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SHORTI MOBILE APPLICATION
PRIVACY POLICY

Last Updated: October 16, 2018

 

1. INTRODUCTION

This privacy policy (this “Policy”) explains how personal information is collected, used, and
disclosed by Little Brown Box Works LLC (the “Company,” “we” or “us”). We respect your
privacy and are committed to protecting it through our compliance with this Policy.
As you use Shorti (the “App”), we want you to be clear how we are using information and the
ways in which you can protect your privacy. This Policy explains:
What types of information we may collect or that you may provide when you
download, install, register with, access, or use the App.

  •  How we use that information and the choices we offer for accessing and updating this
    information.
  •  Our practices for collecting, using, protecting, and disclosing that information.

This Policy applies only to information we collect in this App and in email, text, and other
electronic communications sent through or in connection with this App.
This Policy DOES NOT apply to information that:

  • We collect offline or on any other Company apps or websites, including websites you
    may access through this App.
  •  You provide to or is collected by any third party.
    Our websites and apps, and these third parties may have their own privacy policies, which we
    encourage you to read before providing information on or through them.

Please read this Policy carefully to understand our policies and practices regarding your
information and how we will treat your information. If you do not agree with our policies and
practices, do not download, register with, or use this App.
By downloading, registering with, or using this App, you agree to this Policy. This Policy may
change from time to time. Your continued use of this App after we make changes is deemed to
be acceptance of those changes, so please check the Policy periodically for updates.

2. CHILDREN UNDER THE AGE OF 13

The Children’s Online Privacy Protection Act of 1998 and its rules (collectively, “COPPA”)
require us to inform parents and legal guardians (as used in this Section, “parents”) about our
practices for collecting, using, and disclosing personal information from children under the age
of 13 (“children”).
It also requires us to obtain verifiable consent from a child’s parent for certain collection, use,
and disclosure of the child’s personal information.
This Section 2 of the Policy notifies parents of:

  •  The types of information we may collect from children.
  • How we use the information we collect.
  • Our practices for disclosing that information.
  • Our practices for notifying and obtaining parents’ consent when we collect personal
    information from children, including how a parent may revoke consent.
  • All operators that collect or maintain information from children through this App.
    This Section 2 applies only to children under the age of 13 and supplements the other provisions
    of this Policy. The other provisions of this Policy apply to teenagers and adults.

2.1 INFORMATION WE COLLECT FROM CHILDREN

Children can access many parts of the App and its content and use many of its features without
providing us with personal information. However, some content and features are available only
to registered users or require us to collect certain information, including personal information,
from them. In addition, we use certain technologies, such as cookies, to automatically collect
information from our users (including children) when they visit or use the App.
We collect only as much information about a child as is reasonably necessary for the child to
participate in an activity, and we do not condition her or his participation on the disclosure of
more personal information than is reasonably necessary.

2.2 INFORMATION WE COLLECT DIRECTLY FROM CHILDREN

A child must provide us with the following information to register with the App: the child’s pen
name (a child may choose to create a username or provide her or his real name), date of birth,
and a parent’s email address. We also require the child to create a password. We may request
additional information from your child, such as the child’s favorite genre, but this information is
optional.

 

We enable registered users to communicate with others on or through this App through direct
messaging, comments sections, photos and videos embedded in the words of you stories, as well
as post vertical photos and videos in your profile (”Social Features”). The nature of these
features allows children to disclose personal information about themselves. We do not monitor or
review this content before it is posted, and we do not control the actions of third parties with
whom your child shares his or her information. We encourage parents to educate their children
about safe Internet use and to monitor their children’s use of social features.

2.3 AUTOMATIC INFORMATION COLLECTION AND TRACKING

We use technology to automatically collect information from our users, including children, when
they access and navigate through the App and use certain features. The information we collect
through these technologies may include:

    • Average time spent in the App.
    • Information that identifies the region, in which the App was downloaded.
      We also may combine non-personal information we collect through these technologies with
      personal information about you or your child that we collect online.
      For information about our automatic information collection practices, including how you can opt
      out of certain information collection, see the “Automatic Information Collection and Tracking”(Section 2.3) and “Choices About How We Use and Disclose Your Information” (Section 2.7) sections of this Policy.

2.4 HOW WE USE YOUR CHILD’S INFORMATION

  • We use the personal information we collect from your child to:
  •  Register her or him with the App; and
    Communicate with her or him about activities or features of the App that may be
    of interest

We use the information we collect automatically through technology (see Automatic Information
Collection and Tracking, Section 2.3) and other non-personal information we collect to improve
our App and to deliver a better and more personalized experience by enabling us to:

  •  Estimate our audience size and usage patterns.
    Store information about the user’s preferences, allowing us to customize the
    content according to individual interests.
  • Speed up users’ searches.

2.5 OUR PRACTICES FOR DISCLOSING CHILDREN’S INFORMATION

 

We do not share, sell, rent, or transfer children’s personal information other than as described in
this Section 2.5.

We may disclose aggregated information about many of our users, and information that does not
identify any individual or device. In addition, we may disclose children’s personal information:

  • 1. To third parties we use to support the internal operations of our App and who are
    bound by contractual or other obligations to use the information only for such
    purpose and to keep the information confidential.
    2. If we are required to do so by law or legal process, such as to comply with any
    court order or subpoena or to respond to any government or regulatory request.
    3. If we believe disclosure is necessary or appropriate to protect the rights, property,
    or safety of the Company, our customers or others, including to:
  • Protect the safety of a child;
  • Protect the safety and security of the App; or
  •  Enable us to take precautions against liability.

4. To law enforcement agencies or for an investigation related to public safety.
In addition, if the Company is involved in a merger, divestiture, restructuring, reorganization,
dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going
concern or as part of bankruptcy, liquidation, or similar proceeding or event, we may transfer the
personal information we have collected or maintained to the buyer or other successor.

2.6 SOCIAL FEATURES

The App offers Social Features, including direct messaging, comments sections, photos and
videos embedded in the words of you stories, as well as post vertical photos and videos in your
profile, which enable children communicate with others on our through the App. We do not
control the types of information your child can send or post through them. We encourage parents
to educate their children about safety online and to carefully monitor their children’s use of
social features to ensure they do not disclose their personal information through them.

2.7 ACCESSING AND CORRECTING YOUR CHILD’S PERSONAL INFORMATION

At any time, you may review the child’s personal information maintained by us, require us to
correct or delete the personal information, and/or refuse to permit us from further collecting or
using the child’s information.

You can review, change, or delete your child’s personal information by:

  • Sending us an email at Shortiapp@gmail.com.

To protect your privacy and security, we may require you to take certain steps or provide
additional information to verify your identity before we provide any information or make
corrections.

2.8 OPERATORS THAT COLLECT OR MAINTAIN INFORMATION FROM CHILDREN

The following are all operators that may collect or maintain personal information from children
through the App: Facebook (Analytics Provider) and Backendless (Server Operator).

Please direct your inquiries about any operator’s privacy practices and use of children’s
information to the operator at its contact information provided:
Facebook
ATTN: Privacy Operations
1601 Willow Road
Menlo Park, CA 94025
Backendless
2591 Dallas Pkwy, Suite 300
Frisco, TX 75034
Email: support@backendless.com
Telephone: (408) 792-7757

3. INFORMATION WE COLLECT AND HOW WE COLLECT IT

  • We collect information from and about users of our App:
    Directly from you when you provide it to us.
  • Automatically when you use the App.

3.1 INFORMATION YOU PROVIDE TO US

When you download, register with, or use this App, we may ask you provide information:

By which you may be personally identified, such as full name, mailing address, email
address, telephone number, billing information, or any other identifier or information
the App collects that is defined as personal or personally identifiable information
under applicable law (“personal information”).

  •  That is about you that individually does not identify you, such as time spent in the
    App and region where the App was downloaded.

This information includes:

  • Information that you provide by filling in forms in the App. This includes information
    provided at the time of registering to use the App, posting material, and requesting
  • further services. We may also ask you for information when you enter a contest or
    promotion sponsored by us, and when you report a problem with the App.
    Records and copies of your correspondence (including email addresses and phone
    numbers) if you contact us.
  •  Your search queries on the App.
  •  Details of transactions and orders you enter into through the App. You may be
    required to provide financial information before placing an order through the App.
  •  Your responses to surveys that we might ask you to complete for research purposes.
    You may provide information to be published or displayed on public areas you access through
    the App (collectively, “User Contributions”). Your User Contributions are published or
    displayed and transmitted to others at your own risk. Please be aware that no security measures
    are perfect or impenetrable. Additionally, we cannot control the actions of third parties with
    whom you may choose to share your User Contributions. Therefore, we cannot and do not
    guarantee that your User Contributions will not be viewed by unauthorized persons.

3.2 AUTOMATIC INFORMATION COLLECTION AND TRACKING

When you download, access, and use the App, it may use technology to automatically collect:

Usage Details. When you access and use the App, we may automatically collect certain
details of your access to and use of the App, including traffic data, location data, logs,
and other communication data and the resources that you access and use on or through
the App.
Device Information. We may collect information about your mobile device and Internet
connection, including the device’s unique device identifier, IP address, operating system,
browser type, mobile network information, and the device’s telephone number.
Stored Information and Files. The App also may access metadata and other information
associated with other files stored on your device. This may include, for example,
photographs, audio and video clips, personal contacts, and address book information.
Location Information. This App does not collect real-time information about the
location of your device.
If you do not want us to collect this information, do not download the App or delete it from your
device. Note, however, that opting out of the App’s collection of location information (if that
feature is available) will cause its location-based features to be disabled.

3.3 INFORMATION COLLECTION AND TRACKING TECHNOLOGIES

The technologies we use for automatic information collection may include:

Cookies (or mobile cookies). A cookie is a small file placed on your smartphone. It
may be possible to refuse to accept mobile cookies by activating the appropriate
setting on your smartphone. However, if you select this setting you may be unable to
access certain parts of our App.
Web Beacons. Pages of the App and our emails may contain small electronic files
known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs)
that permit the Company, for example, to count users who have visited those pages or
opened an email and for other related app statistics (for example, recording the
popularity of certain app content and verifying system and server integrity).

3.4 THIRD PARTY INFORMATION COLLECTION

When you use the App or its content, certain third parties may use automatic information
collection technologies to collect information about you or your device. These third parties may
include:

  • Analytics companies;
  •  Your mobile device manufacturer;
  • Your mobile service provider; and
  • Others.
    These third parties may use tracking technologies to collect information about you when you use
    this app. The information they collect may be associated with your personal information or they
    may collect information, including personal information, about your online activities over time
    and across different websites, apps, and other online services websites]. They may use this
    information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you
have any questions about an advertisement or other targeted content, you should contact the
responsible provider directly.

3.5 HOW WE USE YOUR INFORMATION

We use information that we collect about you or that you provide to us, including any personal
information, to:

  • Provide you with the App and its contents, and any other information, products or
    services that you request from us.
  • Fulfill any other purpose for which you provide it.
  •  Give you notices about your account, including expiration and renewal notices.
  • Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • Notify you when App updates are available, and of changes to any products or services we offer or provide though it.

The usage information we collect helps us to improve our App and to deliver a better and more
personalized experience by enabling us to:

  • Estimate our audience size and usage patterns.
  • Store information about your preferences, allowing us to customize our App
    according to your individual interests.
  • Speed up your searches.
  • Recognize you when you use the App.

3.6 DISCLOSURE OF YOUR INFORMATION

We may disclose aggregated information about our users, and information that does not identify
any individual or device, without restriction.

In addition, we may disclose personal information that we collect or you provide:

  • To our subsidiaries and affiliates.
  • To contractors, service providers, and other third parties we use to support our
    business.
  •  To a buyer or other successor in the event of a merger, divestiture, restructuring,
    reorganization, dissolution, or other sale or transfer of some or all of the Company’s
    assets, whether as a going concern or as part of bankruptcy, liquidation, or similar
    proceeding, in which personal information held by the Company about our App users
    is among the assets transferred.
  • To fulfill the purpose for which you provide it.
  •  For any other purpose disclosed by us when you provide the information.
  • With your consent.
  • To comply with any court order, law, or legal process, including responding to any
    government or regulatory request.
  •  If we believe disclosure is necessary or appropriate to protect the rights, property, or
    safety of the Company, our customers or others. This includes exchanging

information with other companies and organizations for the purposes of fraud
protection and credit risk reduction.

3.7 YOUR CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

We strive to provide you with choices regarding the personal information you provide to us.

We do not control third parties’ collection or use of your information to serve interest-based
advertising. However these third parties may provide you with ways to choose not to have your
information collected or used in this way. You can opt out of receiving targeted ads from
members of the Network Advertising Initiative (“NAI”) on the NAI’s website.

3.8 ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION

You can review and change your personal information by logging into the App and visiting your
account profile page.

You may also send us an email at Shortiapp@gmail.com to request access to, correct, or delete
any personal information that you have provided to us. We cannot delete your personal
information except by also deleting your user account. We may not accommodate a request to
change information if we believe the change would violate any law or legal requirement or cause
the information to be incorrect.

If you delete your User Contributions from the App, copies of your User Contributions may
remain viewable in cached and archived pages, or might have been copied or stored by other
App users.

4. YOUR CALIFORNIA PRIVACY RIGHTS

California Civil Code Section 1798.83 permits users of our App that are California residents to
request certain information regarding our disclosure of personal information to third parties for
their direct marketing purposes. To make such a request, please send an email to
Shortiapp@gmail.com or write us at: Shorti, 229 North Greene Street, Greensboro, NC 27401.

5. DATA SECURITY

We have implemented measures designed to secure your personal information from accidental
loss and from unauthorized access, use, alteration, and disclosure. All information you provide to
us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted
using SSL technology.

The safety and security of your information also depends on you. Where we have given you (or
where you have chosen) a password for access to certain parts of our App, you are responsible
for keeping this password confidential. We ask you not to share your password with anyone. We
urge you to be careful about giving out information in public areas of the App like message
boards. The information you share in public areas may be viewed by any user of the App.

Unfortunately, the transmission of information via the Internet and mobile platforms is not
completely secure. Although we do our best to protect your personal information, we cannot
guarantee the security of your personal information transmitted through our App. Any
transmission of personal information is at your own risk. We are not responsible for
circumvention of any privacy settings or security measures we provide.

6. CHANGES TO OUR PRIVACY POLICY

We may update this Policy from time to time. If we make material changes to how we treat our
users’ personal information, we will post the new privacy policy on this page and notify you by
email at the email address specified in your account and an in-App alert the first time you use the
App after we make the change.

The date the privacy policy was last revised is identified at the top of the page. You are
responsible for ensuring we have an up-to-date active and deliverable email address for you and
for periodically visiting this privacy policy to check for any changes.

7. CONTACT INFORMATION

To ask questions or comment about this privacy policy and our privacy practices:

  • send us an email to Shortiapp@gmail.com; or
  • write us at Shorti, 229 North Greene Street, Greensboro, NC 27401.