Privacy Policy

Welcome to Haive (the “Platform”). The Platform is provided and controlled by Haive Inc. (“Haive”, “we” or “us”). This Privacy Policy covers the experience we provide for users age 13 and over on our Platform. For information about our under-13 experience (“Children’s Platform”) and our practices in the United States regarding children’s privacy, please refer to our Privacy Policy for Younger Users. Capitalized terms that are not defined in this policy have the meaning given to them in the Terms of Service.

General

At Haive, we care about your personal data, so we have prepared this Privacy Policy to explain how we collect, use and share it.

This Privacy Policy (“Privacy Policy”) details the personal data Haive, Inc receives about you, how we process it and your rights and obligations in relation to your personal data.

We collect information when you create an account and use the Platform, such as your contact details, content you create, and your location. We also collect information you share with us from third-party social network providers, and technical and behavioral information about your use of the Platform. We also collect information contained in the messages you send through our Platform and information from your phone book, if you grant us access to your phone book on your mobile device.

Haive, Inc., a company registered at 5900 Penn Ave, Second Floor, Pittsburgh, PA 15206, United States of America is the data controller for the purposes of the General Data Protection Regulation (“GDPR”) and any relevant local legislation (“Data Protection Laws”).

By using or accessing the Service, you agree to the terms of this Privacy Policy. Capitalized terms not defined here have the meanings set forth in the terms and conditions (the “Terms and Conditions”), located at www.Haive.com/terms. We may update our Privacy Policy to reflect changes to our information practices. If we do this and the changes are material, we will post a notice that we have made changes to this Privacy Policy on the Website for at least 7 days before the changes are made, and we will indicate the date these terms were last revised at the bottom of the Privacy Policy. Any revisions to this Privacy Policy will become effective at the end of that 7 day period.

Information We Collect

This Privacy Policy explains how we collect, use and share your personal data.

We may receive information about you from other sources. For example, if you choose to link or sign up using your social network (such as Facebook, Twitter, Instagram, or Google), we may collect information from these third-party services, including your contact lists for these services and information relating to your use of the Platform in relation to these services.

We will also receive information about you (including age data and demographic information) from third parties (such as advertising networks and analytics providers) and from other sources, including business directories and other commercially or publicly available sources.

Information we collect automatically

We automatically collect certain information from you when you use the Platform, including your IP address, location-related data (as described below), unique device identifiers, browsing history (including content you have viewed in the Platform), Cookies (as defined below), your mobile carrier, time zone setting, and mobile or device information including the model of your device, screen resolution, operating system, app and file names and types, and platform.

Information you provide

Through the registration process, you will provide us with your name, e-mail address (or parent’s e-mail address), and age or date of birth. You will also provide us with your payment transaction information if you choose to pay for Haive services.

For certain activities, such as when you register, upload content to the Platform, or contact us directly, you may provide some or all of the following information:

• Registration information, such as age, language, and email or phone number

• Profile information, such as name, social media account information, and profile image

• User-generated content, including comments, photographs, videos, and virtual item videos that you choose to upload or broadcast on the Platform (“User Content”)

• Payment information, such as PayPal or other third-party payment information (where required for the purpose of payment)

• Your phone and social network contacts, with your permission. If you choose to find other users through your phone contacts, we will access and collect the names and phone numbers and match that information against existing users of the Platform. If you choose to find other users through your social network contacts, we will collect your public profile information as well as names and profiles of your social contacts

• Your opt-in choices and communication preferences

• Information to verify an account such as a form of identification

• Information in correspondence you send to us

• Information you share through surveys or your participation in challenges, sweepstakes, or contests such as your gender, age, likeness, and preferences.

Usage Information

We collect information regarding your use of the Platform and any other User Content that you generate through and broadcast on our Platform. We also link your subscriber information with your activity on our Platform across all your devices using your email, phone number, or similar information.

Activity Data

When you use the Service, you will submit information and content to your profile. We will also generate data about your use of our Services including your engagement in educational activities on the Service, or your sending of messages and otherwise transmitting information to other users (“Activity Data”). We also collect technical data about how you interact with our Services; for more information, see Cookies.

Messages

We collect and process, which includes scanning and analyzing, information you provide in the context of composing, sending, or receiving messages through our Service's messaging functionality. That information includes the content of the message and information about when the message has been sent, received and/or read, as well as the participants of the communication. Please be aware that messages sent to other users of our Service will be accessible by those users and that we are not responsible for the manner in which those users use or disclose messages.

Live Speaking Practice

When you take a Live Speaking Lesson, we will use your computer's microphone throughout the lesson to speak to your tutor. You also have the option of using your camera to share your video with your tutor. Haive records these audio and video lessons and retains them until you close your Haive account. Haive uses this data to help improve the quality of the lessons and for internal research purposes.

Haive does not share any of your personal data with your tutor. You are completely anonymous to them by default, and you can freely choose whether you show them your video or tell them any personal details such as your name during the conversation. Haive only shares some basic skill level information with the tutor, prior to your lesson, so they understand how best to speak to you.

Metadata

When you upload User Content, you automatically upload certain metadata that is connected to the User Content. Metadata describes other data and provides information about your User Content that will not always be evident to the viewer. In connection with your User Content the metadata can describe how, when, and by whom the piece of User Content was collected and how that content is formatted. It also includes information, such as your account name, that enables other users to trace back the video to your user account. Additionally, metadata will consist of data that you chose to provide with the video, e.g. any hashtags used to mark keywords to the video and captions.

Third Party Data

We also collect information about you from third parties. For more information, see Information obtained by Third Parties.

Product Research and Development

We may contact you to participate in product research activities. These may include surveys, interviews, and other types of feedback sessions. When you participate in these research activities, the information you provide will be used to test, improve, and develop our products. We will record the video, audio and text transcriptions of this feedback together with any additional contact information you provide and will retain this data for two years.

Cookies

When you enter the Website, we collect your browser type and your IP address (a unique address that identifies your computer on the Internet). When you use our mobile Application, we collect your device type, your device ID, and your IP address.

We store certain information from your browser using "cookies." A cookie is a piece of data stored on the user's computer tied to information about the user. We use session ID cookies to confirm that users are logged in. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to deny or accept the cookie feature; however, you should note that cookies may be necessary to provide you certain features available on the Website (e.g., customized delivery of information).

Additionally, we allow our business partners, advertising networks, and other advertising vendors and service providers (including analytics vendors and service providers) to collect information about your online activities through Cookies. We link your contact or subscriber information with your activity on our Platform across all your devices, using your email or other log-in or device information. These third parties may use this information to display advertisements on our Platform and elsewhere online tailored to your interests, preferences, and characteristics. We are not responsible for the privacy practices of these third parties, and the information practices of these third parties are not covered by this Privacy Policy.

You can find more information about cookies and how to manage them at http://www.allaboutcookies.org.

Information Obtained by Third Parties

To support and enhance the Service, we work with a variety of third party advertising networks, marketing analytics service providers and website analysis firms, such as Google, Facebook, Oath, and Unity (collectively, “Third Party Advertising Service Providers”). These Third Party Advertising Service Providers collect and use personal data about your visits to and use of the Website and mobile Application, as well as other websites in order to serve you with advertisements and content tailored to meet your preferences and likely interests or better understand ad effectiveness. Aggregate demographic and interest data will also be used for market research purposes.

We use Google Analytics which is a web analytics tool that helps us understand how users engage with the Website. Like many services, Google Analytics uses first-party cookies to track user interactions as in our case, where they are used to collect information about how users use our site. This information is used to compile reports and to help us improve our Website. The reports disclose website trends without identifying individual visitors. You can opt out of Google Analytics without affecting how you visit our site – for more information on opting out of being tracked by Google Analytics across all websites you use, visit this Google page: https://tools.google.com/dlpage/gaoptout.

You can opt-out of receiving personalized ads from advertisers and ad networks that are members of the Network Advertising Initiative (“NAI”) or who follow the DAA Self-Regulatory Principles for Online Behavioral Advertising using their respective opt-out tools. The NAI's opt-out tool can be found here http://www.networkadvertising.org/choices/ and the DAA's opt out tool can be found here http://www.aboutads.info/choices/.

In addition, your mobile devices may offer settings that enable you to make choices about the collection, use, or transfer of mobile app information for online behavioral advertising (for example, Apple iOS’ Advertising ID and Google Android’s Advertising ID). Please note that opting out does not prevent the display of all advertisements to you.

How we use your information

We use your information to fulfill and enforce our Terms of Service, to improve and administer the Platform, and to allow you to use its functionalities. We may also use your information to, among other things, show you suggestions, promote the Platform, and customize your ad experience.

We generally use the information we collect:

• to fulfill requests for products, services, Platform functionality, support and information for internal operations, including troubleshooting, data analysis, testing, research, statistical, and survey purposes and to solicit your feedback

• to customize the content you see when you use the Platform. For example, we may provide you with services based on the country settings you have chosen or show you content that is similar to content that you liked or interacted with

• to send promotional materials from us or on behalf of our affiliates and trusted third parties

• to improve and develop our Platform and conduct product development

• to measure and understand the effectiveness of the advertising we serve to you and others and to deliver targeted advertising

• to make suggestions and a customized ad experience

• to support the social functions of the Platform, including to permit you and other users to connect with each other through the Platform and for you and other users to share, download, and otherwise interact with User Content posted through the Platform

• to use User Content as part of our advertising and marketing campaigns to promote the Platform

• to help us detect abuse, fraud, and illegal activity on the Platform

• to ensure that you are old enough to use the Platform (as required by law)

• to communicate with you, including to notify you about changes in our services

• to announce you as a winner of our contest, sweepstakes, or promotions if permitted by the promotion rule, and to send you any applicable prizes

• to enforce our terms, conditions, and policies

• consistent with your permissions, to provide you with location-based services, such as advertising and other personalized content

• to inform our algorithms

• to combine all the information we collect or receive about you for any of the foregoing purposes

• for any other purposes disclosed to you at the time we collect your information or pursuant to your consent.

Sharing your personal data with third parties

Authorized third-party vendors and service providers.

We share your information with third-party vendors and service providers that help us perform our business operations, including research, payment processing and transaction fulfillment, database maintenance, contest administration, technology services, deliveries, email deployment, advertising, analytics, measurement, data storage and hosting, disaster recovery, search engine optimization, marketing, and data processing.

Business partners.

We may share your information with our business partners so that we can make you special offers via the Platform.

Corporate group.

We may share your information with a parent, subsidiary, or other affiliate of our corporate group.

Business transfers.

We may share your information in connection with a substantial corporate transaction, such as the sale of a website, a merger, consolidation, asset sale, or in the unlikely event of bankruptcy.

Legal purposes. We may disclose information to respond to subpoenas, court orders, legal process, law enforcement requests, legal claims or government inquiries, and to protect and defend the rights, interests, safety, and security of Haive Inc, our affiliates, users, or the public.

Advertisers.

We give advertisers reports about the types of people seeing their ads and how their ads are performing.

With your consent.

We may share information for any other purposes disclosed to you at the time we collect the information or pursuant to your consent.

Data subject rights and data retention

You can manage your account settings at https://www.Haive.com/settings/account to update, amend, and correct your information.

You also have the following rights in relation to the personal data we hold about you, unless provided otherwise by local law:

• To request access to, or erasure of, the personal data we hold about you.

• To request us to restrict the processing of the personal data we hold about you.

• To object to us processing personal data relating to you.

• Where you have given us consent to process your personal data, you have the right to withdraw that consent at any time.

• To export the personal data you have provided to Haive in a format that can be transferred electronically to a third party.

• To delete your account with Haive by following the instructions available through the Service.

Haive will retain your data until your account is deleted, after which point we will retain anonymous data collected through the Service, including Activity Data, which may be used by Haive and shared with third parties in any manner.

Please note that some of these rights are not absolute. In some cases, we may refuse a request to exercise particular rights if complying with it meant that we are no longer able to meet our contractual obligation to provide you with particular products and services. We will keep you informed as to the actions that we can take when you make your request.

You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. If you need further assistance regarding your rights, please contact us using the contact information provided below and we will consider your request in accordance with applicable law. In some cases our ability to uphold these rights for you may depend upon our obligations to process personal information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.

Third party websites and links

Please note that you may have cookies placed on your computer by third party websites that refer you to our Service. Although we do not share your personal data with these third party websites unless it is reasonably necessary to offer the Service, they may be able to link certain non-personally identifiable information we transfer to them with personal data they previously collected from you. Please review the privacy policies of each website you visit to better understand their privacy practices. In addition, Haive would like to inform you that anytime you click on links (including advertising banners), which take you to third party websites, you will be subject to the third parties’ privacy policies.

Our Services contain links to other sites operated by third parties. Haive does not control such other sites and is not responsible for their content, their privacy policies, or their use of personal data, including any personal or financial information collected by our third party payment processor to process payments for in-app purchases. Haive’s inclusion of such links does not imply any endorsement of the content on such sites or of their owners or operators except as disclosed on the Services. Any information submitted by you directly to these third parties is subject to that third party’s privacy policy.

Your Choices

You may be able to refuse or disable Cookies by adjusting your browser settings. Because each browser is different, please consult the instructions provided by your browser. Please note that you may need to take additional steps to refuse or disable certain types of Cookies. For example, due to differences in how browsers and mobile apps function, you may need to take different steps to opt out of Cookies used for targeted advertising in a browser and to opt out of targeted advertising for a mobile application, which you may control through your device settings or mobile app permissions. In addition, your opt-out selection is specific to the particular browser or device that you are using when you opt out, so you may need to opt-out separately for each of browser or device. If you choose to refuse, disable, or delete Cookies, some of the functionality of the Platform may no longer be available to you.

You can manage third-party advertising preferences for some of the third parties we work with to serve advertising across the Internet by clicking here and by utilizing the choices available at http://www.networkadvertising.org/managing/opt_out.asp and www.aboutads.info/choices.

Your mobile device may include a feature that allows you to opt out of some types of targeted advertising ("Limit Ad Tracking" on iOS and "Opt out of Interest-Based Ads" on Android).

You can opt out of marketing or advertising emails by utilizing the “unsubscribe” link or mechanism noted in marketing or advertising emails.

You can switch off GPS location information functionality on your mobile device if you do not wish to share GPS information.

If you have registered for an account you may access, review, and update certain personal information that you have provided to us by logging into your account and using available features and functionalities.

Some browsers transmit "do-not-track" signals to websites. Because of differences in how browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. We currently do not take action in response to these signals.

Security

We use reasonable measures to help protect information from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction. You should understand that no data storage system or transmission of data over the Internet or any other public network can be guaranteed to be 100 percent secure. Please note that information collected by third parties may not have the same security protections as information you submit to us, and we are not responsible for protecting the security of such information.

Children under age of digital consent

Haive provides some features and services intended for use by children. Haive uses age-gating to restrict what services are available to children depending on the age of the user and the applicable laws of their country. For example, a 15 year old child in Germany will require parental consent to use the Service, whereas a 12 year old child in the United States of America would receive a restricted service but not require parental consent.

Children within the European Union

Each European Union (EU) member state is permitted to legally define its own digital age of consent between 13 and 16. Haive checks the age and country of the user to determine if the user is able to consent to the Service. If consent of a parent/guardian is required, the user will input the e-mail address of an adult who will receive a request to approve the child’s account registration. In the absence of a country specific Act of Law, the age of consent will be set at 16.

These EU child users will receive the following service restrictions: they will not be able to use the service until their parent/guardian has provided consent for the child to do so. After the parent/guardian has given consent, they child will be allowed to access the full Haive service.

Where Haive does make features and services available to children, we recognize that collecting personal data from children requires further privacy protections. Accordingly, Haive will: (1) notify parents or guardians about Haive’s privacy and information practices regarding children, including what personal data we collection and how we use, share, and protect that personal data; (2) limit our collection of personal data to ensure that we collect no more than is necessary to provide Haive’s services; (3) obtain parental consent before collecting personal data from children; and (4) allow parents to request that Haive change or delete personal data about their children.

Children outside of the European Union

If a child of under 13 years from outside the EU registers for the Haive service, upon registration the child will provide an adult’s e-mail address, to whom Haive sends a notification.

These child users will receive the following service restrictions:

• Instead of any Personally Identifiable Information about the child, we will only store the e-mail address of their parent/guardian.

• Only family friendly advertisements are shown and these ads do not do behavioral tracking.

• Mature words such as "beer" and "wine" are disabled.

• Social features are disabled, e.g. profiles, forums, clubs, etc.

• They can not enter profile information such as a profile picture or a bio.

• At the point when the user is known to have reached the age of 13, the account will automatically be transitioned to be a normal non-restricted account.

At all times Haive does not knowingly collect personal information from children in connection with the Service. If we discover that we have unknowingly collected personal information from these children, we will delete it.

Links

The Service may contain links to other websites. We are not responsible for the privacy practices of other websites. We encourage users to be aware when they leave the Service to read the privacy statements of other websites that collect personally identifiable information. This Privacy Policy applies only to information collected by Haive via the Service.

Information security

Haive has implemented administrative and technical safeguards it believes are appropriate to protect the confidentiality, integrity and availability of your personal data, User Photo, and access credentials. However, given sufficient resources, a determined attacker could defeat those safeguards and may, as a result, gain access to the data we seek to protect.

Do Not Track

The Service is not designed to respond to “do not track” signals sent by some browsers.

Changes

We may update this Privacy Policy from time to time. When we update the Privacy Policy, we will notify you by updating the “Last Updated” date at the top of this policy and posting the new Privacy Policy and providing any other notice required by applicable law. We recommend that you review the Privacy Policy each time you visit the Platform to stay informed of our privacy practices.

If you are an EU resident, instead of the below, this Privacy Policy shall apply. If your usual residence is in Germany, this Privacy Policy shall apply. If your usual residence is in Russia, this Privacy Policy shall apply. If your residence is in another country, and not the US, this Privacy Policy shall apply.