Privacy issues are important to Squawkin, Inc. (“Squawkin” or “we”), and we want you to be familiar with how we collect, use and disclose information. This Privacy Policy describes our practices in connection with information that we collect through websites operated by us from which you are accessing this Privacy Policy; through the software applications made available by us for use on or in connection with mobile devices, tablets, and personal computers; through our social media pages and apps located at facebook.com/squawkinapp, twitter.com/squawkin, and instagram.com/squawkinofficial (collectively, “Social Media Pages”), and through HTML-formatted email messages that we send to you that link to this Privacy Policy (collectively, including the websites, software applications, and our Social Media Pages, together with any materials and services available in connection with them and any successors to them, the “Services”). By downloading, accessing or using the Services, or by providing information (including Personal Information (as defined below)) to us, you agree to the terms and conditions of this Privacy Policy.

PERSONAL INFORMATION

Personal Information We May Collect

“Personal Information” is information that identifies you as an individual, including your name and email address.

If you submit any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

Please note that we may use a third-party payment service to process payments made through the Services. If you wish to make a payment through the Services, your Personal Information may be collected by such third party and not by us, and will be subject to the third party’s privacy policy, rather than this Privacy Policy. We have no control over, and are not responsible for, this third party’s collection, use and disclosure of your Personal Information.

How We May Use Personal Information

We may use Personal Information:

• To respond to your inquiries and fulfill your requests, such as to send you newsletters and to operate the Services.
• To send administrative information to you, for example, information regarding the Services and changes to our terms, conditions, and policies.
• To complete and fulfill your purchase, for example, to process your payments, have your order delivered to you, communicate with you regarding your purchase and provide you with related customer service.
• To send you marketing communications that we believe may be of interest to you.
• To personalize your experience on the Services by presenting products and offers tailored to you.
• To facilitate social sharing functionality, including in connection with groups and crowds.
• To allow you to send and receive “Squawks,” texts, images, video and voice transmissions, and other messages to or from other individuals through the Services. By using this functionality, you are telling us that you are entitled to use and provide us with the applicable individual’s name, email address, account ID, and other applicable Personal Information.
• To provide a public directory of users and to identify you in connection with your use of the Services to other users whom you may potentially know.
• For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying our Services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.
• As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

We may use Personal Information:

Your Personal Information may be disclosed:

• To our third party service providers who provide services such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, credit card processing, auditing and other similar services.
• To third parties to permit them to send you marketing communications, if you have opted in to such sharing.
• By you, on the Services’ interactive services (such as groups, crowds, and other forums, and through “Squawk,” texting, image sharing, video conferencing, voice transmission, and other messaging functionality) and other services to which you are able to post information and materials (including without limitation our Social Media Pages). Please note that any information you post or disclose through these services may become public information, and may be available to users of the Services and to the general public. We urge you to be very careful when deciding to disclose your Personal Information, or any other information, on the Services.
• To identify you to anyone to whom you send “Squawks,” texts, images, video and voice transmissions, and other messages through the Services.
• To other users of the Services in connection with your social sharing activity through the Services, such as other users in a group or crowd that you have joined.
• To a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
• As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

OTHER INFORMATION

Other Information We May Collect

“Other Information” is any information that does not reveal your specific identity, such as:

• Browser and device information
• Usage data (such as, number of calls made and received, call duration, voice message duration, and text message usage) that does not reveal an individual’s identity
• Physical location information
• Information collected through cookies, pixel tags and other technologies
• Demographic information and other information provided by you
• Aggregated information

How We May Collect Other Information

We and our third party service providers may collect Other Information in a variety of ways, including:

• Through your browser or device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services you are using. We use this information to ensure that the Services function properly.
• Through your use of the Services: When you download and use the Services, we and our service providers may track and collect usage data, such as the date and time the Services on your device accesses our servers and what information and files have been downloaded to the Services based on your device number.
• Using cookies: Cookies are pieces of information stored directly on the device that you are using. Cookies allow us to collect information such as browser type, time spent on the Services, pages visited, language preferences, and other anonymous traffic data. We and our service providers use the information for security purposes, to facilitate navigation, display information more effectively, and to personalize your experience while using the Services, as well as for online tracking purposes. We can recognize your device to assist your use of the Services. We also gather statistical information about the usage of the Services in order to continually improve the design and functionality of the Services, understand how the Services are used and to assist us with resolving questions regarding the Services.

If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies, or be given the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a particular site. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. However, if you do not accept these cookies, you may experience some inconvenience in your use of the Services. For example, we may not be able to recognize your device and you may need to log in every time you visit the applicable Services.

• Using pixel tags and other similar technologies: Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some Services to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the Services and response rates.
• IP Address: Your “IP Address” is a number that is automatically assigned to the device that you are using by your Internet Service Provider (ISP). An IP Address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice and is done automatically by many websites, applications and other services. We use IP Addresses for purposes such as calculating usage levels of the Services, helping diagnose server problems, and administering the Services.
• Physical Location: We may collect the physical location of your device by, for example, using satellite, cell phone tower or WiFi signals. We may use your device’s physical location to provide you with personalized location-based services and content. In some instances, you may be permitted to allow or deny such uses and/or sharing of your device’s location, but if you choose to deny such uses and/or sharing, we may not be able to provide you with the applicable personalized services and content.
• From you: Information such as your location, as well as other information, such as your preferred means of communication, is collected when you voluntarily provide this information. Unless combined with Personal Information, this information does not personally identify you or any other user of the Services.
• By aggregating information: Aggregated Personal Information does not personally identify you or any other user of the Services, (for example, we may aggregate Personal Information to calculate the percentage of our users who have a particular telephone area code).

How We May Use and Disclose Other Information

Please note that we may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, then we may use it for all the purposes for which we use and disclose Personal Information.

In some instances, we may combine Other Information with Personal Information (such as combining your name with your geographical location). If we combine any Other Information with Personal Information, the combined information will be treated by us as Personal Information as long as it is combined.

THIRD PARTY SERVICES

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.

Please note that we are not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of other organizations, such as Facebook, Instagram, Twitter, Apple, Google, Microsoft, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including any Personal Information you disclose to other organizations through or in connection with the Services (including our software applications and our Social Media Pages).

SECURITY

We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. Please also be aware that we may use third-party cloud service providers that provide hosting, data storage and other services pursuant to standard terms and conditions that are generally non-negotiable; accordingly, although we seek to conduct reasonable due diligence on such service providers, we may be unable to impose contractual obligations on them with respect to the measures they use to protect Personal Information. We are not responsible for the data security measures of such third parties.

If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the “Contacting Us” section below.

CHOICES AND ACCESS

Your choices regarding our use and disclosure of your Personal Information for marketing purposes

If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt- out of receiving these marketing-related emails by clicking the unsubscribe link contained in each of these emails.

Please note that if you do opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, and you cannot opt-out from receiving administrative messages.

How you can update your Personal Information

If you would like to update Personal Information that you have provided to us, you may do so by logging into your account within the Services.

USE OF SERVICES BY MINORS

The Services are not directed to individuals under the age of thirteen (13), and we request that these individuals do not provide Personal Information through the Services.

CROSS-BORDER TRANSFER

The Services are controlled and operated by us from the United States, and are not intended to subject us to any non-U.S. jurisdiction or law. Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have different data protection rules than those of your country.

SENSITIVE INFORMATION

We ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers or health information) on or through the Services or otherwise to us.

UPDATES TO THIS PRIVACY POLICY

We may change this Privacy Policy from time to time. We will notify you of any changes or updates to our Privacy Policy by posting a revised Privacy Policy on the Services. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the Services. Your use of the Services following any changes to this Privacy Policy will constitute your acceptance of such changes. The “LAST UPDATED” legend above indicates when this Privacy Policy was last changed.

CONTACTING US

If you have any questions about this Privacy Policy, please contact us by email at legal@squawkin.com.

Please note that email communications are not always secure; so please do not include credit card information or sensitive information in your emails to us.