Privacy Policy

1. Who We Are and What We Do

At Tinode we build and support messaging software and provide messaging services to allow our customers to communicate with each other. This Privacy Policy explains our information practices, the kinds of information we collect, how we use and share that information, and your options.

2. Scope

This Privacy Policy applies to Personal Information Processed by us in our business, including on our websites (each a “Site”), hosted services, application servers, mobile applications, forums, blogs, and other online or offline offerings (collectively, the “Services”). All Individuals whose responsibilities include Processing Personal Information for us are expected to protect it by following this Privacy Policy.

This Policy applies to all of Tinode LLC's operating divisions, subsidiaries, affiliates, and branches, and any additional subsidiary, affiliate, or branch of Tinode LLC that we may subsequently form.

3. Transparency/Notice

3.1. Personal Information We Collect

The types of Personal Information we collect and our privacy practices depend on whether you are a user or visitor of the Services (together, “Individuals”), if you are using our mobile or web applications to connect to a third party service or to the servers we control, and the requirements of applicable law.

• Account Creation. We may collect Personal Information from you such as your phone number and email address when you create an Account with us. However, other than the username you select, the name you give us (which you may choose to be anything you want), and avatar you select to represent you we will not display any Personal Information you provide to create your Account to other users, including the users you message, on the Services. If you are using our mobile application to connect to a third party service this information will be passed to them.
• Contact Information. As part of the Account creation process, we will request permission from you to access and store the contact information of your contacts saved to your mobile device. These contacts will be used when you search for other users to connect to through our services. If you are using our mobile application to connect to a third party service the contacts will be passed to them. You may choose to deny permission to access your contacts. It will not affect the core functionality of the app but will make searching for connections more difficult. From time to time, we will update your list of connections on the Services based on your current contacts list.
• Communications with Us. We may collect Personal Information from you such as your name, email address or phone number when you request information about our Services, request user or technical support, or otherwise communicate with us.
• Communications with Other Users. We store Personal Information you choose to disclose about yourself through your communications with other users. We do not process this information other than storing unless the communication is reported as non-compliant with our Acceptable Use Policy and then we may process it further.
• Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include Personal Information.
• Posting. We may offer forums or blogs in which you can contribute posts or comments to. Any content you provide on these channels will be considered “public” to other users of the Services and is not subject to privacy protections.
• Automatic Data Collection. We may collect certain information automatically when you use the Services. This information may include your Internet protocol (IP) address, user settings, cookie identifiers, mobile carrier, and other unique identifiers, details about your browser, operating system or device, location information, Internet service provider, information about the links you click, and other information about how you use the Services. Information we collect may be associated with accounts and other devices.

3.2. How We Use Your Information

We Process Personal Information about Individuals for a variety of business purposes, including:

• To Provide Products, Services, or Information Requested including to:
  • Manage Individual information and Accounts;
  • Respond to questions, comments, and other requests;
  • Provide access to certain areas, functionalities, and features of our Services; and
  • Answer requests for user or technical support.
• For Administrative Purposes including to:
  • Measure interest and engagement in our Site and Services;
  • Conduct research and development;
  • Improve our products and Services;
  • Develop new products and Services;
  • Ensure internal quality control;
  • Verify Individual identity;
  • Communicate with you about your Account, activities on our Site and Services and policy changes;
  • Prevent potentially prohibited or illegal activities; and
  • Enforce our Terms and Acceptable Use Policy.
• To Market Our Products and Services. We may use Personal Information to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. We may provide you with these materials as permitted by applicable law. Such uses include:
  • To tailor content and offers;
  • To notify you about our offers, products, and services that may be of interest to you;
  • To provide Services to you and our sponsors; and
  • Other purposes you consent to or are disclosed when you provide Personal Information.

You may contact us at any time to opt out of the use of your Personal Information for marketing purposes as described below.

• De-identified and Aggregated Information Use. We may use Personal Information and other information about you to create de-identified and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access our Site and Services, or other analyses we create. De-identified or aggregated information is not Personal Information, and we may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes.
• Other Uses. Tinode LLC may use Personal Information to pursue legitimate interests, such as direct marketing, research (including marketing research), network and information security, and fraud prevention, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.

3.3. Cookies, Pixel Tags/Web Beacons, and Analytics Information

We, as well as third parties that provide content or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. Technologies are essentially small data files placed on your computer, tablet, mobile phone, or other devices that allow us to record certain pieces of information whenever you visit or interact with our Site and Services.

• Cookies. Cookies are small text files placed in visitors’ device browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly.
• Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page.
• Analytics. We may also use the following analytics services to collect information regarding visitor behavior and visitor demographics on our Site and Services.
  • Google Analytics for Firebase: For more information about Google Analytics for Firebase, please visit https://firebase.google.com/terms/. You can opt out of Google’s collection and Processing of data generated by your use of the Services by going to https://policies.google.com/privacy?hl=en.

Our uses of such Technologies fall into the following general categories:

• Operationally Necessary. This includes Technologies that allow you access to our Site, Services, applications, and tools that are required to identify irregular site behavior, prevent fraudulent activity and improve security or that allow you to make use of our functions such as saved search, or similar functions;
• Performance Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how our visitors use the Services;
• Functionality Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Site and Services. This may include identifying you when you sign into our Site or Services or keeping track of your preferences and interests;

3.4. Third Party Websites/Applications, Social Media Platforms and Software Development Kits

The Services may contain links to other websites/applications and other websites/applications may reference or link to our Site or other Services. These other websites and applications are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.

We may use third party APIs and software development kits (“SDKs”) as part of the functionality of our Services. APIs and SDKs may allow third parties to collect your Personal Information to provide content that is more relevant to you. We use the following SDKs: Firebase, Crashylitics. For more information about our use of APIs and SDKs, please contact us as set forth below.

4. Onward Transfer — How We May Disclose Your Information

4.1. Information We Share

We may share your information as described in this Privacy Policy:

• We Use Service Providers. We may share any information we receive with service providers. The types of service providers (processors) to whom we entrust Personal Information include service providers for: (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) user service activities, including the monitoring of user communications on the Services to ensure compliance with our Acceptable Use Policy; and (iv) the provision of the Site and Services.
• Business Partners. We may provide Personal Information to business partners with whom we jointly offer products or services. In such cases, our business partner’s name will appear along with ours.
• Disclosures to Protect Us or Others. We may access, preserve, and disclose your Personal Information, other account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect your, our or others’ rights, property, or safety; (iv) to enforce our policies or contracts; (v) to collect amounts owed to us; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
• Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract.

4.2 International Data Transfers

You agree that all information Processed by us may be transferred, Processed, and stored anywhere in the world, including but not limited to, the European Union, the United States or other countries. Personal Information may be stored in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request.

5. Your Choices: Right to Object to Processing

5.1. General

You have the right to object to or opt out of certain uses of your Personal Information. Where you have consented to the Processing of your Personal Information, you may withdraw that consent at any time and prevent further Processing by contacting us as described below. Even if you opt out, we may still collect and use non-Personal Information regarding your activities on our Site and Services.

5.2. Email and Telephone Communications

If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding the Services or updates to our Terms or this Privacy Policy).

We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists as may be required by law.

5.3. Mobile Devices

We may send you push notifications through our mobile application. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device. Tinode LLC may also collect location-based information if you use our mobile applications. You may opt-out of this collection by changing the settings on your mobile device.

5.4. “Do Not Track”

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

6. Data Retention

Tinode LLC retains the Personal Information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

7. Security of Your Information

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unintentional disclosure.

By using the Services or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services, by mail or by sending an e-mail to you.

8. Children’s Information

The Site and Services are not directed to people under age 18 (or other age as required by local law), and we do not knowingly collect Personal Information from children. If you learn that your child has provided us with Personal Information without your consent, you may contact us as set forth below. If we learn that we have collected any Personal Information in violation of applicable law, we will promptly take steps to delete such information and terminate the child’s account.

9. Changes to Our Privacy Policy

We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use the Services after the new Privacy Policy takes effect.

10. Terms of Service

This Privacy Policy is incorporated by reference into the Tinode Terms of Service (the “Terms”). All other terms not defined in this Privacy Policy will have the meanings set forth in the Terms. The terms “Tinode,” “we,” and “us” include Tinode LLC and our affiliates and subsidiaries.

11. Contact Us

If you have any questions about our privacy practices or this Privacy Policy, please contact us at the link on the bottom of this page or at:

 Tinode LLC
 375 Chevy Chase St.
 Reno, NV 89509 USA
 info@tinode.co

13. Definitions

• “Personal Information” is any information relating to an identified or identifiable natural person.
• “Process” or “Processing” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.