EFFECTIVE DATE: DECEMBER 16, 2017
We are letting you know that AVM, Inc. (including its video chat brands such as Paltalk®, Camfrog®, Tinychat, Firetalk, Ribbit Live, and Pack Live) has merged with Snap Interactive, Inc.
We’ve have added some additional ways to reach you with special offers from us and our marketing partners, which may be customized based on your interests gathered from the sites you have visited and from the devices you use to access those sites.
Personal Information Collected
When you create an account, you voluntarily share with us certain personal information such as your email address and mobile number. If you create a profile, information you provide to us and other users may include first name (as the user name displayed to other users), gender, current city, interests, photos, age and any other information, video or photos you choose to provide. With your prior permission, your social media profile information will be displayed on our Services should you connect through a social media network such as Facebook. More Info
Tracking Technologies (Cookies, etc.)
We use tracking technologies such as cookies and similar technologies to measure your usage of the services to provide you with information that will be of most interest. We may also collect your IP address and the unique device identifier from your mobile device. We may also collect your precise location if you permit us to. More info
Use and Sharing of Information
Your Information Access Options
You can change your profile, account information and privacy settings by logging into the services or by contacting customer service. More Info
Your Information Opt-out Choices
You can control how and when you want to receive promotional notifications from us. More info. You may also have the option to opt-out of receiving our analytics providers’ cookies or third party cookies used for interest-based advertising. More Info
Effective Date: December 16, 2017
Video Chat Services
1. INFORMATION WE COLLECT
Account and Profile Information You Provide to Us. We will collect personal information from you when you sign up for any of our Services, interact with our Services, create or update your account or profile, interact with other users, or communicate directly with us. For example, account information may include name, date of birth, email address, physical address, and mobile number. Profile information may include your nickname, gender, current city, interests, videos, photos, ethnicity, age and any other information you choose to provide in your profile. Profile information is public and will be made available to other users. We will not disclose your account information to other users.
When you create an account, you may be asked to provide us with certain additional information such as username and password. In connection with signing up for a subscription service or purchasing Virtual Gifts and Stickers, you may also provide payment information such as credit or debit card information, and billing name and address.
Surveys and Promotions. From time-to-time we may request information from you via surveys, contests or sweepstakes. Participation is completely voluntary. Information collected in any sweepstakes or contest may be used as set forth in this policy and as described in the official rules, such as to notify the winners, award prizes and file winners’ information, as required by law. Survey information will be used for the purposes of the survey.
Information You Post. The Services are designed to enable you to communicate with other users through interactive forums, and any information or content you post when participating in the Services becomes public information, and is subject to redistribution by Snap and other third parties. There is no expectation of privacy when posting a profile or otherwise participating in the Services and we have no control over how users may use the information you make public. Therefore, you should exercise caution and discretion when deciding to disclose your personal information. It is possible that your profile information may become available through internet search crawlers; we therefore encourage you not to disclose any information that you may not want to make public.
Mobile Information. We may collect additional information from you if you access the Services through a mobile device, such as your unique device identifier, device’s operating system, mobile carrier, regional location or, with your permission, precise geo-location. Please note that the degree to which your location can be identified depends on the device you are using (e.g. laptop, smartphone, tablet) (“Device”) and how you are connected to the internet (e.g. via cable broadband connection, Wi-Fi, etc.).
Information About Others/Inviting Friends. You may have the option to choose to submit personal information about other people to invite them to join the Services. Inviting friends is optional and you should have prior permission to contact other people through the Services. Please be aware that if you use any send-to-a-friend functionality on the Services, your email address may be included in the communication sent to your friend.
We and our business partners may use a variety of tracking technologies that automatically (or passively) collect certain information from your Devices whenever you visit or interact with the Services or third party websites (“Tracking Technologies”). For a current list of tracking technologies used click here. Tracking Technologies are used for a variety of purposes, including:
- Operationally Necessary.
We may use Tracking Technologies for system administration, to prevent fraudulent activity, to improve security or to allow you to make use of our Services.
- Performance Related.
We may use Tracking Technologies to assess the performance of our Services, including as part of our analytics practices to improve content offered through the Services. For example, we may use these tools to measure and collect session information, including page response times, download errors, time spent on certain pages and page interaction information. We may also use Tracking Technologies to tell us whether you have visited the Services before or if you are a new visitor and to help us identify the features in which you may have the greatest interest. We may also collect information about the website you visited before you came to our Services and the website you visited after you leave our Services, if this information is supplied by your browser. We use Google to serve first party cookies (such as Google Analytics cookie) to report how our ad impressions, and interactions with these ad impressions and ad services, are related to visits to the Services. To learn about Google Analytics opt-outs for the web or mobile, click here. To learn more about our other analytics providers’ data collection practices, click here.
- Targeting Related.
We may use Tracking Technologies to deliver content, including ads, relevant to your interests on the Services and third party sites based on how you interact with our advertisements or content, and to track the content you access.
- Tracking Your Activities Across Devices and Apps.
To better understand your purchasing preferences, we may also use third party vendors that provide tracking tools that recognize and collect usage and interest information across the sites you’ve visited from your various Devices. When you visit the Services on a specific Device, a unique ID is created for that Device which may be based on your hashed (de-identified) email address. This allows us and our third party vendors to deliver relevant product recommendations, personalized content and advertising to you based on your interests gathered across multiple sites. This data may be combined with the same information from another browser or Device if you use multiple browsers or Devices. Third party tracking tools might also obtain information about other applications that you have downloaded to your mobile Device, the websites you visit and other information about you or your Device in order to analyze and serve anonymous targeted advertising on the Services and elsewhere.
Completing the opt-out process on one Device will not cause you to be opted out of targeted advertising collection and use on other Devices attributed to you or your family. Your choice of “do not track” must be exercised on each Device separately.
Mobile app opt-outs do not affect cookie-based data, while browser-based opt-outs do not affect mobile app and cross-app data. Also, mobile app opt-outs are limited to a specific Device, while browser-based opt-outs are limited to a specific browser. In addition, choice mechanisms may be presented to you, as you move about the web, but they will be limited to the companies participating in any particular program.
The use of Tracking Technologies by third parties is subject to their own privacy policies and is not covered by this Policy. Please visit our Analytics Providers page at the back of this policy for a list of service providers we use and your opt-out options.
We or our advertising partners may use Tracking Technologies to collect Information about your visits over time and across the Services and other third-party web sites, and combine that information with other information received from other sources, in order to serve more targeted advertising to you. For example, we use Google interest based cookies to serve personalized ads to you. Our ad partners automatically receive your IP address or Device identifier when this happens. Their tools may also limit the number of times you see the same ad and help measure the effectiveness of our advertising campaigns. These third parties may also use information gathered from your use of the Services to serve targeted, interest based advertisements from other advertisers to you on third-party websites and applications.
The Digital Advertising Alliance (“DAA”) has also made available for consumers tools on which you can register your choices not to be tracked by participating advertising networks or companies in the collection and use of your online activities. These are (1) The DAA Consumer Choice Page for Mobile Web (at http://www.aboutads.info/choices/ ) and (2) DAA AppChoices (at http://www.aboutads.info/appchoices), which is a mobile app that allows you to opt out of the collection and use of cross-app data, other than for permitted uses, by listed third-party AppChoices participants. You may opt out of mobile-app targeted advertising ads from any or all of the listed participating advertising networks. You can download the free mobile app from an app store available on your mobile platform. When you opt out with a particular participating advertising network, the mobile app adds your device identifier to that participant’s opt-out list. The participant advertising network is then notified to block the device identifiers on the opt-out list.
You can also prevent your receipt of interest-based ads on websites by deleting and declining cookies in your browser(s). Note that your opt-out choice is applied only to the browser from which you make the choice.
Some newer mobile device operating systems allow you to limit the use of information to deliver interest-based advertising in mobile applications, or your mobile web browser may provide a “Do Not Track” browser setting which will notify those ad servers and networks who recognize the signals to refrain from sending you interest based ads to your mobile device. You can check the settings on your device for such options in your devices’ operating system. Alternatively, you may wish to download the TrustE mobile application and/or the Digital Alliance “App Choices” mobile application and follow the instructions provided.
For those users in Europe, you may be able to opt-out via the IAB Europe’s industry opt-out at www.youronlinechoices.com.eu.
If you opt-out of receiving targeted ads on our Services, you may continue to receive advertising and promotional messages after you opt-out, but they will not be customized or personalized to you based on your use of our Services.
WE DISCLAIM THE ACCURACY AND RELIABILITY OF THIRD-PARTY NOTICES AND CHOICE MECHANISMS. WE DISCLAIM RESPONSIBILITY FOR NONCOMPLIANCE OF OTHERS.
Browser Do Not Track Signals. Some third party browsers provide “do not track” machine readable signals for websites and online services which are automatically applied by default and therefore do not necessarily reflect our users’ choice as to whether they wish to receive advertisements tailored to their interests. As such, we do not currently respond to these signals.
- Location and Geo-location Functionality.
Information gathered from your use of the Services may be combined with information from third-party sources to identify your location by state and region (“Regional Location”). If you enable location services for our Services, we may passively collect regional location data periodically as you use or leave open our Services. Certain of our mobile applications have search functionality that gathers aggregate location data about visitors and when visitors opt-in, allows us to collect information about their precise geographic location (“Geo-location”). We may use GPS, Wi-Fi, Bluetooth or cell tower proximity to determine Geo-location. If you agree to have your Geo-location collected, we may use and retain that precise location data to provide you with information about our Services or carry out marketing and other activities contemplated by our mobile applications and by this Policy. When you have Geo-location software running on your Device, we may only collect that information as controlled by your privacy settings on your Device. For most mobile Devices, you can withdraw your permission for us to acquire this information on your location through the Device settings. If you have questions about how to disable your mobile Device's location services, we recommend you contact your mobile Device service provider or the Device manufacturer.
Other Snap Services. With prior consent and an opportunity to opt out, Snap may register you with and display your profile on other online services owned by Snap. For example, certain members of Paltalk may have the opportunity to automatically register for Camfrog.
Service Providers. We may disclose information to our third party service providers in order to monitor the activity of the Services, conduct surveys, administer contests or sweepstakes, send marketing communications, and provide other Services to you, such as customer service.
Analyze and Aggregate Information. We use aggregate information about our users and non-personal information to analyze the Services and user behavior and prepare aggregated reports that we share with third parties.
Messages. We may also use your email address or mobile phone number to send you updates and communications about our products and Services or other messages, such as newsletters, text messages (if you agree to opt-in), information about other users, changes to features of the Services, special offers, or share your information with our marketing partners so they can send promotional offers to you.
Push Notifications. Our Services may include a function that allows us to use push notifications to send you updates, communications, and other messages about the Service. We do not send promotional messages about other products or services through these push notifications.
Information from Other Sources. The information we collect may be combined with information from outside records (e.g., demographic information, navigation information, additional contact information), or from other sources about your visits over time and across other third party websites (e.g. to serve more targeted advertising to you on the Services), that we have acquired in accordance with the law. We may also combine that information with other information collected from the Devices you use to access our Services, such as your mobile device model, and system settings, as well as the language your system uses and the country and time zone of your Device and other demographics.
Sale or Transfer of Business or Assets. If Snap or an affiliated company is sold or disposed of as a going concern, whether by merger, sale of assets or otherwise, or in the event of an insolvency, bankruptcy or receivership, personal and non personally identifiable information of our users may be one of the assets sold or merged in connection with that transaction. Information about our users may also need to be disclosed in connection with a commercial transaction where we or any one of our businesses are seeking financing, investment, support or funding.
Transactional Communications. We may send you notices from time to time relating to your account or your subscription. These may include order confirmations, invoices or customer service notifications or Service updates or notifications. We may also send you service-related announcements when it is necessary to do so; for instance, if our Services are temporarily suspended for maintenance, or the delivery of a product is delayed or there is some service issue with something you may have ordered.
Process Payments. Information may be disclosed to process credit card transactions, which are handled by established third party banking, processing agents and distribution institutions. They receive the information needed to verify and authorize your credit card or other payment information and to process your order. In addition, we may disclose information to third parties to verify the authenticity of any financial transaction involving our company or to update your billing information.
To Change Your Account or Profile Information. Members can review and edit their profile information by accessing their accounts within the Service. To change your profile on our Service, go to Edit My Profile (or similar tab) on the applicable Service. From your account, you may edit your “about me” description or add additional photos to supplement or replace the photos originally imported.
If you registered on the Service using Facebook, you may deactivate your account by going to https://www.facebook.com/bookmarks/apps and removing the app for the particular Service. Upon deactivation your profile and account information will be publicly removed from the Service. Facebook users can reactivate their accounts by clicking on the Facebook connect on the Service website or through Facebook.
If your information is not correct and you cannot change it by accessing your account, contact us as described in the “Contacting Us” section below. You should promptly update your personal information if it changes or becomes inaccurate.
Transactional/Service-related Messages. You may not opt-out of transactional or service-related messages, including emails.
Opting-out of Analytics Cookies. You may be able to opt-out of the collection and use of data by our third party analytics or service providers; See Section 2. and the current list of our analytics providers attached to this policy for details. 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 features offered on our Services.
Opting-out of Interest based Advertising. See Section 2C. Opt-out of Interest-based Advertising.
Opting-out of Promotional Messages. You may choose not to receive our promotional communications by logging into your account and clicking the “Preferences” tabs. You may also click the unsubscribe link in the footer of any email or newsletter, or click “STOP” on a mobile text. You may also contact us as described in the “Contacting Us” section below
Opting-out of Push Notifications. You may not opt-out of receiving push notifications.
Opt-out Timing and Third Parties. We will endeavor to comply with your requests as soon as reasonably possible but please note that changes requested of us may not be effective immediately. Unless required by law, we are not responsible for informing third parties with whom we have shared your information of any changes, or for removing or causing to be removed information from the databases or records of such entities.
Deleting Personal Information. You may request that all user submitted personal information (other than your email address) is deleted from our database by emailing us at the email address noted in Section 6 Contacting Us.
Security. We implement security measures to protect against the loss, misuse and alteration of information under our control, including “Secure Socket Layers” or SSL to protect your data. SSL is encryption technology that helps safeguard your personally identifiable information against misuse by unauthorized individuals. However, despite our efforts, no system can completely guaranty that there will never be unauthorized access to your personal information, and your use of the Services indicates that you are willing to assume this risk. The Federal Trade Commission’s site, www.ftc.gov, also offers useful information about how to protect personally identifiable information provided online or through mobile applications.
Your California Privacy Rights. California Civil Code Section 1798.83, known as the "Shine the Light" law, permits our customers who are California residents to request and obtain from us a list of what personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once a year and are free of charge. To make such a request, please contact us as described in the “Contacting Us” section below. For all requests, you must put the statement "Your California Privacy Rights" in the body of your request, as well as your name, street address, city, state, and zip code. In the body of your request, please provide enough information for us to determine if this applies to you. You need to attest to the fact that you are a California resident and provide a current California address for our response. Please note that we will not accept requests via the telephone, mail, or by facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.
Storage and Retention. If your account or subscription is terminated or suspended, we may maintain some information to prevent re-registration. If any of your content, including your personal information, was previously accessed by others using the Service, we are unable to delete the information from their systems. When you deactivate your account, or ask that we delete your content on a Service, we will retain logs and information about you along with an archival copy of your information, which is not accessible by you or third parties on the Service but which might be used by us to respond to your request to reactivate your account, for recordkeeping and internal purposes, including enforcing our Terms and demographic, reporting and research purposes.
Jurisdiction and Cross-Border Issues. We do not represent or warrant that our Services are appropriate or available for use in any particular jurisdiction. Those who choose to access the Services do so on their own initiative and at their own risk, and are responsible for complying with all local laws, rules and regulations. We may limit access to our Services to any person, geographic area or jurisdiction we choose, at any time and in our sole discretion. By using our Services and submitting personal information, you consent to the transfer of personal information to other countries, such as the United States, which may provide a level of data security different from your country of residence. You are also consenting to the application of United States law in all matters concerning the Services.
Children’s Privacy. The Services are directed to a general audience. We restrict the use of our Services to individuals age 18 and above. We do not knowingly collect personal information from individuals under 18 years of age and if we obtain actual knowledge that a user is under 18 years of age, we will take steps to remove that user’s personal information from our systems. If you become aware that anyone under 18 has provided us with personal information, please contact us in accordance with the “Contacting Us” section below.
Camfrog and Ribbit Live: firstname.lastname@example.org
or write to us at:
Snap Interactive, Inc.
122 East 42nd Street, 26th Floor
New York, NY 10168
When contacting us, please include your full name, address, phone number, and email address, and indicate the specific Service you’re using and the nature of your request.
Copyright © 2017 Snap Interactive, Inc. All rights reserved.
As of December 16, 2017
This is a list of third parties we have hired to provide us information, reports and analysis about the usage and browsing patterns of users of the Services.
Google Analytics Opt-out https://tools.google.com/dlpage/gaoptout/
Flurry Analytics https://dev.flurry.com/secure/optOut.do
HTML5. We use HTML5 in some of our applications, including in our mobile website for the iPhone or iPad. HTML5 has browser web storage that does not rely on traditional browser cookies. Like Flash cookies, HTML5 cookies are not stored in a browser “cookies” file and, like Flash cookies, can be used to track users across websites. To our knowledge there is currently no known way for a user of a mobile Device to remove HTML5 tracking and storage.
Web Beacons/GIFS. Small graphic images or other web programming code called web beacons (also known as “1×1 GIFs” or “clear GIFs”) may be included in our web pages and messages.
Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a web page or email can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to our Services, to monitor how users navigate the Services, to count how many emails that were sent were actually opened or to count how many particular articles or links were actually viewed.
Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Services such as the links you click on. The code is temporarily downloaded onto your Device used to access Services from our web server or a third party service provider, is active only while you are connected to the Services, and is deactivated or deleted thereafter.
e-tags/cache browsers/web logs. Like most standard website servers, we log IP addresses (a unique number assigned to every computer on the Internet) and Device identification in order to improve security, analyze trends and administer the Services. We may track your movement within the Services, the pages from which you were referred, access times and browser types. This information may include the browser you are using, the Internet address from which you linked to our Services, the operating system of your computer, the unique IP address of the computer or Device identification from the mobile device that you used to access our Services and usage and browsing habits. We use this information in the aggregate to gauge the effectiveness, usage, and popularity of our Services, track information for statistical purposes, help diagnose and troubleshoot server malfunctions, analyze trends, track user movement in the aggregate, and gather broad demographic information. We may also use individual information we collect through web logs to send you targeted offers and other communications.
Device Fingerprinting. We may use Device fingerprinting in some of our Services, which allows us to collect information about a remote computing Device for the purpose of identification. It can be used to prevent fraud or collect information about you.
IDFA. The IDFA is a Device identifier that is used by many software kit developers for various reasons including to measure user behavior in mobile apps. Additionally, the IDFA is the shared identifier between an ad network and an ad server to report which networks delivered a particular download.