Privacy Policy

1. Pattr Privacy Policy

This policy explains what information we collect when you use Pattr’s sites, services, mobile applications, products, and content (“Services”). It also has information about how we store, use, transfer, and delete that information. Our aim is not just to comply with privacy law—it’s to earn your trust.

Information We Collect & How We Use It

To give you the best possible experience when using Pattr, we collect information from your interactions with our Services. Some of this information you may actively tell us, such as your name, email address, phone number, or a photo of yourself, which we use to track your account or communicate with you. Other information we collect based on actions you take while using Pattr, such as what rooms you join and your use of product features. This information includes records of those interactions, your Internet Protocol address, and information about your device (such as device or browser type).

We use this information to:

· provide, test, improve, promote and personalize the Services

· fight spam and other forms of abuse

· generate aggregate, non-identifying information about how people use the Services

When you create your Pattr account, and authenticate with a third-party service (like Twitter, Facebook, Apple or Google) we may collect, store, and periodically update information associated with that third-party account. We will never publish something through one of your third-party accounts without your express permission.

Content of Conversations

Pattr may collect information such as types of conversations you join, rooms you join, features you use, and people you interact with.

We may analyze conversations to extract abstract attributes such as tone and mood, and may use the extracted attributes in order to provide the best possible user experience on the Service. However we do not perform voice recognition on any conversations on the Service, and do not generate, store, or use any semantic information from conversations except as explicitly reported by users.

Information Disclosure

Pattr won’t transfer information about you to third parties for the purpose of providing or facilitating third-party advertising to you. We won’t sell information about you to a third-party.

We may transfer your account information with third parties in some circumstances, including: (1) with your consent; (2) to a service provider or partner who meets our data protection standards; (3) with academic or non-profit researchers, with aggregation, anonymization, or pseudonymization; (4) when we have a good faith belief it is required by law, such as pursuant to a subpoena or other legal process; (5) when we have a good faith belief that doing so will help prevent imminent harm to someone.

If we are going to share your information in response to legal process, we’ll give you notice so you can challenge it (for example by seeking court intervention), unless we’re prohibited by law or believe doing so may endanger others or cause illegal conduct. We will object to legal requests for information about users of our services that we believe are improper.

Data Storage

Pattr uses third-party vendors and hosting partners, such as Amazon, for hardware, software, networking, storage, and related technology we need to run Pattr. By using the Services, you authorize Pattr to transfer, store, and use your information in the United States and any other country where we operate.

Tracking & Cookies

We use browser cookies and similar technologies to recognize you when you return to our Services. We use them in various ways, for example to log you in, remember your preferences (such as default language), evaluate email effectiveness, and personalize content and other services.

Some third-party services that we use to provide the Service, such as Google Analytics, may place their own cookies in your browser. This Privacy Policy covers use of cookies by Pattr only and not the use of cookies by third parties.

Modifying or Deleting Your Personal Information

If you have a Pattr account, you can access, modify or export your personal information, or delete your account along with its associated personal information. To request export or deletion you may email us at privacy@pattr.co.

To protect information from accidental or malicious destruction, we may maintain residual copies for a brief time period (generally several weeks). But, if you delete your account, your information and content will be unrecoverable after that time. Pattr may preserve and maintain copies of your information beyond this time period when required to do so by law.

Data Security

We use encryption (HTTPS/TLS) to protect data transmitted to and from our site. However, no data transmission over the Internet is 100% secure, so we can’t guarantee security. You use the Service at your own risk, and you’re responsible for taking reasonable measures to secure your account.

Business Transfers

If we’re involved in a merger, acquisition, bankruptcy, reorganization or sale of assets such that your information would be transferred or become subject to a different privacy policy, we’ll notify you in advance so you can opt out of any such new policy by deleting your account before transfer.

Email from Pattr

Sometimes we’ll send you emails about your account, service changes or new policies. You can’t opt out of this type of “transactional” email (unless you delete your account). But, you can opt out of non-administrative emails such as digests, newsletters, and activity notifications.

When you interact with an email sent from Pattr (such as opening an email or clicking on a particular link in an email), we may receive information about that interaction.

We won’t email you to ask for your password or other account information. If you receive such an email, please forward it to us at abuse@pattr.co so we can investigate.

Changes to this Policy

Pattr may periodically update this Policy. We’ll notify you about significant changes to it. The most current version of the policy will always be here and we will archive former versions of the policy.

2. Data Protection Statement for European Union Users

Description of Processing Activity

Pattr collects and stores personal information about its users to customize their experience and enable personalized recommendations. It shares minimal data with its service providers.

Purposes of Processing

· Provide, test, promote, and improve the Services

· Gather usage statistics of services

· Provide a customized experience

· Fight spam, fraud, and other abuse of services

Legal Bases

In order to provide the Services, Pattr collects and stores personal data about its users to fulfill its contractual obligations to users as described in our Terms of Service.

Public Nature of Personal Data

Logged-in users may choose to interact publicly with the Services in the form of sharing room links on connected social media accounts. Where such sharing may reveal special category protected data, it is processed on the basis that it is manifestly made public by the user. Additional information on potential consequences of such processing can be found below. If you do not agree to this public usage, do not create an account or use these features of the Services.

Search engines may index your Pattr user profile page and public interactions. Users may also share links to your public rooms on social media platforms such as Facebook or Twitter.

Categories of Personal Data Collected

Logged out users:

· IP address

· Browser information

· DNT status

Logged in users:

· Username

· Display name

· Bio

· Avatar image

· Email address (non-public)

· Session activity (security)

· Linked social media accounts (optional)

· IP address

· Browser information

· Conversation history

Categories of Recipients

Pattr shares minimal personal data with third-party processors in order to provide the Services. These processors offer at least the same level of data protection as that set out in this statement. This includes the following categories of recipients:

· Hosting, Storage, & Other Infrastructure

· Security

· Analytics

· Communication & Support

Use of Algorithms to Personalize User Experience

Pattr collects and stores personal data about its users to customize their Pattr experience by displaying recommendations tailored to the preferences and interests indicated by the users (including through their conversation history and Services interactions). This does not constitute automated decision-making as that phrase is used in the GDPR because it does not produce any legal effects or similarly significant effects for users.

Potential Consequences of Processing

By creating and using an account on Pattr, users may make certain personal data about themselves public and accessible to others on their profile and through network interactions. This may in some cases constitute special category protected data which is considered manifestly made public by the user.

Due to the public nature of information posted to Pattr, it may be possible for third parties to derive identifying personal data from the information, whether by reading, inference, supplemental research, or automated extraction and analysis.

Users are free to use their real name and information, or a pseudonym of their choosing, for their account. Users may also choose to use the service without creating rooms or engaging in network interactions. However, if you do not agree with and accept the risks of such usage, you may not use the Services.

Cross-border Transfers

Pattr is hosted in the United States. By using the Services, you authorize Pattr to transfer, store, and use your information in the United States and any other country where we operate. Where your data is disclosed to our processors, it is subject by contract to at least the same level of data protection as that set out in this statement.

Retention

Pattr retains personal data associated with your account for the lifetime of your account. If you would like to delete your personal information, you can delete your account at any time. Deleted account information will become unrecoverable in our system after a period of fourteen days.

Rights of Data Subjects

1. If you sign up for a Pattr account, you may at any time request an export of your personal information from the Settings page.

2. You may correct information associated with your account from the Settings and Profile pages.

3. You may withdraw consent by deleting your account at any time through the Settings page, which will erase your personal information completely within 14 days (except to the extent Pattr is prevented by law from deleting your information).

4. You may object at any time to the use of your personal data by contacting privacy@pattr.co. If your complaint relates to alleged misuse of your personal data by a third party, it may result in suspension of that account in keeping with relevant law, public interest, our contractual obligations, and the rights of expression and access to information of others.

5. Under EU law you have the right to lodge a complaint regarding the processing of your personal data by Pattr with the dedicated Supervisory Authority of your EU member state.

Subject Access Requests

For security and account ownership verification reasons, we process Subject Access Requests and account deletion requests from the account holder only. We are unable to process requests made by third-party services.

Contact Information

If you have any questions about this Privacy Policy, you can contact us at privacy@pattr.co.

3. Consumer Privacy for California Users

If you are a California resident, the processing of certain personal data about you may be subject to the California Consumer Privacy Act (“CCPA”) and other applicable California state privacy laws. Beginning January 1, 2020, the CCPA gives you certain rights with respect to the processing of your personal data (known as “personal information,” as described in the CCPA).

This section provides additional privacy disclosures and informs you of key additional rights as a California resident:

Right to Know Request

Under the CCPA, you have a right to request information about our collection, use, and disclosure of your personal information over the prior 12 months, and ask that we provide you with the following information:

1. Categories of and specific pieces of personal information we have collected about you.

2. Categories of sources from which we collect personal information.

3. Purposes for collecting, using, or selling personal information.

4. Categories of third parties with which we share personal information.

5. Categories of personal information disclosed about you for a business purpose.

6. If applicable, categories of personal information sold about you and the categories of third parties to which the personal information was sold, by category or categories of personal information for each third party to which the personal information was sold.

To make a verifiable request for information about the personal information we have collected about you, please email us at privacy@pattr.co.

Right to Delete Request

Under the CCPA, you also have a right to request that we delete personal information, subject to certain exceptions. You may exercise your right to delete if you have a Pattr account by emailing us at privacy@pattr.co.

Household Requests

We do not knowingly collect household data. If all the members of a household makes a Right to Know or Right to Delete request, we will respond as if the requests are individual requests.

General Requests under CCPA

If you do not have a Pattr account, we will not have enough information about you to verify your Right to Know and Right to Delete requests since we do not keep sufficient information to reidentify and link you to a prior visit to Pattr. You may make a verifiable consumer request related to your personal information twice per 12-month period. We will not discriminate against you for exercising any of your rights under the CCPA.

Requests made through Agents

You may designate, in writing or through a power of attorney document, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us.

Disclosures of Personal Information for a Business Purpose

In the last 12 months, Pattr has disclosed certain data from the following categories of personal information to the categories of recipients listed above in the ‘Categories of Recipients’ for one or more business purposes:

Logged in users:

· Username

· Display name

· Avatar image

· Email address (non-public)

No Sale of Personal Information

Under the CCPA, a “sale” means providing to a third party personal information for valuable consideration. At this time and pending final regulations and guidance interpreting the CCPA, we don’t believe any of our data practices constitute a “sale” under the CCPA.

You may contact us regarding this policy by emailing us at privacy@pattr.co.