Welcome to Smoothy (“Smoothy,” “we,” “us,” or “our”). This Privacy Policy provides information to the users about the Smoothy mobile application (“App”) and website of www.smoothy.co("Site"). Our Privacy Policy is about that personal information data (“Personal Information”) which Smoothy, Inc. collects, uses, and shares, the information collected from the Site, and the information collected from the visitors of the App. Our Policy applies to all visitors, users, and others who access the Apps and the Site (“Users”). The App enable you to participate in group video chats with other Users. When you use the Apps, you will be able to join a video chat with a User with whom you are connected on the App (each a “Connection”). You can add Connections by inviting them to connect on the App.

1. How We Use the Information You Provided Us

Creating an Account and Profile Information

If you create an account, you will provide us with certain information that can be used to identify you, such as your name and phone number (“Personally Identifiable Information” or “PII”). We may also collect non-identifying information (such as your nickname) and other information that is not considered PII because it cannot be used by itself to identify you.

Contacts

When you authorize us to access your contacts information from your address book on your mobile device (“Contacts”), we will use your Contacts in order to identify and suggest other Users that you may know, Users with whom you may want to connect, or Users you may want to invite to a video chat session. For example, the App may indicate a common Contact that one or more participants in a video chat session have, with whom you may want to invite to join a video chat session.

Use of Your Information

By providing Personal Information to Smoothy you understand and agree that Smoothy will use the Personal Information based on the private policy. By collecting information, we will improve our App and enable you to enjoy and easily navigate our App.

Location Information

If you enable your computer or mobile device to send us location information we may collect and store information about your location by converting your IP address into a rough geolocation or by accessing your mobile device’s GPS coordinates. We may use and store information about your location to provide features of our App, such as providing location specific filters, stickers and to improve and customize the App with content based on your location. If you do not want us to collect location information, you may disable that feature on your mobile device. In addition, if you have provided Personal Information, this Personal Information will be transmitted to Smoothy’s server from your current location, and authorized third-party services will require you to re-authorize the use of Personal Information from this location.

Cookies

We use “Cookie” technology to collect additional information, including usage data to facilitate and improve our Services. Smoothy, Inc. may use both session Cookies and persistent Cookies to identify that you’ve logged in to the Services, to better understand how you interact with our App, to monitor aggregate usage and web traffic routing on our App, and to customize and improve our Services. Unlike persistent cookies, session Cookies are deleted when you log off from the App. If you do not want cookies from Smoothy, Inc., you can change your settings to stop accepting Cookies or to prompt you before accepting a cookie from the services you visit. However, some Apps may not function properly if you disable Cookies.

Web Beacons

Our Service may also employ the use of “Web Beacons” (also known as web bugs, pixel tags or clear GIFs). Web Beacons with a unique identifier may be included on our App for a number of purposes, and may be embedded invisibly on a web page or in an e-mail. These purposes may include monitoring, tracking, and measuring the effectiveness of our advertising as well as improving our communications with Users.

Log Data

Our servers automatically record information (“Log Data”) created by your use of the App. Log Data may include information such as your IP address, browser type, operating system, location, your mobile carrier, device and application IDs, the Users with whom you video chat, access date and time spent on features of the Services and other statistics, Cookie information, camera filters and stickers, and more. We receive Log Data when you interact with our App. For example, when you visit our websites, sign into our App, or participate in a video chat session, that information is included in our Log Data. Smoothy, Inc. uses Log Data to facilitate our App and to measure, customize, and improve them. For example, Smoothy, Inc. may provide you with recommendations based on your use of the App.

2. Sharing of Your Personal Information

Smoothy believes personal information is a crucial part of the relationship between Users. We will not share any PII and other personal information that we have collected from you or that regards you except as described below:

Information Shared with other Users

As part of our App, you may communicate with other Users through group video chat sessions. You will be able to participate in a group video chat session with your Connections and the Connections of any other User that is participating in a current session. Any Connection of a participant in a video chat session may join a chat session, with or without an invite from you and whether or not you know him or her. However, if a User that isn’t your Connection is about to join a video chat session you are in, you’ll receive a notice that such a participant is joining. When you participate in a group video chat session, the content of your communications (including audio and video) will be visible and available to any User participating in that session. In addition, your Connections and other Users may view your profile information on the Services. Your Connections will be able to see your nickname, username, profile picture, the last time you were online, your other Connections, and a list of your top Connections. Other Users (i.e., people who are not part of your Connections) will only be able to see your profile picture, nickname, and username.

Information Shared with Service Providers and Third Parties

We engage third-party service providers to perform functions and provide services to us in the United States and abroad. These third-party service providers only have access to your PII for the purpose of performing services on our behalf and are expressly obligated not to disclose or use your PII for any other purpose. We may share aggregated information and non-identifying information with third parties for industry research and analysis, demographic profiling, and other similar purposes.

Information Disclosed for Our Protection and the Protection of Others

We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. We may disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate: (i) to respond to claims, legal process (including subpoenas); (ii) to protect our property, rights and safety and the property, rights and safety of a third party or the public in general; and (iii) to stop any activity that we consider illegal, unethical or legally actionable activity.

Information Disclosed in Connection with Business Transfers

Information that we collect from our users, including PII, is considered to be a business asset. In the event that Smoothy, Inc. is involved in a bankruptcy, merger, acquisition, reorganization, or sale of assets, or if our assets are acquired by a third party in the event we go out of business or enter bankruptcy, some or all of our assets, including your PII, may be sold or transferred to a third party as part of that transaction.

3. Your Choices

We offer you choices regarding the collection, use and sharing of your PII and we’ll respect the choices you make. Please note that if you decide not to provide us with the PII that we request, you may not be able to access all of the features of the App.

4. Modifying Your Personal Information

If you are a User, we may provide you with tools and account settings to access or modify your PII associated with your account, such as your profile picture, nickname, username, and phone number. If the functionality for modifying your account is not available you can contact us at hello@gooroomee.com with your request. You can also permanently delete your account or request that we delete your PII directly, by contacting us at hello@gooroomee.com. However, some information may remain in archived/backup copies for our records or as otherwise required by law.

5. The Security of Your Information

We take reasonable administrative, physical and electronic measures designed to protect the information that we collect from or about you (including your PII) from unauthorized access, use or disclosure. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information.

6. Responding to Do Not Track Signals

Our Site does not have the capability to respond to “Do Not Track” signals received from various web browsers.

7. Links to Other Sites

Our App may contain links to websites and services that are owned or operated by third parties (each, a “Third-party Service”). Any information that you provide on or to a Third-party Service or that is collected by a Third-party Service is provided directly to the owner or operator of the Third-party Service and is subject to the owner’s or operator’s privacy policy. We’re not responsible for the content, privacy or security practices and policies of any Third-party Service. To protect your information we recommend that you carefully review the privacy policies of all Third-party Services that you access.

8. International Transfer

Your PII may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may differ from those in your jurisdiction. If you’re located outside the United States and choose to provide your PII to us, we may transfer your PII to the United States and process it there.

9. Our Policy Towards Children

Our Services are not directed to persons under 13. We do not knowingly collect PII from children under 13. If we become aware that a child under 13 has provided us with personal information, we take steps to remove such information from our files as soon as possible and terminate the child’s account.

10. Changes To This Privacy Policy

Any information that is collected via our App and Site is covered by the Privacy Policy in effect at the time such information is collected. We may revise this Privacy Policy from time to time. If we make a change to this Privacy Policy, we will notify you of those changes by posting them on the Services and we’ll update the “Last Updated Date” above to indicate when those changes will become effective. By continuing to access or use the Services after those changes become effective, you agree to be bound by the revised Privacy Policy.

Questions?

Please contact us at hello@gooroomee.com if you have any questions about our Privacy Policy.

Last Updated: Sep 20th, 2017