personal Information collected from you prior to the transfer in accordance with the terms of the then-current version of this Privacy Policy.
6.
ACCESSING AND UPDATING PERSONAL INFORMATION When you use our Services, we make good faith efforts to provide you with access to your Personal Information and either to correct this data if it is inaccurate or to delete such data at your request if it is not otherwise required to be retained by law or for legitimate business purposes.
We ask individual users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backups), or for which access is not otherwise required.
In any case, where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort.
Please e-mail us at app@getslidejoy.com if you need assistance accessing or changing your Personal Information or if you would like to have your Personal Information deleted.
Please be aware that if you delete your Personal Information, you may not be able to continue to use the Services, Application or Site.
Also, even if you request that we delete your Personal Information, we may need to retain certain information for a limited period of time to satisfy our legal, audit and/or dispute resolution requirements.
7.
COOKIES AND AUTOMATIC INFORMATION GATHERING TECHNOLOGIES We and our Advertisers, authorized service providers, advertising companies, and ad networks may use various activity tracking technologies, such as cookies, pixels and web beacons, to collect information from any computer or mobile device you use to access the Services about your activities on our Site or interaction with our advertisements (see “Information Collected by Third Parties” below).
A cookie is a small amount of data stored on the hard drive of your computer that allows your computer's browser to store your preferences and allows Slidejoy, our Advertisers, authorized service providers, advertising companies and ad networks to identify you by a unique identifier and associate this with corresponding information in our or their database.
Through the use of a cookie, we and these companies may store your non-personally identifiable registration information and user preferences and may also automatically collect information about your online activity on our Site, such as the web pages you visit, the links or advertisements you click, or the other actions you conduct while on our Site.
In addition, Slidejoy may set a cookie on your computer when you view our advertisements delivered on or in connection with a third-party website you are visiting.
After a cookie is set, Slidejoy may track how you interact with the Ad Content (for example, registering, purchasing, clicking, browsing, etc.).
Most browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies.
If you choose to decline cookies, please note that you may not be able to sign in or use some of the interactive features offered on our Services.
We do not tie tracking cookies used for behavioral or targeted advertising purposes to any Personal Information you submit while on our site.
however, cookies may be tied to your Personal Information solely for purposes of effectuating transactions you have requested and similar purposes related to the operation of our Site (such as managing our relationships with Advertiser and tracking, processing, maintaining and redeeming your Rewards Points).
They do NOT, however, collect Personal Information.
Although we may place or allow third parties to place their cookies when you visit our Site (as described more fully in the subsection below entitled “Targeted or Behavioral Advertising”), we do not have access or control over third party cookies nor does our privacy policy cover the use of cookies by third parties.
We may use other standard Internet activity tracking technologies, such as web beacons and similar technologies, to track your use on our Site, Application or your interactions with Ad Content.
A web beacon is a programming code used to display an image on a web page and can also transfer an individual's user identification to a database and associate the individual with previously acquired information about the individual.
Such information may be used in targeted or behavioral advertising, as well as for the other uses described in this paragraph.
We may include web beacons in promotional e-mail messages or newsletters or online advertisements to determine whether messages have been opened or acted upon.
We may use the information we obtain in this manner to customize the Services, Ad Content and offers we provide to users via our Site and Application, to deliver targeted advertisements through such vehicles, and to measure the overall effectiveness of our online advertising, content, programming or other activities.
We do not tie web beacons to any Personal Information you submit while on our Site.
Information Collected by Third Parties: Targeted or Behavioral Advertising.
Targeted advertising (also known as behavioral advertising) uses information collected on an individual's web browsing or mobile application behavior, such as the pages they have visited or the searches they have made to target advertising to the user based on this behavior.
This information is then used to select which Slidejoy advertising should be displayed to a particular individual on websites or mobile applications other than the Site or Application.
For example, if you have shown a preference for a certain product while visiting the Site, you may be served an advertisement from or about the Site for the same or a similar product when you visit a site other than the Slidejoy Site.
The information collected is only linked to an anonymous cookie ID (alphanumeric number).
it does not include any information that could be linked back to a particular person, such as their name, address or credit card number.
The information used for targeted advertising either comes from the Site, the Application or through third party website publishers.
In addition, we may place (or allow third parties to place) cookies and pixels on our Site or Application which enable our authorized service providers, advertising companies and advertising networks to collect information about our users who view or interact with their or our advertisements on our Site or Application or complete certain actions on our site, such as submitting an application or registration form.
However, we do not tie these cookies and pixels to personal information that you submit on our Site or Application.
The information collected by the cookies and pixels allows us and the companies mentioned above to deliver, and gauge the effectiveness of, targeted advertisements, both on our site and when you are browsing other websites.
Some of these third-party advertising companies may be advertising networks that are members of the Network Advertising Initiative (www.networkadvertising.org), which offers a single location to opt out of ad targeting from member companies.
8.
Global operation and Privacy Shield We base our services on AWS solutions, which has already obtained approval from EU data protection authorities, known as the Article 29 Working Party, of the AWS Data Processing Addendum and Model Clauses to enable transfer of data outside Europe, including to the U.S.
9.
OUR POLICY ON MINORS In principle, the Company does not collect any information from the children under 13 or equivalent minimum age as prescribed in the laws in the relevant jurisdiction.
The website, products, and services of the Company are the ones to be provided to ordinary people, in principle.
The Company does not intentionally collect any personal information from children.
If you are located in the European Economic Area, the United Kingdom, or Switzerland, you must be at least 16 years of age to consent to personalized advertising experience.
We do not collect or otherwise process personal data from individuals in the European Economic Area, the United Kingdom, and Switzerland whom it knows to be under 16 years of age, except for compliance with a legal obligation and pursuit of a legitimate interest.
We do not knowingly collect, maintain, or use Personal Information from children under 16 years of age, and no part of the Service is directed to children under the age of 16.
If you learn that your child has provided us with personal information without your consent, then you may alert us at dpo@buzzvil.com.
If we learn that we have collected any Personal Information from children under 16, then we will promptly take steps to delete such information.
10.
INFORMATION SECURITY We utilize reasonable information security measures to safeguard your Personal Information.
For example, industry-standard encryption (Hyper Text Transfer Protocol Secure a/k/a “https”) is used to protect communications between our servers and our users’ web browsers and mobile devices.
Unfortunately, however, no data transmission over the Internet and no method of data storage can be guaranteed to be 100% secure.
Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its security.
11.
YOUR CALIFORNIA PRIVACY RIGHTS A California resident who has provided personal information to a business with whom he/she has established a business relationship for personal, family, or household purposes ("California Customer") is entitled to request information about whether the business has disclosed Personal Information to any third parties for the third parties direct marketing purposes.
In general, if the business has made such a disclosure of Personal Information, upon receipt of a request by a California Customer, the business is required to provide a list of all third parties to whom Personal Information was disclosed in the preceding calendar year, as well as a list of the categories of Personal Information that were disclosed.
We will not share Personal Information about you with third parties for their own direct marketing purposes unless you affirmatively agree to such disclosure - typically by opting in to receive information from a third party through our Site.
To prevent disclosure of your Personal Information for use in direct marketing by a third party for its own purposes, do not opt in to or authorize such use when you provide Personal Information on our Site.
Please note that whenever you choose to share your Personal Information with a third party or allow your Personal Information to be shared with a third party to communicate with you (for example, if you are an End User, to facilitate your acceptance and/or receipt of special offers from an Advertiser), your information will be subject to the third party's privacy policy.
If you later decide that you do not want that third party to use your information, you will need to contact the third party directly, as we have no control over how third parties use information.
You should always review the privacy policy of any party that collects your information to determine how that entity will handle your information.
California Customers may request further information about our compliance with California's privacy law by e-mailing app@getslidejoy.com.
Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this e-mail address.
12.
PUBLIC MESSAGE BOARDS AND OTHER ONLINE FORUMS Please note that when you choose to post messages and/or profile content on messages boards and other online forums that we may make available on our Site or Application, such content is viewable by third parties and, in the case of public online forums and any public profiles, is publicly viewable.
Accordingly, you should exercise discretion with regard to what Personal Information you post on our Site or Application and you should not post highly confidential or sensitive information.
Slidejoy is not responsible for how third parties who view your Personal Information may use this information (such as to send you unsolicited messages).
13.
Data Protection Officer To communicate with our Data Protection Officer, please email dpo@buzzvil.com.
14.
CHANGES TO THIS POLICY Slidejoy may modify or update this Privacy Policy periodically with or without prior notice by posting the updated policy on the Site or Application.
We encourage you to check this Privacy Policy from time to time and to refer to the “Last Updated” date at the bottom of this document to see when the Privacy Policy was last changed.
We may also post a notice of changes to this Privacy Policy by e-mailing you about the changes.
Your continued use of our Site, Application or other Services following the effective date of an updated Privacy Policy constitutes your consent to the contents of such policy.
However, we will not apply any material changes retroactively to any information we collected from you before such changes took effect, without your affirmative consent to do so.
IF YOU DO NOT AGREE TO FUTURE CHANGES TO THIS PRIVACY POLICY, YOU MUST STOP USING OUR SITE AND APPLICATION AFTER THE EFFECTIVE DATE OF SUCH CHANGES.
Please note that upon discontinuing use of the Site, Application and/or other Services, any Privacy Policy in effect immediately prior to your departure shall continue to be binding on you and applicable to any data or information (including, without limitation, Personal Information) collected from you prior to such departure.
15.
HOW TO CONTACT US To ask questions about our Privacy Policy or to lodge a complaint, please contact us at: <br>
<br> Buzzvil Co., Ltd.<br> Attn: Privacy Matters<br> 3rd Floor, Daelim Building,<br> 272 Seokchon Lake, Songpa-gu,<br> Seoul, Korea<br> Email: app@getslidejoy.com<br>