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Scope

This Privacy Policy applies to personal information we collect when you install, download, subscribe to, access, use the features and/or interact with the content of the Roposo platform, and other online or offline related consumer offerings. To make this Privacy Policy easier to read, the Roposo platform, its updates, enhancements and/or features, and other related offerings are referred to collectively as the “Services” or “Roposo Platform”. This Privacy Policy does not cover data that other companies, creators, or influencers may collect directly from you.

PERSONAL INFORMATION WE COLLECT

The categories of personal information we collect depend on how you interact with us, our Services, and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below. Please note that you may interact with our customers, partners, advertisers, and media partners directly, and their respective privacy policies govern their collection and use of your data.

Information You Provide to Us Directly
- Account Creation. If you create an account on a Roposo app, we collect your name, email address, age-range, and gender when you register an account. If you use a third-party application to login to your Roposo account, we collect that third-party’s authorization token.
- Account Profile. If you create an account, we collect the information you provide when you build your account profile, including an avatar or profile photo, social media links, Roposo account handle, details related to who do you follow and who follows you, and the information you provide about yourself to display in the “About Me” section.
- Content You Provide and View. Roposo allows you to create, share and stream short videos. We collect and store any videos or other content you create in the Services. If you comment on other users’ content, we collect any information you provide in the comments. We keep a record of the content you view on Roposo, including videos you watch and live streams you join.
- Payments. Any payments made via our Services are processed by third-party payment processors. We do not directly collect or store any payment card information entered through our Services, but we may receive information associated with your payment card information (e.g., your billing details).
- Virtual points or tokens transactions. Roposo may provide you with a feature that allows you to buy and use virtual points or tokens via our Service. You may also be able to distribute your points or token to the creators. If you decide to participate in such virtual points or token related transactions, you may be asked to provide certain information, which may include personal information. Any payments made via our Services are processed by third-party payment processors.
- Your Communications with Us. When you contact us, we collect the contact information you provide, such as your email address, phone number, or mailing address.
- 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.
- Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.
- Contests. We may collect personal information you provide for any contests that we offer.
- Reward Payment. We may collect personal information and details associated with your reward disbursement, including payment information. Any payments made via our Services are processed by third-party payment processors. We do not directly collect or store any payment card information entered through our Services. We may receive transaction related information associated with your payment from our payment processors for the purposes of addressing questions you may have concerning transactions.
Information Collected Automatically
- Automatic Data Collection. We may collect certain information automatically when you use our Services, such as your device identifier, Internet protocol (IP) address, mobile advertising identifier (e.g., Google Advertising ID “GAID”, IDFA), push tokens, browser user-agent, device information (including device type, screen size, operating system, language setting and time zone)), and Network provider when utilizing our Service. We may also automatically collect information regarding your use of our Services, such as links you click, the types of content you interact with, including video streams you watch, content you follow or like, products you view, the frequency and duration of your activities, ads presented on your device, including, content type of the ad (the advertiser and category, e.g., games, finance, entertainment, news); ad type (e.g., whether the ad is a text, image, video or other format based); where the ad is being served (e.g., the site, digital media or app on which the ad appears); whether you viewed, clicked or otherwise interacted with the ad, and other information about how you use our Services.
- Crash Reports. If you send them, we may also receive crash reports with more detailed diagnostic information about your device and the activities that led to the crash.
- Location Information. We may use your IP address to approximate your location in order to provide the Services. We infer your last location based on your IP address.
- Analytics. We may use technologies and other third-party tools to process analytics information on our Services. These technologies allow us to process usage data to better understand how our Services are used, and to continually improve and personalize our Services.
- Social Media and Communications Platforms. Our Services may also contain social media buttons such as Facebook, Twitter, LinkedIn, which might include widgets such as “share this” button or other interactive mini programs that allow you to share content on third-party platforms. These platforms may collect your IP address and which page you are visiting on our Services and may set a cookie to enable the feature to function properly. Your interactions with these platforms are governed by the privacy policy of the company providing it.
- Tracking Technologies. The technologies we as well as third parties that provide content, advertising, or other functionality on our Services, may use technologies such as pixel tags and other tracking tools (“Technologies”) for automatic information collection through your use of our Services. The use of such Technologies may be subject to your consent in accordance with the applicable law.
  - Web Beacons/ Pixel Tags. Pages of the Roposo Platform may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) embedded in our Services that collects information about engagement on our Services. The use of a pixel tag permits Roposo, for example, to count users who have visited those pages, clicked on a particular advertisement, or for other related statistics (for example, recording the popularity of certain application content and verifying system and server integrity).
  - Our uses of these Technologies fall into the following general categories:
    - Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity, improve security, or allow you to make use of our functionality.
    - 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 individuals use our Services (see Analytics below). For example, we may track your in-Roposo Platform activity, and other interactions with the platform.
    - Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed.
    - Advertising- or Targeting-Related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third-party websites.
Information Collected from Other Sources
- Third Party Account Login. If you create a Roposo account by using a third-party service account, such as a social networking service, we collect that service’s authorization token from you and information about you such as your name and email address from that third-party application that you have made available via your privacy settings.
- Ads Displayed on Roposo Platform. In the context of advertising displayed on Roposo Platform, our customers, partners, or vendors (“Ad-Third Parties”) may disclose to us certain personal or non-personal information they have separately collected about you so that we can effectively provide our services. Roposo Platform may facilitate promotion of certain products or services.

HOW WE USE YOUR INFORMATION

We use your information for a variety of business purposes, including to provide our Services, assist with order fulfillment, for administrative purposes, and to market our products and Services, as described below.

Provide Our Services
Administrative Purposes
Marketing and Advertising our Products and Service
With your Consent
We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.
Other Purposes
- Automated Decision Making. We may engage in automated decision making, including profiling. Roposo processing of your personal information will not result in a decision based solely on automated processing that significantly affects you unless such a decision is necessary as part of a contract we have with you, we have your consent, or we are permitted by law to engage in such automated decision making. If you have questions about our automated decision making, you may contact us as set forth in “Contact Us” below.
- De-identified and Aggregated Information. We may use personal information and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, information about the device from which you access our Services, or other analyses we create. If we create or receive personal data that has been de-identified or aggregated, we will not attempt to reidentify it, except to comply with applicable law.

HOW WE DISCLOSE YOUR INFORMATION

We disclose your information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.

Disclosures to Provide our Services
- Service Providers. We may share your personal information with our third-party service providers who use that information to help us provide our Services. This includes without limitation service providers that provide us with IT support, data analysis, hosting, fraud detection, payment processing, customer service, and related services. For avoidance of any doubt, Roposo does not provide any payment related services.
- Business Partners and Content Creators. We may share your personal information with business partners and content creators to provide you with a product or service you have requested. We may also share your personal information with business partners with whom we jointly offer products or services. If you elect to make a purchase from a third-party seller on the Roposo platform, the providers of such products or services (e-commerce partners or other advertiser partners) may ask you to provide information such as your name, email, phone number, shipping address, and may further engage other payment partners for processing such transactions. Those transactions are governed by the e-commerce partners or advertiser partners’ respective privacy policies.
- Group. We may share your personal information with Glance Group’s affiliates for our administrative and business purposes, including activities such as IT management, for them to provide services to you or support and supplement the Services we provide. A full list of the Glance Group affiliates can be found here.
- Other Users/Website Visitors. As described above in “Personal Information We Collect,” our Services allow you to share your profile and/or User Content with other Users/publicly, including to those who do not use our Services.
- Advertising Partners. When you use the Roposo Platform or its content, certain third parties may use Technologies to collect information about your activities or your device. These third parties may include the Group (in their capacity as advertising partners), advertisers, ad networks, e-commerce partners, reward partners or payment facilitators, ad servers, attribution partners and analytics companies, your device manufacturer and/or your mobile service provider. The information they collect may be your personal information, including information about your online activities over time and across different websites, apps, IP address, and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content when you visit digital properties within their networks. Please note that your interactions with these platforms are governed by the respective privacy policy of the company providing it and we do not control these third parties’ Technologies.
- APIs/SDKs. We may use third-party Application Program Interfaces (“APIs”) and Software Development Kits (“SDKs”) as part of the functionality of our Services. For more information about our use of APIs and SDKs, please contact us as set forth in “Contact Us” below.
Disclosures to Protect Us or Others
We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.
Disclosure in the Event of 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, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

YOUR PRIVACY CHOICES AND RIGHTS

Your Privacy Choices. The privacy choices you may have about your personal information are determined by applicable law and are described below.

Email 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 our Services or updates to our Terms or this Privacy Policy).
Mobile Devices. We may send you push notifications through our mobile application. You may opt out from receiving these push notifications by changing the settings on your mobile device. With your consent, we may also collect precise location-based information via our mobile application. You may opt out of this collection by changing the settings on your mobile device.
Technologies and Interest-Based Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. Please note that you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, and others.

The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada

Please note you must separately opt out in each application and on each device.

Opt-out of all information collection. You may also stop all collection of information by the Roposo Application by uninstalling the Application.

Your Privacy Rights. In accordance with applicable law, you may have the right to:

Access Personal Information about you, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information in a structured, commonly used, and machine readable format; and (iii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company in a structured, commonly used, and machine readable format (the “right of data portability”);
Request Correction of your personal information where it is inaccurate, incomplete, or outdated. In some cases, we may provide self-service tools that enable you to update your personal information;
Request Deletion, Anonymization or Blocking of your personal information when processing is based on your consent or when processing is unnecessary, excessive or noncompliant;
Request Restriction of or Object to our processing of your personal information;
Withdraw your Consent to our processing of your personal information. Please note that your withdrawal will only take effect for future processing and will not affect the lawfulness of processing before the withdrawal. If you refrain from providing personal information or withdraw your consent to processing, some features of our Service may not be available;
Be informed about third parties with which our application has shared your personal information that was collected by our application; and
Request the review of decisions taken exclusively based on automated processing if these decisions could affect your data subject rights.

If you would like to exercise any of these rights, please click here to raise request with us. We will process such requests in accordance with applicable laws. We do not track users with cross-device identifiers, please keep in mind that every time you change your device, reset your identifier, or reinstall the app please submit a new request. You may also reach out to us as set forth in “Contact Us” section.

SECURITY OF YOUR INFORMATION

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, no system is 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 unauthorized disclosure.

INTERNATIONAL DATA TRANSFERS

All information processed by us may be transferred, processed, and stored anywhere in the world as described in this policy, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.

RETENTION OF PERSONAL INFORMATION

We store the personal information we collect 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.

SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS

This Supplemental Notice for California Residents only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information we have collected about them, and whether we disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months. California residents can find this information below:

Category of Personal Information Collected by Roposo	Category of Third Parties Information is Disclosed to for a Business Purpose
Identifiers. A real name, alias, unique personal identifier, online identifier, Internet Protocol address, device identifier, device meta details, email address, account name, age range, gender, social media profile links, or other similar identifiers.	Advertising networks, including affiliates Service providers Other Users/Public (User Content)
Commercial information. Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Advertising networks, including affiliates Service providers
Internet or other electronic network activity Browsing history, search history, information on a consumer's interaction with an internet website, application, or advertisement.	Advertising networks, including affiliates Service providers
Sensory data Audio, electronic, visual, or similar information.	Service providers
Inferences drawn from other personal information to create a profile about a consumer Profile reflecting a consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	Service providers

The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth in “Personal Information We Collect” and “How We Use Your Personal Information” above, respectively.

“Sharing” of Personal Information under the CCPA

California residents have the right to opt out of the “sale” or “sharing” of their personal information. Under the CCPA, “sale” is includes the transfer of personal information by a business to a third party for valuable consideration. “Sharing” means transferring personal information for cross-contextual behavioural advertising, whether or not for monetary or other valuable consideration.

We do not “sell” your personal information. We may “share” the following categories of personal information with advertising networks and partners:

Category of Personal Information Shared by Roposo

Identifiers

A real name, alias, unique personal identifier, online identifier, Internet Protocol address, device identifier, device meta details, email address, account name, age range, gender, social media profile links, or other similar identifiers.

Internet or other electronic network activity

Browsing history, search history, information on a consumer's interaction with an internet website, application, or advertisement.

Sensory data

Audio, electronic, visual, or similar information.

Inferences drawn from other personal information to create a profile about a consumer

Profile reflecting a consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Our business and commercial purposes for “sharing” personal information can be found in “How We Use Your Information” above.

Opt-out of “Sharing”” California residents may opt-out of the “sale” or “sharing” of their personal information by accessing the option available in your application’s privacy setting/contacting us as set forth in “Contact Us” below.

Additional Privacy Rights for California Residents:

Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.

Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, please contact us as set forth in “Contact Us” below and provide written authorization signed by you and your designated agent.

Verification. To protect your privacy, we will take the following steps to verify your identity before fulfilling your request. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include, but not limited to, asking you to answer questions regarding your account, device information and/or use of our Services.

If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.

California Shine the Light. The California “Shine the Light” law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties.

SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Information to third parties who intend to license or sell that Personal Information. You can exercise this right by contacting us as set forth below with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Information as sales are defined in Nevada Revised Statutes Chapter 603A. If you have any questions, please contact us as set forth below.

CHILDREN’S INFORMATION

Protecting children’s privacy online is very important to us. Although our Services are designed for a general audience, for any Services that may appeal to children we limit personal information collection and sharing to only what is necessary to support the internal operations of our Services If you are a parent or guardian and believe your child has provided personal information to us without your consent, you may contact us as described in “Contact Us” below. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account, if applicable.

OTHER PROVISIONS

Third-Party Websites/Applications. The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services 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. Providing personal information to third-party websites or applications is at your own risk.

Supervisory Authority. If you are located in the European Economic Area, Switzerland, the United Kingdom, Columbia, Ecuador or Brazil, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.

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 our Services after the new Privacy Policy takes effect.

CONTACT US

If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at [email protected].