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Privacy Policy

 

commoonal

Central to our mission is our commitment to be transparent about the data we collect about you, how it is used and with whom it is shared.

This Privacy Policy applies when you use our mobile application (the “App”), our web site www.commoonal.com, or any software provided on or in connection with commoonal services (collectively, the "Services" or “our Services). When you use our Services, you explicitly consent to the collection, storage, sharing, use, protection and disclosure of your information as described in this Privacy Policy, and your choices about the collection and use of your information.

By using our Services, you understand and agree that we are providing a platform for you to post content, including photos, comments and other materials ("User Content"), to our Services and to share User Content publicly. This means that other Users may search for, see, use, or share any of your User Content that you make publicly available through the Service, consistent with the terms and conditions of this Privacy Policy and our Terms and Conditions.

Our Policy applies to all visitors, users, and others who access the Service ("Users").

This Privacy Policy may be updated from time to time and therefore we ask you to check back periodically for the most updated form of Privacy Policy as indicated below. We will post any changes to this Policy on our Site and App.

 

1. Personal Information We Collect

1. Data Collected Directly from You

 

To use certain Services, you will need to register, either by providing us your email address or your social media account. We may also collect information including your name, mailing address, phone number, birthday, gender and photos as well as information about your preferences (such as your preferred method of communication). In case you choose to register using a social media account, you authorize us to access and use certain information depending on the privacy settings that you have selected in that social network. Examples of personal information that we compile and use include your basic account information (e.g. name, email address, gender, birthday, current city, profile picture, list of friends, etc.) and any other additional information or activities that you permit the third-party social network to share.

 

You can use our App and visit our Website without providing personal information. However, we may need to collect personal information in order to provide certain Services. If you refuse to provide your personal information when required, we may not be able to provide certain Services. If you submit any personal information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy. You may visit some areas of the Services as a guest, but you may not be able to access all the content and features of those areas without registering. 

 

We collect the content, communications and other information you provide when you use our Services, including when you sign up for an account, create or share content, and message or communicate with others. This can include information in or about the content you provide (like metadata), such as the location of a photo or the date a file was created. It can also include what you see through features we provide, such as our camera, so we can give you tips on using camera formats. This can also include communications between you and commoonal. For example, we may send you Service-related emails (e.g., account verification, changes/updates to features of the Service, technical and security notices). Note that you may not opt out of Service-related emails.

 

We may also receive your personal information from other sources, such as public databases, joint marketing partners, social media platforms (including from people with whom you are friends or otherwise connected) and from other third parties.

 

1.2 Service Use

We log usage data when you visit or otherwise use our Services, including our site, app and platform technology (e.g., our off-site plugins), such as when you view or click on content or ads (on or off our site and app), perform a search, install or update our mobile app. We use log-ins, device information, cookies and internet protocol (“IP”) addresses to identify you and log your use.

 

1.2.1 Log Data

We receive information when you view content on or otherwise interact with our Services, even if you have not created an account. When you use our Services, our servers automatically record certain log file information, including your web request, Internet Protocol ("IP") address, browser type, operating system, the referring web pages and URLs, pages visited, location, your mobile carrier, device information (including device and application IDs, device manufacturer and model, MAC address), search terms, cookie information, number of clicks, domain names, landing pages, and other such information. We also receive log data when you click on, view, or interact with links on our services. Log file information is automatically reported by your browser each time you make a request to access (i.e., visit) a web page or app. It can also be provided when the content of the webpage or app is downloaded to your browser or device. We may also collect similar information from emails sent to our Users which then help us track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of our Services. 

 

1.2.2 Device and Location Information

 

When you visit or leave our Services (including our plugins or cookies or similar technology on the sites of others), we receive the URL of both the site you came from and the one you go to next. We collect information from and about the devices you use that integrate with our Services, and we combine this information across different devices you use. Information we obtain from these devices includes: 

 

  • Device attributes: information such as the operating system, hardware and software versions, battery level, signal strength, available storage space, browser type, app and file names and types, and plugins.

  • Device operations: information about operations and behaviors performed on the device, such as whether a window is foregrounded or backgrounded, or mouse movements (which can help distinguish humans from bots).

  • Identifiers: unique identifiers, device IDs, and other identifiers, such as from games, apps or accounts you use. When you use a mobile device like a tablet or phone to access our Service, we may access, collect, monitor, store on your device, and/or remotely store one or more "device identifiers." Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device's operating system or other software, or data sent to the device by us. A device identifier may deliver information to us or to a third-party partner about how you browse and use our Services and may help us or others provide reports or personalized content and ads. Some features of the Service may not function properly if use or availability of device identifiers is impaired or disabled.

  • Device signals: Bluetooth signals, and information about nearby Wi-Fi access points, beacons, and cell towers. We may collect the physical location of your device to record and publish information on your position and to show you items offered by users close to you. We may collect this information by, for example, using satellite, cell phone tower or Wi-Fi signals. You may allow or deny such collection and publication of your device’s location, but it may affect your use of the Services (for example, by not allowing us to post your item in a determined geographic location).

  • Data from device settings: information you allow us to receive through device settings you turn on, such as access to your GPS location, camera or photos.

  • Network and connections: information such as the name of your mobile operator or ISP, language, time zone, mobile phone number, IP address, connection speed and, in some cases, information about other devices that are nearby or on your network.

  • Cookie data: data from cookies stored on your device, including cookie IDs and settings. 

 

1.2.3 Cookies 

 

A cookie is a small piece of data that is stored on your device. Like many websites and apps, we use cookies and similar technologies to collect additional usage data and to operate our services. We use Cookies to recognize you as a customer; customize our Services, other content and advertising; measure the effectiveness of promotions; perform a wide range of analytics; mitigate risk and prevent potential fraud; and to promote trust and safety across our Services. Although most web browsers automatically accept cookies, with some browsers you can set to decline cookies or alert you when a website or app is attempting to place a cookie on your device. Certain aspects and features of our Services are only available through the use of Cookies, so if you choose to disable or decline Cookies, your use of our Services may be limited or not possible.

 

When your browser or device allows it, we use both session cookies and persistent cookies to better understand how you interact with our services, to monitor aggregate usage patterns, and to personalize and otherwise operate our services such as by providing account security, personalizing the content we show you including ads, and remembering your language preferences. You can also opt-out from our use of cookies and similar technologies that track your behavior on the sites of others for third party advertising. 

 

 

1.3 Messages

 

We collect information about you when you send, receive, or engage with messages in connection with our Services. When you communicate with others by sending or receiving Messages, we will store and process your communications and information related to them. This includes link scanning for malicious content, URLs, detection of spam and prohibited images, and review of reported issues. We also use information about whom you have communicated with and when (but not the content of those communications) to better understand the use of our services and to protect the safety and integrity of our platform. We share the content of your Messages with the people you’ve sent them to; we do not use them to serve you ads. When you use features like Messages to communicate, remember that recipients have their own copy of your communications on commoonal - even if you delete your copy of those messages from your account - which they may duplicate, store, or re-share.




2. How We Use Your Information

We use the information we have (subject to choices you make) as described below and to provide, support and personalize our Services (including ads) so that they can be more relevant and useful to you and others.

2.1 Services

We use your data to authorize access to our Services, including to personalize features and content (including ads). You can also opt-in to allow us to use your precise location or proximity to others for certain events (e.g. to meet with other members of your community in order to exchange items). We also use your data to automatically update the commoonal app on your device.

2.2 Communications

We use the information we have to communicate with you about our Services, and let you know about our policies and terms. We also use your information to respond to you when you contact us. We will send you messages about the availability of our Services, security, or other service-related issues. We also send messages about how to use the Services, network updates, reminders and promotional messages from us and our partners. Please be aware that you can’t opt-out of receiving service messages from us, including security and legal notices. We also enable communications between you and others through our Services.

2.3 Advertising

Advertising revenue allows us to support and improve our services. We use the information described in this Privacy Policy to help make our advertising more relevant to you, to measure its effectiveness, and to help recognize your devices to serve you ads on and off of our Services. Some of our ad partners, particularly our advertisers, also enable us to collect similar information directly from their website or app by integrating our advertising technology.

commoonal adheres to the Digital Advertising Alliance Self-Regulatory Principles for Online Behavioral Advertising (also referred to as “interest-based advertising”) and participates in industry opt-outs from such ads. This does not opt you out of receiving advertising; you will continue to get other ads by advertisers not listed with these self-regulatory tools. You can also opt-out specifically from our use of certain categories of data to show you more relevant ads. In addition, our ads policies prohibit advertisers from targeting ads based on categories that we consider sensitive or are prohibited by law, such as race, religion, politics, sex life, or health.

2.4 Marketing

We use data and content about our Users for invitations and communications promoting user and network growth, and engagement on our Services.

2.5 Product Research and Development

We use data, including public feedback, to conduct research and development for the further development of our Services in order to provide you and others with a better, more intuitive and personalized experience, drive membership growth and engagement on our Services.

2.6 Customer Support

We use the data (which can include your communications) to investigate, respond to and resolve complaints and Service issues (e.g., bugs). 

2.7 Aggregate Insights

We use your data to produce and share aggregated insights that do not identify you. We may use your data to generate statistics about our Users, to calculate ad impressions served or clicked on, or to monitor metrics such as total number of visitors, traffic, and demographic patterns.

2.8 Safety, integrity and security

We use your data (including your communications) if we think it’s necessary for security purposes or to investigate suspicious activity, possible fraud or other violations of our Terms & Conditions or this Privacy Policy and/or attempts to harm our Users.

We use the information we have to verify accounts and activity, combat harmful conduct, detect and prevent spam and other bad experiences, maintain the integrity of our Services, and promote safety and security on and off of our Services. 

 

3. How We Share Information

3.1 Profile and User Content

Some data that you include on your profile and any content you post on our Services will be seen by others. 

Your profile is partially visible to all Users and customers of our Services (your initials and profile picture are visible to other Users). It can also be partially visible to others on or off of our Services (e.g. Visitors to our Services or users of third- party search engines). 

Any information or content that you voluntarily disclose for posting to our Services, such as User Content, becomes available to the public. Once you have shared User Content or made it public, that User Content may be re-shared by others. Also, any User Content that you make public is searchable by other Users and subject to use under the terms of this Privacy Policy.

If you remove information that you posted to the Service, copies may remain viewable in cached and archived pages of our Service, or if other Users or third parties using our API have copied or saved that information.

You, other Users and us as commoonal, can provide access to or send public information to anyone on or off our Services, including in search results, or through tools and APIs. Public information can also be seen, accessed, reshared or downloaded through third-party services such as search engines, APIs, and offline media such as TV, and by apps, websites and other services that integrate with our Services. 

 

3.2 Service Providers - Third Party

We work with third-party partners who help us provide and improve our Services (e.g., maintenance, analysis, audit, payments, fraud detection, marketing and development). They will have access to your information as reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes. For example, we share with advertisers the identifiers of devices that saw their ads, to enable them to measure the effectiveness of our advertising business. We also share device identifiers, along with the interests or other characteristics of a device or the person using it, to help partners decide whether to serve an ad to that device or to enable them to conduct marketing, brand analysis, interest-based advertising, or similar activities.

We provide these partners with reports about the kinds of people seeing their ads and how their ads are performing, but we don't share information that personally identifies you (information such as your name or email address that by itself can be used to contact you or identifies who you are) unless you give us permission. Some of these partnerships allow the information we share to be linked to other personal information if the partner gets your consent first.

 

For example, we may provide general demographic and interest information to advertisers to help them better understand their audience. We also confirm which commoonal ads led you take an action with an advertiser.

 

We may share your private personal data with such service providers subject to obligations consistent with this Privacy Policy and any other appropriate confidentiality and security measures, and on the condition that the third parties use your private personal data only on our behalf and pursuant to our instructions.

 

We may remove parts of data that can identify you and share anonymized data with other parties. We may also combine your information with other information in a way that it is no longer associated with you and share that aggregated information.

 

We don't sell any of your information to anyone, and we never will. We also impose strict restrictions on how our partners can use and disclose the data we provide. 



3.3 Responding to Legal Requests and Preventing Harm

It is possible that we will need to preserve, use or disclose information about you in response to a legal request (like a search warrant, court order or subpoena) if we have a good faith belief that the law requires us to do so or that disclosure is reasonably necessary. This may include the following:

 

  • investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies

  • detect, prevent and address fraud, security, or technical issues

  • enforce our agreements with you, including violations of our Terms of Use or this Policy

  • investigate and defend ourselves against any third-party claims or allegations

  • protect the security or integrity of our Service, including to help prevent spam, abuse or malicious actions

  • exercise or protect the rights and safety of our Service, our Users, personnel, or others

  • respond to legal requests from jurisdictions outside of the United States where we have a good faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards

 

However, nothing in this Privacy Policy is intended to limit any legal defenses or objections that you may have to a third party’s, including a government’s, request to disclose your personal data.

We attempt to notify Users about legal demands for their personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand. 

Information we receive about you may be accessed, processed and retained for an extended period of time when it is the subject of a legal request or obligation, governmental investigation, or investigations concerning possible violations of our terms or policies, or otherwise to prevent harm.



3.4 Change of Ownership and Closing your Account

In the event that we are involved in a sale, merger, reorganization, bankruptcy, dissolution, liquidation or change in control, or in preparation for any of these events, your information such as name and email address, User content and any other information collected through our Services may be among the items sold, shared or transferred. You will continue to own your User content. Any other entity which buys us or part of our business will have the right to continue to use your data, but only in the manner set out in this Privacy.  

Should you close your account with us, we may retain the information we have collected about you, including Personal Information, for internal purposes, including record keeping and business purposes, data reconstruction and backup, and compliance with applicable law.



4. Managing your Personal Information

4.1 Data Retention

We retain your personal data for as long as your account is open or as needed to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. This includes data you or others provided to us and data generated or inferred from your use of our Services.

 

4.2 Rights to Access and Control Your Personal Data

You can review and update your personal information in your account settings at any time by logging in to your account.

  • Delete Data: You can ask us to erase or delete all or some of your personal data (if it is no longer necessary to provide Services to you).

  • Rectify Data: You can edit some of your personal data through your account. You can also ask us to change, update or fix your data in certain cases, particularly if it’s inaccurate.

  • Restrict or Limit Use of Data: You can ask us to stop using all or some of your personal data (if we have no legal right to keep using it) or to limit our use of it (if your personal data is inaccurate or unlawfully held).

 

You can exercise your rights to any of the above actions at any time by sending a written request to the following email address: privacy@commoonal.com. In order to properly attend your request, please make clear what personal information you are writing about. For your protection, we may only respond to requests for the personal information associated with the email address you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as we can, but we may need to retain certain information for our recordkeeping purposes and there may also be residual information that will remain within our databases and other records, which will not be removed.

 

4.3 Account Deletion

If you choose to close your account, your personal data will generally stop being visible to others on our Services within 24 hours. We generally delete closed account information within 30 days of account closure, except as noted below.

We retain your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, or fulfill your request to “unsubscribe” from further messages from us. We will retain de-personalized information after your account has been closed.

Information you have shared with others will remain visible after you closed your account or deleted the information from your own profile or mailbox, and we do not control data that other Users copied out of our Services. Your profile may continue to be displayed in the services of others (e.g., search engine results) until they refresh their cache.

 

Keep in mind that search engines and other third parties may still retain copies of your public information, like your profile information and User content, even after you have deleted the information from our services or deactivated your account. 

5. How We Protect and Store Personal Information

5.1 Security

We store and process your personal information using third party servers located in data centers inside of the United States. This information is protected by physical, electronic and procedural safeguards in compliance with applicable US federal and state regulations. We also use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our office and files, and we authorize access to personal information only for those employees who require it to fulfill their job responsibilities.

We strive to ensure security on our systems. However, no website or Internet data transfer is completely secure. Despite our efforts, we cannot guarantee that personal information may not be accessed, disclosed, altered or destroyed by breach of our administrative, managerial and technical safeguards. Therefore, we urge you to take adequate precautions to protect your personal data as well, including never sharing your password with anyone. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

If we learn of a systems security breach, we may attempt to notify you electronically so that you can take appropriate protective steps. By using our Services, you agree that commoonal may communicate with you electronically. We may post a notice on the website or mobile application if a security breach occurs. We may also send an email to you at the email address you have provided to us. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice of a security breach), please email us at privacy@commoonal.com.

If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please notify us immediately.



5.2 Cross-Border Data Transfers

We and our affiliates and service providers may transfer, store and/or process information that we collect about you, including personal information, across borders and from your country or jurisdiction to other countries or jurisdictions around the world, and rely on legally-provided mechanisms to lawfully transfer data across borders. These countries may have data protection rules that are different from those of your country. By registering for and using our Services you consent to such transferring, storing and/or processing of personal information, and the use and disclosure of information about you as described in this Privacy Policy.

 

5.3 Public information

Please note that any information you post on the Services will become public and may be available to other users and the general public. We urge you to be very careful when deciding what information to disclose through the Services. You should also consider that your user name and your profile picture will be made available to the public when you participate in some Services, such as posting items, so you should exercise discretion when using our Services. Personal information posted by you or disclosed by you to other users may be collected by other users of such Services and may result in unsolicited messages. We are not responsible for protecting such information that you may disclose to third parties through our Services (e.g. sending your telephone number to another user through the Services).



6. Children’s Privacy

We do not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons to register for the Service. The Service and its content are not directed at children under the age of 13. In the event that we learn that we have collected personal information from a child under age 13 without parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us. Furthermore, you must be at least 18 years of age to use our Services. 

 

7. Changes to our Privacy Policy

It may be necessary for us to modify or update this Privacy Policy from time to time, for example to reflect updates to our Services or where required by law. We will notify you before we make changes to this Privacy Policy and gișve you the opportunity to review the revised Privacy Policy before continuing to use our Services. The most current version of the policy will govern our processing of your personal data. All changes to the Policy will be effective when posted, and your continued use of our Services after the posting will constitute your acceptance of, and agreement to be bound by, those changes. 

 

 

8. Contact Us

If you have any questions or comments regarding this Privacy Policy, please contact us by email at privacy@commoonal.com. Please do not send sensitive information to us by email, since email communications are not always secure.