Together Privacy Policy
Last Updated: May 31, 2023
This Privacy Policy ("Policy") applies to Togetherapp.com, Together App, and other Togetherrelated sites, apps, communications, and services ("Together Services"). GLOBAL CONNECTIONTECHNOLOGIES LIMITED., (referred to as "we," "us," "our") is the service provider and operator of Together Services. We value and respect your privacy, and we are committed to protecting it in compliance with this Privacy Policy and applicable laws and regulations, including the California Consumer Privacy Act (CCPA). This Policy aims to provide you ("you," "User") with an understanding of our practices concerning the collection, use, share and storage of personal information we collect from or about you when you interact with us, as well as your rights regarding the information you provide and how we safeguard those rights. It is important to note that this Policy does not apply to any products, services, websites, or content offered by third parties ("Third-Party Services"). Third-Party Services are governed by their respective privacy policies, and we encourage you to review the privacy statements of any Third-Party Service you may choose to use. We strongly advise you to read this Policy carefully to understand our practices regarding your personal information. We also recommend visiting this Policy frequently to stay informed of any updates. If you have any questions, please feel free to contact us at [email protected].
This Policy will help you understand the following contents:
1. What Information We Collect About You
2. How We Use Your Information
3. How We Share Your Information
4. Children’s Privacy
5. Your Rights and Choices
6. Third-Party Service Providers and Services
7. Data Security and Retention
8. International Data Processing & Transfer
9. Update of this Policy
10. How to Contact Us
11. Supplemental Terms - Jurisdiction Specific
Terms
1. What Information We Collect About You We collect information about you through various means when providing the Together Services. Please note that certain types of information are necessary for us to provide the Together Services to you. If you choose not to provide us with such information or request its deletion, you may no longer be able to access or use the Together Services. We collect your information in the following ways: Information You Provide Directly to Us Profile information: This includes your nickname and avatar. Registration details: We may collect your email address, gender, date of birth, phone number, registration region and nationality inferred by your registration region. User-generated content: If you create or upload content, such as audio, comments, or pictures (referred to as "User Content"), we collect this content and associated metadata, including details of when, where,score, and by whom the content was created. Messages. This includes the content of messages and voice messages exchanged through Together's messaging functionalities, as well as information regarding message timestamps, recipients, and read statuses. Information, including text, images, and links found in your device’s clipboard, with your permission. For example, if you choose to initiate information sharing with a third-party, or choose to paste content from the clipboard onto Together, we access this information stored in your clipboard in order to fulfill your request. Transaction information. When you make purchases related to Together, we collect the order number and information about the goods or services you have purchased. This helps us understand user feedback and analyze consumption patterns. Account verification information. In some cases, we may require proof of identity or age to verify your account. Correspondence information. If you contact us for support, we also collect the correspondence information to provide user feedback service to you. Information We Obtain Automatically We automatically collect certain information from you when you access and use Together Services, including your Internet Protocol address ("IP Address") and device identifiers. Here is an overview of the information we collect: Device Information. When you start using Together Services, we collect information about the mobile device you are using, such as your IP Address, identifiers for advertising purposes, device model, operating system, system language and region, mobile carrier, network type, and App version. We assign you a unique device ID and user ID. If you log in from multiple devices, we use this information to identify your activity across devices. Location Information. We collect information about your approximate location, including location information based on your SIM card and/or IP address. With your permission, we may also collect precise location information, such as GPS. Usage Information. When you use Together Services, we collect information regarding your use of the Together Services. This includes information about your interactions with Together (e.g., your log information, or actions you take within the app). Information We Obtain from Other Sources We may receive information about you from other sources, such as Third-Party Services, in accordance with their privacy policies. Third-Party Services. If you choose to sign up or log in to Together using a third-party service like Facebook, Twitter, Apple, or Google, or if you link your Together account to a third-party service, we may collect information from that service, such as your public profile information (e.g., nickname and avatar). Advertisers and Partners. Our advertisers, measurement partners, and other trusted partners may share information with us about your activities outside of Together, such as your actions on other websites, apps, or in physical stores. This may include information about products or services you purchased. This information, including mobile identifiers for advertising, is used to help match your actions outside of Together with your Together account. Other Third Parties: In accordance with applicable law, we may obtain your personal information from individuals, business entities, public sources, or other third parties acting on your behalf or in partnership with us. We will explain this to you at the time of collection and obtain your consent. We may also use other methods to collect additional information about you, your device, or your use of the services. We will explain these methods to you at the time of collection and obtain your consent if required by applicable laws. Please note that we are not responsible for the privacy practices of our service providers and business partners, and their information practices are not covered by this Policy. We may aggregate or de-identify the information described above, and such aggregated or de-identified data is not subject to this Policy.
2. How We Use Your Information We use the information we collect from you to ensure the operation, maintenance, enhancement, and development of all features, functionality, and services offered on Together Services. Here is an overview of how we use your information: Security and Fraud Prevention. We use your information to provide security for our websites, products, software, and applications. This includes preventing fraud and abuse. Service Provision and Support. We use your information to fulfill your requests for services, support, and information. This includes internal operations such as troubleshooting, testing, research, statistical analysis, data analysis, and soliciting your feedback. Improving and Developing Together Services. We use your information to improve and develop Together Services, ensuring that we continue to enhance the platform based on user feedback and needs. Social Functions of Together. We utilize your information to support the social functions of Together, allowing you and other users to utilize features such as voice chat and the Birthday Party Event service. Location-Based Services. With your permission, we provide location-based services to enhance your experience. This may include helping you find users nearby and matching you with nearby players for Together in-app games. Age Verification. To comply with legal requirements, we use your information to ensure that you meet the age restrictions for using Together Services. For example, we may ask for your age when entering in-app games to verify if you are over 16 years old. Communication and Feedback. We use your information to communicate with you and respond to your feedback. This enables us to address your inquiries, provide support, and keep you informed about updates and developments. Enforcement of Policies. We utilize your information to enforce our Terms of Service, Community Guidelines, and other policies to maintain a safe and positive environment for all users. Sales and User Support. We use your information to facilitate sales, promotions, and purchases of goods and services on Together Services. Additionally, we provide user support to assist you with any issues or inquiries related to your interactions on the platform. Occasional Promotional Activities. From time to time, we may launch promotional activities. If you choose to participate in such activities, we will collect the information you voluntarily provide, such as your name and contact details, to contact you and grant you prizes. Your participation in these activities is voluntary, and if you choose not to provide the necessary information, it may affect your eligibility for the prizes, but it will not impact your normal use of other features. In certain cases, we may seek your consent to process your personal information for specific purposes. If you provide consent, you can withdraw it at any time, and we will cease processing your data for that purpose.
3. How We Share Your Personal Information Together does not sell your personal information to third parties. However, we may share your information in the following ways: Delegation to Affiliates We may delegate the processing of your personal information to our affiliates to fulfill the purposes described in this Policy. Such delegation will be within the scope of the purposes described, and we ensure that our affiliates comply with the provisions of this Policy regarding the retention of personal information. Service Providers and Business Partners We may share certain information with service providers and business partners to assist us in performing business operations and for business purposes. These parties may include website hosting providers, database maintenance providers, data storage and security service providers, payment processors, transaction fulfillment providers, advertising and marketing vendors, and others. We require these parties to process the information in compliance with this Policy, limit its use to the purposes for which it is provided, and implement reasonable confidentiality measures. Corporate Transactions In the event of a substantial corporate transaction such as the sale of a website, merger, consolidation, asset sales, or bankruptcy, we may share all the information we collect. Legal Compliance and Protection We may disclose your information when required by law, subpoena, or other legal process, or when we have a good faith belief that disclosure is reasonably necessary to investigate, prevent, or take action regarding suspected or actual illegal activities, assist government enforcement agencies, enforce our agreements with you, investigate and defend against third-party claims or allegations, protect the security or integrity of our services, or exercise or protect the rights and safety of Together, our users, personnel, or others. We strive to notify users about legal demands for their personal information unless prohibited by law or court order, or in case of emergencies. We may choose to challenge such demands when we believe they are overbroad, vague, lack proper authority, but we do not guarantee to challenge every demand. Consent and Third-Party Services We partner with third-party services (e.g., Facebook) to provide sign-up, log-in, and content-sharing experiences. If you choose to use these features, we may share information about you with these Third-Party Services. Depending on the permissions you grant, these Third-Party Service may access your account information and other information you choose to provide. When engaging in public activities on Together, be cautious about disclosing personal information, as it may be read, collected, or used by other users. Together is not responsible for the information you choose to submit in such cases. It's important to review and understand the privacy practices of our Third-Party Service Providers and business partners, as their information practices are not covered by this Policy.
4. Children's Privacy
Together Services are not intended for children under the age of 13 (or the minimum age required by local law), and we do not knowingly collect personal information from children. If you are a parent or guardian and want to review, modify, or delete any information collected from your child, you can contact us using the information provided below. If we become aware that a child has provided us with personal information in violation of applicable laws, we will delete the information we have collected and terminate the child's account unless we have a legal obligation to retain it.
5. Your Rights and Choices
You have the right to submit a request to know, access, correct, or delete the information we have collected about you. You can do this by contacting us at [email protected]. If you disagree with any decision we have made regarding your request, you can follow the instructions provided in the communication you receive from us to appeal that decision. Additionally, you have the ability to update your account information directly through the settings within the app. You also have the right to request a copy of your information we have collected about you, as well as the option to request the deactivation or deletion of your account. As part of your right to know, you are entitled to receive specific details about the personal information we have collected, including the categories of sources from which the information was obtained, the business or commercial purpose for collecting or sharing the information, and the categories of third parties with whom we share the information. It is important to note that we do not discriminate against you based on your exercise of privacy rights. If allowed by applicable law, you have the option to designate an authorized agent to act on your behalf and exercise your rights. To designate an authorized agent, you will need to provide evidence that the agent has the necessary authority, such as a power of attorney or valid written authorization. We will respond to your requests in accordance with applicable law and after verifying your identity. We may request additional information from you to confirm your identity and ensure that we are providing access to the correct person's information. While we generally do not charge a fee for processing lawful and reasonable requests, we may charge a reasonable fee for repeated requests that exceed a reasonable limit, as permitted by applicable laws and based on actual administrative costs. We may refuse to process certain requests or only respond to some of your requests if exemptions apply or if we are otherwise entitled to do so under applicable laws. For example, we may not fulfill requests that are manifestly unfounded, obviously excessive, or require the disclosure of third-party information. It's important to understand that, for security reasons, we may request additional information to confirm your identity and ensure the protection of personal information before processing your request.
6. Third-Party Service Providers and Services
During your use of Together Services, you may encounter links to third-party websites or content and services provided by third parties. Some third-party products or services may be accessed through SDKs or other means to provide certain functions and features in Together, such as thirdparty logins, notifications, and user analysis. It is up to you to decide whether to visit or accept the offerings of third-party websites, products, and services. Please note that this Policy does not apply to products and services provided by third parties. As we have limited control over third parties, we are not responsible for their collection and processing of your personal information. Together utilizes the YouTube Data API and YouTube IFrame Player API. To understand how your personal data is used and processed in relation to these APIs, please refer to the YouTube Terms of Service and Google Privacy Policy.
7. Data Security and Retention
We employ various managerial, technical, and physical measures to safeguard the integrity and security of your information. The specific measures used may depend on the sensitivity of the information. However, it's important to understand that no security measures or systems can provide absolute guarantee of protection. We evaluate these measures on a regular basis to ensure the security of the processing. We retain data related to your use of Together Services for as long as necessary to fulfill the purposes outlined in this Policy or as required by applicable laws. This may include retaining information for tax and accounting purposes, compliance with contractual and legal obligations, legitimate business interests (such as improving and developing Together Services, enhancing safety, security, and stability), and the exercise or defense of legal claims. The retention periods for different types of information and purposes may vary. For example, if you have an account, we retain your profile information as long as your account is active. In case of violations of our Terms of Service, Community Guidelines, or other policies, we may take immediate action to remove your profile. In such cases, we may also retain other relevant information about you to address and resolve the violation in accordance with our policies and legal obligations.
8. International Data Processing & Transfer
Information collected by Together is stored and processed in the United States and Singapore. If we share information about you with Together affiliates, subsidiaries, partners, or service providers, we take appropriate measures to ensure that such entities adequately protect your information in accordance with this Policy and applicable laws.
9. Update of this Policy
We reserve the right to periodically update or modify this Policy to reflect changes in our business, technology, and relevant laws and practices. Whenever we make updates to the Policy, we will notify you by updating the "Last Updated" date at the top of the revised Policy, or providing any other notice as required by applicable law. We strongly recommend that you review the Policy each time you visit Together to stay informed about our current privacy practices.
10. How to Contact Us
If you have any comments, questions, or concerns regarding our Privacy Policy or personal information protection practices, please contact us at [email protected]. Please label all requests as "Together Privacy Policy request" in the email subject line to help us assist you more effectively. If your request involves complex or significant issues, we may require additional information.
11. Supplemental Terms - Jurisdiction Specific Terms
In some jurisdictions where you access or use Together Services, applicable laws may require us to supplement this Policy with jurisdiction-specific terms. These supplemental terms are an integral part of this Policy. In the event of any conflict between the provisions of the Supplemental Terms and the rest of this Policy, the Supplemental Terms will prevail. For California Residents: If you are a California resident, you may have the right, once per calendar year, to request information about the personal information we have shared with third parties for their own direct marketing purposes. This includes categories of user information shared and contact information of relevant third parties. If you would like to exercise this right, please email your request to us using the provided contact information. Content Removal for Users Under 18. California residents who are under 18 years old and users of Together may request the removal of User Content they have posted. To request removal, please contact us using the provided contact information and provide a description of the User Content you want to be removed, along with information reasonably sufficient to help us locate the content. Please note that while we will endeavor to remove the requested content, complete or comprehensive removal may not be possible if the content has been republished or reposted by another user or third party.
You also have the right not to be treated in a discriminatory manner for exercising your privacy rights under the California Consumer Privacy Act (CCPA).