Privacy Policy

Effective October 24th, 2019

This “Privacy Policy” describes the privacy practices of Supermediafuture Corp. d/b/a Octi and our subsidiaries and affiliates (collectively, “Octi”, “we”, “us”, or “our”) in connection with the www.supermediafuture.com website, the Octi mobile app, and any other website or mobile app that we own or control and which posts or links to this Privacy Policy (collectively, the “Service”), and the rights and choices available to individuals with respect to their information.

We provide important information for individuals residing in the European Union below .


Table of Contents

·        Personal Information We Collect

·        How We Use Your Personal Information

·        How We Share your Personal Information

·        Your Choices

·        Other Websites, Mobile Applications and Services

·        Security Practices

·        International Data Transfers

·        Children

·        Changes to This Privacy Policy

·        How to Contact Us

·        Your California Privacy Rights

·       Biometric Data Retention for Illinois Resident Users

·       Notice to European Users

Personal Information We Collect

Information you provide to us. Personal information you provide to us through the Service or otherwise includes:

·       Contact information, such as your first and last name, email and mailing addresses, and phone number.

·       Content you choose to upload to or post on the Service, such as text (including comments and messages), images, audio, and video, along with the metadata associated with the files you upload.

  • Profile information, such as your username and password that you may set to establish an online account with us, your photograph, interests, and preferences.

·        Biometric information, such as facial scans of photographs and other images you upload to the Service, and data derived from this information, as well as information about your physical movements when you use the camera in connection with the Service.

·        Demographic Information, such as your city, state, country of residence, postal code, gender and birthdate.

  • Resume information, such as details about your educational history and work experience you provide when you submit an application for employment with Octi.
  • Precise geolocation information, such as when you authorize our mobile app to access your location.
  • Feedback or correspondence, such as information you provide when you contact us with questions, feedback, or otherwise correspond with us online.
  • Usage information, such as information about how you use the Service and interact with us and/or others through the Service which we may observe and/or record in real time.
  • Marketing information, such as your preferences for receiving marketing communications, and details about how you engage with our communications.

Information we obtain from social media platforms. If you choose to login to the Service via a third-party platform or social media network, or otherwise connect your account on the third-party platform or network to your account through the Service, we may collect information from that platform or network. For example, this information may include your Facebook username, user ID, profile picture, cover photo, and networks to which you belong (e.g., school, workplace). You may also have the opportunity to provide us with additional information via the third-party platform or network, such as a list of your friends or connections and your email address, and which of your friends also use the Octi app. Our collection and processing of the information we obtain from social media platforms is governed by the requirements these social media platforms impose on us in their relevant terms and conditions. You can read more about your privacy choices in the “Third party platforms or social media networks” portion of the “Your Choices” section.

Information about others. If you decide to invite a third party to use the Service, we will collect your and the third party’s names and e-mail addresses or mobile telephone numbers in order to send an e-mail or SMS message invitation to the third party. We rely upon you to obtain whatever consents from the third party that may be required by law to allow us to access and upload the third party’s names and e-mail addresses as required above. You or the third party may contact us at info@supermediafuture.com to request the removal of this information from our database.

Cookies and Other Information Collected by Automated Means

We, our service providers, and certain third parties (e.g., online advertising networks and their clients) may automatically log information about you, your computer or mobile device, and activity occurring on or through the Service. The information that may be collected automatically includes your computer or mobile device operating system type and version number, manufacturer and model, device identifier (such as the Google Advertising ID or Apple ID for Advertising), browser type, screen resolution, IP address, the website you visited before browsing to our website, general location information such as city, state or geographic area; and information about your use of and actions on the Service, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and length of access. Our service providers and other third parties may collect this type of information over time and across third-party websites and mobile apps. On our webpages, this information is collected using cookies, browser web storage (also known as locally stored objects, or “LSOs”), web beacons, and similar technologies, and our emails may also contain web beacons. In our mobile app, we may collect this information directly or through our use of third-party software development kits (“SDKs”). SDKs may enable third parties to collect information directly from our App.

How We Use Your Personal Information

We use your personal information for the following purposes and as otherwise described in this Privacy Policy or at the time of collection:

Biometric and Non-Biometric Personal Information:

To provide the facial-recognition features of the Octi mobile app. We use your personal information to provide the facial recognition features of the Octi mobile app, including to establish your user profile and account, to identify and locate the profiles of other Octi mobile app account holders, and to allow you to create and edit photos, videos and other content through the app.

To comply with law. We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

For compliance, fraud prevention, and safety. We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the Service; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

Additional Uses of Non-Biometric Personal Information:

To provide, operate and improve the Service. We use your personal information to provide, operate and improve the Service, including to establish and maintain your account on the Service, facilitate your to login to the Service via third-party identity and access management providers, such as Snapchat and Facebook, enable security features of the Service, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in, facilitate social features of the Service, such as by identifying and suggesting connections with other users of the Service and providing chat or messaging functionality, communicate with you about the Service, including by sending you push notifications, announcements, updates, security alerts, and support and administrative messages, understand your needs and interests, and personalize your experience with the Service and our communications, provide support and maintenance for the Service, provide information about our products and services, and respond to your requests, questions and feedback.

For research and development. We analyze use of the Service to analyze and improve the Service and to develop new products and services, including by studying user demographics and use of the Service.

To send you marketing and promotional communications. We may send you Octi-related marketing communications as permitted by law. You will have the ability to opt-out of our marketing and promotional communications as described in the Opt out of marketing section below.

To display advertisements. We work with advertising partners to display advertisements on the Service or elsewhere online. These advertisements are delivered by our advertising partners and may be targeted based on your use of the Service or your activity elsewhere online. To learn more about your choices in connection with advertisements, please see the section below titled “Targeted online advertising.”

To manage our recruiting and process employment applications. We use personal information, such as information submitted to us in a job application, to facilitate our recruitment activities and process employment applications, such as by evaluating a job candidate for an employment activity, and monitoring recruitment statistics.

With your consent. In some cases we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.

To create anonymous, aggregated or de-identified data. We may create anonymous, aggregated or de-identified data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous, aggregated or de-identified data by removing information that makes the data personally identifiable to you. We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

How We Share Your Personal Information

We do not share your personal information with third parties without your consent, except in the following circumstances or as described in this Privacy Policy:

Biometric and Non-Biometric Personal Information:

Service providers. We may share your personal information with service providers that perform services on our behalf or help us operate the app (such as customer support, hosting, analytics, email delivery, marketing, and database management services). We do not authorize these third parties to use your personal information other than to provide the services.

To comply with law. We may share your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities

For compliance, fraud prevention and safety. We may share your personal information for the compliance, fraud prevention and safety purposes described above .

Business transfers.  We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.

Additional Sharing of Non-Biometric Personal Information:

Partners. We may sometimes share your personal information with partners or enable partners to collect information directly via our Service. For example, if you choose to integrate your Snapchat account with your Octi account, Snapchat may collect information about your use of the Service. You may view Snapchat’s privacy policy here .

Third-party platforms and social media networks. If you have enabled features or functionality that connect the Service to a third-party platform or social media network (such as by logging in to the Service using your account with the third-party, providing your API key or similar access token for the Service to a third-party, or otherwise linking your account with the Service to a third-party’s services), we may disclose the personal information that you authorized us to share. We do not control the third party’s use of your personal information.

Other users of the Service and the public. We may provide functionality that enables you to disclose personal information to other users of the Service or the public. For instance, you may be able to maintain a user profile with information about yourself that you can make available to other users or the public, and you may be able to communicate with other users of the Service via a chat or other messaging functionality. You may also be able to upload content to the Service (such as comments, reviews, photos, and videos) which will be displayed alongside your username and a link to your user profile, and viewable by other users of the Service and/or the public. We do not control how other users or third parties use any personal information that you make available to other users or the public.

Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.

Your Choices

In this section, we describe the rights and choices available to all users. Users who are located within the European Union can find additional information about their rights below.

Account information. You may review and update certain personal information in your account profile by logging into your account. You may also contact us at support@supermediafuture.com to request that we close your account, in which case we will close your account as soon as practicable, but we may retain your information as we deem necessary for the purposes described in this Privacy Policy.

Marketing communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email. You may continue to receive service-related and other non-marketing emails.

Cookies and browser web storage. We may allow service providers and other third parties to use cookies and similar technologies to track your browsing activity over time and across the Service and third party websites. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Sites may not work properly. Similarly, your browser settings may allow you to clear your browser web storage.

Privacy settings and location data. We make available certain privacy settings on the Service, including options to grant and revoke permission to access to your mobile device’s contacts, camera, camera roll, and/or microphone. You can adjust these permissions in the mobile app “Account Settings,” or through the device-level settings on your mobile device. We may also send push notifications to your mobile device. If you no longer wish to receive push notifications, you can adjust your permissions in “Account Settings” and/or turn push notifications off at the device level. Users of our mobile app also have the choice whether to allow us to access your precise location data. You may revoke our ability to access your location data through the mobile app “Account Settings” and/or the device-level settings on your mobile device.

Do Not Track.Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Choosing not to share your personal information. Where we are required by law to collect your personal information, or where we need your personal information in order to provide the Service to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with our services. We will tell you what information you must provide to receive the Service by designating it as required at the time of collection or through other appropriate means.

Third-party platforms or social media networks. If you choose to connect to the Service via a third-party platform or social media network, you may have the ability to limit the information that we may obtain from the third-party at the time you login to the Service using the third-party’s authentication service or otherwise connect your account. Subsequently, you may be able to control your settings through the third-party’s platform or service. For example, you may access and change your settings through the Facebook settings page for Apps and Websites. If you withdraw our ability to access certain information from a third-party platform or social media network, that choice will not apply to information that we have already received from that third-party.

Other Websites, Mobile Applications and Services

The Service may contain links to other websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on websites or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications or online services, and we are not responsible for their actions. Other websites, mobile applications and online services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Security Practices

We employ a number of organizational, technical and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

International Data Transfers

We are headquartered in the United States and have service providers in other countries, and your personal information may be transferred to the United States or other locations outside of your state, province, or country where privacy laws may not be as protective as those in your state, province, or country.

Children

The app is not directed at children under the age of 13, and our Terms of Use do not allow children under 13 years of age to use the app. If we learn that we have collected personal information of a child under the age of 13, we will delete it. We encourage parents with concerns to contact us.

Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service. We may, and if required by law will, also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via e-mail (if you have an account where we have your contact information) or another manner through the Service.

Any modifications to this Privacy Policy will be effective upon our posting the new terms and/or upon implementation of the new changes on the Service (or as otherwise indicated at the time of posting). In all cases, your continued use of the Service after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.

How to Contact Us

Please direct any questions or comments about this Policy or privacy practices to octiaccountinquiries@octi.tv. You may also write to us via postal mail at:

SuperMediaFuture Inc DBA "Octi" 

Attn: Privacy

8560 W Sunset Blvd 

10th Floor 

Los Angeles, CA 90069 

Biometric Data Retention for Illinois Resident Users

If you are an Illinois resident, in accordance with Illinois state law Octi will retain your biometric data only until the occurrence of the first of the following, after which we will permanently destroy the biometric data:

·        The initial purpose for collecting or obtaining such biometric data – as set out in this Privacy Policy – has been satisfied; or

·        Three years following your last interaction with Octi, where your last interaction is the later of the date on which you closed your Octi mobile app account, or the last date you communicated with us about the Octi mobile app.

Notice to European Users

The information provided in this “Notice to European Users” section applies only to individuals residing in the Europe Union.

Personal information. References to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation.

Controller. Supermediafuture Corp. is the controller of your personal information covered by this Privacy Policy for purposes of European data protection legislation.

Legal bases for processing. We use your personal information only as permitted by law. Our legal bases for processing the personal information described in this Privacy Policy are described in the table below.

Processing purpose (click link for details)

Details regarding each processing purpose listed below are provided in the section above titled “How we use your personal information”.

Legal basis

·   To provide the facial recognition features of the Octi mobile app

 

Processing is based on your consent. Where we rely on your consent you have the right to withdraw it any time in the manner indicated when you consent or in the Service.

·   To provide, operate and improve the Service

Processing is necessary to perform the contract governing our provision of the Service or to take steps that you request prior to signing up for the Service. If we have not entered into a contract with you, we process your personal information based on our legitimate interest in providing the Service you access and request.

·   For research and development

·   To send you marketing communications

·   To display advertisements

·   For compliance, fraud prevention and safety

·   To create anonymous, aggregated or de-identified data

These activities constitute our legitimate interests. We do not use your personal information for these activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

To comply with law

Processing is necessary to comply with our legal obligations.

With your consent

Processing is based on your consent. Where we rely on your consent you have the right to withdraw it any time in the manner indicated when you consent or in the Service.

 

Sensitive personal information. If you provide us with any sensitive personal information to us when you use the Service, you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through our Service.

Retention

We retain personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

When we no longer require the personal information we have collected about you, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.

Your rights

European data protection laws give you certain rights regarding your personal information. If you are located within the European Union, you may ask us to take the following actions in relation to your personal information that we hold:

 

  • Access. Provide you with information about our processing of your personal information and give you access to your personal information.
  • Correct. Update or correct inaccuracies in your personal information.
  • Delete. Delete your personal information.
  • Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
  • Restrict. Restrict the processing of your personal information.
  • Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.

You may submit these requests by email to octiaccountinquiries@octi.tv or to our postal address provided above. If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here .





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