1. INFORMATION WE COLLECT

The categories of information we collect from Website Users, Employees, and Users may include:

Identification Information you provide to us directly. We may collect personal information, such as your name, phone number, location, and email address when you use or register for our Service.

Creating Accounts. When you create an account through our StayTouch service, you need to provide us with your name, mobile number, email, and a password.

• Third Party Account Information: If you choose to connect third party accounts to the Services (e.g. Google) to sign-up for an account with StayTouch, we may collect information associated with your third party account such as the name, email address, and profile information you provided to the relevant third party. If you sign-up for the StayTouch Service using a third-party platform, we will collect information about your authentication directly from that platform. Please note that your use of the third-party platform’s sign-in tool will be subject to the applicable third-party’s terms.

If you subscribe to our StayTouch Premium Service, you will need to provide us with your subscription preferences and payment information such as your credit card number, billing address, and other authentication details. Payments will be processed by the mobile platform provider (e.g., Apple, Google), and we will receive information about the transactions from the provider. Please note, however, that we store only a tokenized version of such information and do not maintain payment card information on our servers. Your account information is not visible to your contacts.

Creating Profiles. When you create a profile, you have full control over the information included in the profile such as your photo, education, work experience, skills, or contact information (e.g. email, phone number, or mailing address) or links to social media accounts. If you upload a photo, we may request access to the camera roll and camera on your mobile device. You may withdraw this permission to access your device’s camera roll and camera at any time through the ‘Settings’ in your mobile device’s app. Your profile information is different from your StayTouch account information, and is only visible to people who have added you as a contact through StayTouch (unless you declined their request to share your contact info) or who you shared your profile information through email or your phone’s native SMS text messaging app.

If you subscribe to the StayTouch Premium Service, you are able to create multiple profiles with the same or different information. You are the master of your contact information and can choose what information to include in each profile.

Please note that we do not require you to include sensitive information in your profile such as date of birth, race, ethnicity, biometrics, medical information, financial information or social security number. Please do not include sensitive information in your profile. If you choose to include such information, it will be visible to those with whom you have shared your profile as described above.

Communications With Us. We receive your personal information such as name, email address, or phone number when you sign up for our mailing list, fill out a survey, or otherwise communicate with us. We may also collect any communications between you and us, and any other information you provide to us.

Marketing Information. We may collect your preferences for receiving our marketing communications, and details about your engagement with them.

Voice Notes. With your permission, we collect voice notes and request access to the microphone on your mobile device in order to facilitate collecting the voice notes. You may withdraw this permission to access your device’s microphone at any time through the “Settings” in your mobile device’s app. Voice notes are intended for your own individual use so you can record information about your contacts. Voice notes should not be used to record others. We are not responsible for the recording of any third parties through the use of voice notes. Therefore, if you will use voice notes, you agree to comply with all applicable laws, whether federal, state, local or international, relating to the privacy of communications, including advising all participants in a recorded conversation that the conversation is being recorded and obtaining their consent, as required. We may also send voice notes to our sub-processor for transcription.

Address Book and Calendar Information. With your permission, we may request access to your contacts or calendar information available on your mobile device or through your email accounts and import or sync contact and calendar information with StayTouch. To help you connect with people you know, we may also receive your personal information when others authorize importing or syncing their contacts or calendar with StayTouch. You can turn off syncing at any time or choose to manually add contacts or calendar information.

You choose who to invite or send your Virtual Contact File (“vCard”). If you choose to send invitations via text message, the standard rates may apply. When inviting your contacts to connect via StayTouch, we use third-party service providers to facilitate sending your emails or texts. Please note that you are the sender of these messages. Only send invitations to contacts you know personally that are interested in using the Service.

Communications with Others. When you use the chat to communicate with other users, we transmit the messages, photos and videos that you upload to your intended recipients. Please note that we are not responsible for any recipient’s use of the information you send. We do not have access to the contents of the chat communications.

Social Media Information. We have pages on social media sites like Facebook, Instagram, and YouTube (“Social Media Pages”). When you interact with our Social Media Pages, we will collect personal information that you elect to provide to us, such as your contact details. In addition, the companies that host our Social Media Pages may provide us with aggregate information and analytics regarding the use of our Social Media Pages.

Information from Other Sources. We may receive information about you from third parties and combine this information with other information we collect from or about you. For example, we may receive your information when someone uploads to StayTouch your contact information that is stored on their phone or address book. We may also receive your information from third parties such as distribution partners, data services, and marketing firms.

For more information about your communication preferences, see “Control Over Your Information” below.

We Process Employees’ Professional Information on Behalf of Our Customers. In order to provide easy connections between contacts, we collect photos, chat communications, voice notes, address book information, calendar information, and other data from Employees. We process that data, including any personal information contained within it, pursuant to our agreements with our business customers. We have no direct relationship with the Employees whose personal information we process in the course of providing our contact information tool to our customers. If you are such an individual and have questions about the processing of your information, please contact the business customer that you interact with directly.

Where an Employee is also a User (i.e., one individual has both professional and personal accounts), the relevant customer may permit that Employee to keep certain information collected through the Employee’s professional account after the Employee’s employment relationship with the customer ends.

Usage Information. We, and our third-party partners, automatically collect certain types of usage information when you visit our Sites, use or Service, read our emails, or otherwise engage with us. We typically collect this information through a variety of tracking technologies, including cookies, web beacons, embedded scripts, location-identifying technologies, file information, and similar technology (collectively, “tracking technologies”).

We, and our third-party partners, use tracking technologies to automatically collect usage and device information, such as:

Information about your device and its software, such as your IP address, browser type, Internet service provider, device type/model/manufacturer, operating system, date and time stamp, and a unique ID that allows us to uniquely identify your browser, mobile device, computer, or your account (including, for example, a persistent device identifier or an Ad ID), and other such information. We may also work with third-party partners to employ technologies, including the application of statistical modeling tools, which permit us to recognize and contact you across multiple devices.

Information about the way you access and use our Service, for example, the site from which you came and the site to which you are going when you leave our Service, the pages you visit, the links you click, whether you open emails or click the links contained in emails, whether you access the Service from multiple devices, whether you accepted a contact, how long you spent on a page or screen, information about your activity on a page or screen, access times, and duration of access, and whether or you have opened our marketing emails or clicked links within them, and other actions you take on the Service.

Information about your location, including GPS coordinates (e.g., latitude and/or longitude) or similar information regarding the location of your mobile device, or we may be able to approximate or infer a device’s location by analyzing other information, like an IP address. We also use the Google Maps API to gather information about your location. Google uses various technologies to determine your location, including IP address, GPS, and other sensors that may, for example, provide Google with information on nearby devices, Wi-Fi access points, and cell towers (see Google Maps privacy policy to learn more).

Analytics. We may collect analytics data or use third-party analytics tools such as Google Analytics to help us measure traffic and usage trends for the Service and to understand more about the demographics of our users. You can learn more about Google’s practices at and view its currently available opt-out options at https://tools.google.com/dlpage/gaoptout. We may also work with third-party partners to employ technologies, including the application of statistical modeling tools, which permit us to recognize and contact you across multiple devices.

Cookies Opt Out. Cookies are text files that websites store on a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising. If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Please note that doing so may negatively impact your experience using the Service, as some features and services on our Service may not work properly. Depending on your mobile device and operating system, you may not be able to delete or block all cookies. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.

Deleting cookies does not delete Local Storage Objects (LSOs) such as Flash objects and HTML5. To manage Flash cookie settings and preferences, you must use the settings manager on Adobe’s website. If you choose to delete Flash objects from our Service, then you may not be able to access and use all or part of the Service or benefit from the information and services offered.

For more information about tracking technologies, please see “Third Party Tracking and Online Advertising” below.

2. HOW WE USE YOUR INFORMATION

We may use your information for the following purposes:

To update your in-app contacts with the latest profile information, enable you to send your vCard and invite others to join the Service and connect with you, and take advantage of StayTouch features such as chat, connection analytics (e.g. how many times you’ve met with a person, extent of meetings), or meeting reminders.

To complete your transactions and requests, and to operate, maintain, improve, and provide to you the features and functionality of the Service, including the StayTouch Premium Service.

To communicate directly with you, such as to send you Service-related emails and push notifications (e.g., account verification, updates to features of the Service, technical and security notices). We may also send you promotional messages, including email messages and push notifications, from us and from our partners. You may change your communications preferences at any time, see the Control Over Your Information section below. Please note that you are not able to opt-out of receiving service messages from us, including security and legal notices.

To remember your information so you will not have to re-enter it during a subsequent visit; help you efficiently access your information after you sign in; provide, improve, test, update and monitor the Service; or diagnose or fix technology problems.

To identify potential customers who are using our services for marketing purposes.

To enable you to participate in the interactive features of the Service (such as engaging in surveys or promotions).

To comply and fulfill our legal duties and obligations such as tax and accounting purposes.

To ensure the security of our products and services and preventing abuse.

To ensure the security of our IT environments and protection of data.

To respond to your emails, comments, questions or requests for customer service.

For any other purpose we may describe when you provide the information.

3. HOW WE SHARE YOUR INFORMATION

We may share your personal information in the instances described below. For further information on your choices regarding your information, see the Control Over Your Information section below.

We may share your personal information with:

Employee Information with Customers: We may share the contacts, meetings, notes, and other personal information an Employee uploads, receives, or creates through the Service with the customer that employs that Employee.

Third parties at your request. For example, you may share your contact information with others through email, or text, or you may want to chat with them or invite others to join the Service and add you as a contact. Third parties will only see your name (and company name if you have provided one), until they accept you as a contact. You will only see a third party’s name (and third party’s company name if they have entered one), until you accept them as a contact. Once the connection is made, a third party will be able to see the information you include in your profile. Please do not include in your profile personal information you would not want to be shared. If you subscribe to our StayTouch Premium Service, you may be able to create multiple profiles. Only the information included in the specific profile shared with a contact will be visible. For example, if you have a “painter” profile and a “writer” profile through your StayTouch Premium Service, and you share your “writer” profile with a contact, that contact will only see the information included in the “writer” profile, and not the “painter” profile. You are in full control of the profiles you create, and the profiles you share with your contacts (number of profiles depends on whether you have the StayTouch Basic or Premium Service).

Third parties at the request of your contacts, Your contacts may direct us to share your vCard information with others though email, text or other instant messaging service.

Other companies and brands owned or controlled by StayTouch, and other companies owned by or under common ownership as StayTouch, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns. These companies will use your personal information in the same way as we can under this Policy.

Third parties with whom we partner to provide contests and sweepstakes, which will usually be identified by name in the Official Rules of the contest or sweepstakes.

Third-party vendors and other service providers that perform services on our behalf, as needed to carry out their work for us, which may include identifying and serving targeted advertisements, providing audio transcription, scanning, and mailing services, third-party platforms for authenticating your account and processing your payments, providing tax and accounting services, contest fulfilment, web hosting, or providing analytic services.

The public when you provide feedback on our Service. For example, if you post user content on our blog or comment on our social media sites, your information, such as your first name, last initial, state of residence, and your comments, may be displayed on our website or on our social media pages.

Other parties in connection with a company transaction, such as a merger, sale of company assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by another company or third party, or in the event of a bankruptcy or related or similar proceedings.

Third parties as required by law or subpoena or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce our Terms of Use or to protect the security or integrity of our Service; and/or (c) to exercise or protect the rights, property, or personal safety of StayTouch, our visitors, or others.

Aggregated or Anonymized information. We may also share information with others in an aggregated or otherwise anonymized form that does not reasonably identify you directly as an individual.

4. CONTROL OVER YOUR INFORMATION

Profile and Data Sharing Settings. You may update your profile information, such as your company name, job title, and profile photo etc. by editing information on your user profile(s) screen(s) and may change some of your data sharing preferences on your Settings page or by emailing us at contact@staytouch.com.

Access to Your Device Information. You may control the App’s access to your device information through your “Settings” app on your device. For instance, you can withdraw permission for the App to access your address book, location, photo stream, and camera.

How to Control Your Email/Marketing Communications Preferences. You can stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in such communications. We make every effort to promptly process all unsubscribe requests. You may not opt out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Service, technical and security notices).

How to Control Push Notifications. You can stop receiving push notifications from us by changing your preferences on your Settings page, by clicking on send notifications tabs on screens such as favorites in your StayTouch contact book, or by emailing us at contact@staytouch.com.

Modifying or Deleting Information. Users with questions about reviewing, modifying, or deleting your information, or who want to remove their name or comments from our Service or publicly displayed content, can contact us directly at contact@staytouch.com. We may not be able to modify or delete your information in all circumstances. For example, if you are an Employee, we modify or delete information in accordance with the terms of our agreement with the relevant customer.

5. THIRD-PARTY TRACKING AND ONLINE ADVERTISING

Interest-Based Advertising. We participate in interest-based advertising and use third-party advertising companies to serve you targeted advertisements based on your browsing history. We may share, or we may permit third-party online advertising networks, social media companies, and other third-party services to collect information about your use of our website over time so that they may play or display ads on our Service, on other devices you may use, and on other websites, apps, or services, including on Facebook. Typically, though not always, the information we share is provided through cookies or similar tracking technologies, which recognize the device you are using and collect information, including click stream information, browser type, time and date you visited the site, and other information. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research.

Social Media Advertising. We display targeted advertising to you through social media platforms, such as Facebook, Twitter, Google+, and others. These companies have interest-based advertising programs that allow us to direct advertisements to users who have shown interest in our Service while those users are on the social media platform or to groups of other users who share similar traits, such as likely commercial interests and demographics. These advertisements are governed by the privacy policies of those social media companies that provide them.

Cross-Device Linking. We, or our third-party partners, may link your various devices so that content you see on one device can result in relevant advertising on another device. We do this by collecting information about each device you use when you are logged in to our Service. We may also work with third-party partners who employ tracking technologies or the application of statistical modeling tools to determine if two or more devices are linked to a single user or household. We may share a common account identifier (such as an email address or user ID) with third-party advertising partners to help recognize you across devices. We, and our partners, can use this cross-device linkage to serve interest-based advertising and other personalized content to you across your devices, to perform analytics, and to measure the performance of our advertising campaigns.

Your Choices:

Interest-Based Advertising. To learn about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Network Advertising Initiative’s online resources at http://www.networkadvertising.org/choices and/or the DAA’s resources at www.aboutads.info/choices .

Cross-Device Linking. Please note that opting-out of receiving interest-based advertising through the NAI’s and DAA’s online resources will only opt-out a user from receiving interest-based ads on that specific browser or device, but the user may still receive interest-based ads on his or her other devices. You must perform the opt-out on each browser or device you use.

Mobile Advertising. You may also be able to limit interest-based advertising through the settings on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest-based ads” (Android). You may also be able to opt-out of some—but not all—interest-based ads served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.

Some of these opt-outs may not be effective unless your browser is set to accept cookies. If you delete cookies, change your browser settings, switch browsers or computers, or use another operating system, you will need to opt-out again.

Google Analytics and Advertising. We use Google Analytics to recognize you and link the devices you use when you visit our site or Service on your browser or mobile device, log in to your account on our Service, or otherwise engage with us. We share a unique identifier, like a user ID or hashed email address, with Google to facilitate the service. Google Analytics allows us to better understand how our users interact with our Service and to tailor our advertisements and content to you. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google's site “How Google uses data when you use our partners’ sites or apps”. You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Ad-On here https://tools.google.com/dlpage/gaoptout/ .

We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to the Service. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/lireferences , or by visiting NAI’s online resources at http://www.networkadvertising.org/choices.

6. DATA RETENTION

We may retain your information as long as appropriate for business purposes, unless we are required by law or regulation or for litigation and regulatory investigations to keep it for longer periods of time. Any personal information that we have acquired, either directly or from third parties, and that is no longer needed for any business or record-keeping purposes, is disposed of securely and in compliance with established best practices for secure data destruction and/or deidentification.

7. CONFIDENTIALITY AND SECURITY

We maintain commercially reasonable physical, electronic, and procedural safeguards designed to protect the information. These safeguards include storing your information on our secure servers behind firewalls. Despite the actions and precautions, we take, no data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of the information and you acknowledge and agree that you transmit it to us at your own risk. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose personal information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

8. CHILDREN’S PRIVACY

We do not knowingly collect or solicit any information from anyone under the age of 13 on this Service. In the event that we learn that we have inadvertently collected personal information from a child under age 13, we will delete that information. If you believe that we might have any information from a child under 13, please contact us at privacy@staytouch.com.

9. LINKS TO OTHER WEB SITES AND SERVICES

The Service may contain links to and from third-party websites of our business partners, advertisers, and social media sites and our users may post links to third-party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. We strongly recommend that you read their privacy policies and terms and conditions of use to understand how they collect, use, and share information. We are not responsible for the privacy practices or the content on the websites of third-party sites.

10. CALIFORNIA PRIVACY RIGHTS

Where provided for by law and subject to any applicable exceptions, California residents may have the right:

• To know the categories of personal information that StayTouch has collected about you, the business purpose for collecting your personal information, and the categories of sources from which the personal information was collected;
• To access the specific pieces of personal information that StayTouch has collected about you;
• To know whether StayTouch has disclosed your personal information for business purposes, the categories of personal information so disclosed, and the categories of third parties to whom we have disclosed your personal information;
• To have StayTouch, under certain circumstances, delete your personal information;
• To instruct businesses that sell personal information to stop doing so – StayTouch, however, does not sell personal information; and
• To be free from discrimination related to the exercise of these rights.

Users who would like to exercise any or all of these rights may do so by filling out the form here or contacting us as set forth below. After we receive your request, we may request additional information from you to verify your identity. Your authorized agent may submit requests in the same manner, although we may require the agent to present signed written permission to act on your behalf, and you may also be required to independently verify your identity with us and confirm that you have provided the agent permission to submit the request. Employees should direct their requests to the relevant customer.

Please contact us with questions or to request access to an alternative format of this Privacy Policy.

11. EU USERS

Scope. This section applies to individuals in the EU (for these purposes, reference to the EU also includes the European Economic Area countries of Iceland, Liechtenstein and Norway, the United Kingdom, and, to the extent applicable, Switzerland).

Legal Bases for Processing. We process Employees’ information pursuant to our contracts with our customers. The specific purposes for which we process Users’ personal information and the legal bases we rely on for the processing are listed below.

Your Rights. Pursuant to the European Union General Data Protection Regulation (or “GDPR”), you have the following rights in relation to your personal information, under certain circumstances and subject to any applicable exceptions:

• Right of access: If you ask us, we will confirm whether we are processing your personal information and, if so, provide you with a copy of that personal information along with certain other details. If you require additional copies, we may need to charge a reasonable fee.
• Right to rectification: If your personal information is inaccurate or incomplete, you are entitled to ask that we correct or complete it. If we shared your personal information with others, we will tell them about the correction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your personal information so you can contact them directly.
• Right to erasure: You may ask us to delete or remove your personal information, such as where you withdraw your consent. If we shared your data with others, we will tell them about the erasure where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your personal information with so you can contact them directly.
• Right to restrict processing: You may ask us to restrict or “block” the processing of your personal information in certain circumstances, such as where you contest the accuracy of the data or object to us processing it (please read below for information on your right to object). We will tell you before we lift any restriction on processing. If we shared your personal information with others, we will tell them about the restriction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your personal information so you can contact them directly.
• Right to data portability: You have the right to obtain your personal information from us that you consented to give us or that was provided to us as necessary in connection with our contract with you, and that is processed by automated means. We will give you your personal information in a structured, commonly used and machine-readable format. You may reuse it elsewhere.
• Right to object: You may ask us at any time to stop processing your personal information, and we will do so:
  • If we are relying on a legitimate interest to process your personal information -- unless we demonstrate compelling legitimate grounds for the processing or we need to process your data in order to establish, exercise, or defend legal claims;
  • If we are processing your personal information for direct marketing. We may keep minimum information about you in a suppression list in order to ensure your choices are respected in the future and to comply with data protection laws (such processing is necessary for our and your legitimate interest in pursuing the purposes described above);
• Right to withdraw consent: If we rely on your consent to process your personal information, you have the right to withdraw that consent at any time. Withdrawal of consent will not affect any processing of your data before we received notice that you wished to withdraw consent.
• Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we handled your personal information, you can report it to the data protection authority that is authorized to hear those concerns (in the UK, the Information Commissioner’s Office (ICO), who can be contacted at https://ico.org.uk/concerns, and in other EU countries the data protection authority of the country in which you are located).

Please see the “Contact Us” section below for information on how to exercise your rights.

StayTouch is headquartered in the U.S. The U.S. may have data protection laws less stringent than or otherwise different from the laws in effect in the EU and UK. Transfers of your personal information to StayTouch in the U.S. are necessary to perform the agreement we have entered into, or are about to enter into, with you.

12. HOW TO CONTACT US

If you have any questions about this Privacy Policy or the Service, please contact us at legalcontact@staytouch.com.