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Privacy Policy

Voxer, Inc. Privacy Policy

Effective Date of Current Policy: 06/07/2018

1. PURPOSE

This Privacy Policy is incorporated by reference into the Voxer Terms of Service (the “Terms”). The terms “Voxer,” “we,” “us”, and “our” include Voxer, Inc. (and any entity controlling, controlled by or under common control with Voxer). This Privacy Policy explains our online and offline information practices, the kinds of information we may collect, how we intend to use and share that information, and how you can opt out of a use or correct or change such information. All other terms not defined in Section 13 or otherwise herein will have the meanings set forth in the Terms.

2. SCOPE

Voxer is a messaging service that permits authorized users to send voice, text, video and image messages to other users or groups of users via a supported smartphone or other supported devices using the Voxer Walkie Talkie App. This Privacy Policy applies to Personal Information that is Processed by Voxer in the course of our business, including on the Voxer website (voxer.com) and other websites owned by Voxer (each a “Site”); the Voxer Walkie Talkie App, Voxer Pro App, and other mobile applications (each an “App”); forums, blogs, and other online or offline offerings. To make this Privacy Policy easier to read, we will refer to all current or future Sites, Apps or other online or offline offerings operated by or on behalf of Voxer, as the “Products”.

All individuals responsible for Processing Personal Information on behalf of Voxer are expected to adhere to this Privacy Policy. This Policy applies to all of Voxer’s operating divisions, subsidiaries, affiliates, and branches, and any additional subsidiary, affiliate, or branch of Voxer that we may subsequently form.

3. TRANSPARENCY/NOTICE-TYPES OF PERSONAL INFORMATION WE COLLECT AND HOW WE USE IT

The types of Personal Information we may collect (directly from you or from Third-Party sources) and our privacy practices depend on the nature of the relationship you have with Voxer and the requirements of applicable law. Some of the ways that Voxer may collect Personal Information include:

You may provide Personal Information directly to Voxer through interacting with the Products, participating in surveys, during events such as sweepstakes, and requesting Products, or information.
As you navigate the Products, certain passive information may also be collected about your visit, including through cookies and similar technologies as described below.

We endeavor to collect only that information which is relevant for the purposes of Processing. Below are the ways we collect Personal Information and how we use it.

3.1 TYPES OF PERSONAL INFORMATION WE COLLECT
Voxer collects Personal Information regarding its current, prospective, and former clients, customers, users, visitors, and guests (collectively “Individuals”).

Information You Provide Directly to Us. When you use the Products or engage in certain activities, such as creating an Account with Voxer, responding to surveys, requesting Products or information, or contacting us directly, we may ask you to provide some or all of the following types of information:

Communications with Us. We may collect Personal Information from you such as email address, phone number or mailing address when you choose to request information about our Products, request a Product demonstration, register for Voxer’s newsletter or a loyalty program that we may offer from time to time, request to receive customer or technical support, or otherwise communicate with us.
Registering Products. When you register with us and use the App, you generally provide us with Personal Information such as your name, email address, user name, password, phone number and other registration information. Registration with us is mandatory in order to be able to use the App. The App obtains the Personal Information you provide when you download and register for the App. If you choose to register on the Voxer Site, we will receive that registration data as well.
Communications with Third-Parties. The Products can be used to communicate with others. When you share information, including Personal Information, it will be seen by the recipients. Voice, text and images you create and transmit will be stored on your device, the device of recipients of such communications, and on our servers.
Contacts Data. To provide you an opportunity to automatically connect with your contacts, we may, with your permission, access and store on our servers Personal Information regarding your contacts, including their names, email addresses, phone numbers, profile image, geographic location and Facebook IDs. In addition, when you invite contacts to use our Products, we will access your address book so you can facilitate the invitation. If you send invitations to your contacts, you represent that all such contacts have consented to receive SMS from you. To better match you with your most important contacts, with your permission, we may also access and store your call and SMS log information from your device.
Location Information. If you give the App permission to access Location data, the App will collect your GPS location at the time you send a message. A map indicating your location will be available to the recipients of the message. You can disable this feature by turning off the location function in the “Settings” menu of the App or on your phone.
Surveys. From time to time, we may contact you to participate in online surveys. If you do decide to participate, you may be asked to provide certain information which may include Personal Information. All information collected from your participation in our surveys is provided by you voluntarily. We may use such information to improve our Products, Sites and/or services and in any manner consistent with the policies provided herein.
Posting on the Site. Voxer may offer publicly accessible pages, blogs, private messages, or community forums. You should be aware that, when you disclose information about yourself in on Voxer’s pages, blogs, private messages, and community forums, the Site will collect the information you provide in such submissions, including any Personal Information. If you choose to submit content to any public area of the Site, such content will be considered “public” and will not be subject to the privacy protections set forth herein.
Registration for Sweepstakes or Contests. Occasionally, Voxer may run sweepstakes and contests. We ask those who enter in the sweepstakes or contests to provide contact information (e.g., an e-mail address). If you participate in a sweepstakes or contest, your contact information may be used to reach you about the sweepstakes or contest, and for other promotional, marketing and business purposes. All sweepstakes/contests entry forms will provide a way for participants to opt out of any communications that are not related to awarding prizes.
Automatic Data Collection. We may collect certain information automatically through our Apps or other Products, such as the type of mobile device you use, your mobile device’s device ID, your IP address, your mobile operating system, the type of mobile Internet browsers you use, crash information, information about the way you use the Apps or Products, cookie identifiers, mobile carrier, mobile advertising identifiers, MAC address, Advertiser ID, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type and language, geo-location information, hardware type, operating system, Internet service provider, pages that you visit before and after using the Products, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Products, and other actions taken through use of the Apps or the Products such as preferences.

Information Submitted to Us Via Products. You agree that Voxer is free to use the content of any communications submitted by you to us via the Products, including any ideas, inventions, concepts, techniques, or know-how disclosed therein, for any purpose including developing, manufacturing, and/or marketing goods or Products. Voxer will not release your name or otherwise publicize the fact that you submitted materials or other information to us unless: (a) you grant us permission to do so; (b) we first send notice to you that the materials or other information you submit to a particular part of a Service will be published or otherwise used with your name on it; or (c) we are required to do so by law.

Information from Other Users of the Apps and Products. We may collect Personal Information about you from other users of Voxer Products. For example, when a friend provides friend details or contact information, or indicates a relationship with you, Voxer may receive Personal Information such as your name, email address, phone number, profile image, geographic location and Facebook ID. We may use such Personal Information to determine if you use Voxer Products, and to help your contacts find you.

Information from Other Sources. We may receive information about you from other sources, including through Third-Party services and organizations to supplement information provided by you. For example, if you access our Products through a Third-Party application, such as an App Store or Social Networking Sites (“SNS”) such as Facebook, we may collect information about you from that Third-Party application that you have made public via your privacy settings. If you authorize the activity, Personal Information we collect through App Stores or SNS accounts may include your name, your SNS user identification number, your SNS user name, location, gender, birth date, email, profile picture, your contacts on the SNS, and their profile information and their SNS images. This supplemental information allows us to verify information that you have provided to Voxer, to facilitate messages between you and your contacts, and to enhance our ability to provide you with information about our business and Products. In addition, Third-Party service providers may provide Voxer with automatically collected data similar to the data collected automatically by Voxer, as described more fully above.

3.2 HOW VOXER USES YOUR INFORMATION
We acquire, hold, use, and Process Personal Information about Individuals for a variety of business purposes, including:

Sharing Content with Friends or Colleagues. Voxer’s Products may offer various tools and functionalities. For example, the Apps allow you to send voice messages, text messages and photos (“Communications Content”) to other users. In addition, our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Products. Email addresses that you may provide for a friend or colleague will be used to send your friend or colleague the content or link you request, but will not be collected or otherwise used by Voxer or any other Third Parties for any other purpose.

To Provide Products or Information Requested. Voxer may use information about you to fulfill requests for Products or information, including information about potential or future Products, including to:

Communicate with other Voxer users as directed by you through use of the Apps;
Facilitate connections between Voxer users and other Individuals in the user’s contacts data;
Generally manage Individual information and Accounts;
Respond to questions, comments, and other requests;
Provide access to certain areas, functionalities, and features of Voxer’s Products;
Contact you to answer requests for customer support or technical support;
Provide you with access to demonstrations of our Products at your request; or
Allow you to register for events.

Marketing Voxer Products. Voxer may use Personal Information to provide you with materials about offers and Products that may be of interest, including new content or Products. Voxer may provide you with these materials by phone, postal mail, facsimile, or email, as permitted by applicable law. Such uses include:

To tailor content, advertisements, and offers;
To notify you about offers, products, and services that may be of interest to you;
To provide Products to you and our sponsors;
For other purposes disclosed at the time that Individuals provide Personal Information; or
Otherwise with your consent.

You may contact us at any time to opt out of the use of your Personal Information for marketing purposes, as further described in Section 5 below.

Research and Development. Voxer may use Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing Products and services or develop new Products and services. From time to time, Voxer may perform research (online and offline) via surveys. We may engage Third-Party service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve Individuals by learning more about their needs and the quality of the Products and services we provide. The survey responses may be utilized to determine the effectiveness of our Products, various types of communications, advertising campaigns, and/or promotional activities. If an Individual participates in a survey, the information given will be used along with that of other study participants. We may share anonymous Individual and aggregate data for research and analysis purposes.

Direct Mail, Email and Outbound Telemarketing. Individuals who provide us with Personal Information, or whose Personal Information we obtain from Third Parties, may receive periodic emails, newsletters, mailings, or phone calls from us with information on Voxer’s or our business partners’ products and services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to the Individual by following the instructions in Section 5 below.

Products via Mobile Devices. From time to time, Voxer may provide Products that are specifically designed to be compatible and used on mobile devices. Voxer will collect certain information that your mobile device sends when you use such Products, like a device identifier, user settings, location information, mobile carrier, and the operating system of your device. Mobile versions of Voxer’s Products may require that users log in with an Account. In such cases, information about use of mobile versions of the Products may be associated with Accounts. In addition, Voxer may enable Individuals to download an application, widget, or other tool that can be used on mobile or other computing devices. Some of these tools may store information on mobile or other devices. These tools may transmit Personal Information to Voxer to enable Individuals to access Accounts and to enable Voxer to track use of these tools. Some of these tools may enable users to email reports and other information from the tool. Voxer may use personal or non-identifiable information transmitted to Voxer to enhance these tools, to develop new tools, for quality improvement and as otherwise described in this Privacy Policy or in other notices Voxer provides.

Anonymous and Aggregated Information Use. Voxer may use Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access Voxer’s Products, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Products. Anonymized or aggregated information is not Personal Information, and Voxer may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within Voxer and with Third Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.

Other Uses. Voxer may use Personal Information for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, 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, ANALYTICS INFORMATION, AND INTERNET-BASED ADVERTISING

We, as well as Third Parties that provide content, advertising, or other functionality on our Products, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Products. We use Technologies that are essentially small data files placed on your computer, tablet, mobile phone, or other devices (referred to collectively as a “device”) that allow us to record certain pieces of information whenever you visit or interact with our sites, services, applications, messaging, and tools, and to recognize you across devices.

Cookies. Cookies are small text files placed by a web server in visitors’ computer browsers to store their preferences and for other record-keeping purposes. Most browsers allow you to block and delete cookies. However, if you do that, the Site may not work properly.

Web Beacons. A (also known as a clear gif, pixel tag or web bug) is a tiny graphic with a unique identifier, similar in function to a cookie. A web beacon is on the Site and 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 or clicked on a particular advertisement.

Analytics.

Google. We may use Google Analytics, Google Analytics Demographics and Interest Reporting, and Google Analytics for Firebase to collect information regarding all or some of our Products, and to develop website content. This analytics data is not tied to any Personal Information. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. For more information about Google Analytics for Firebase, please visit https://firebase.google.com/docs/analytics/. Users are bound by the Google Maps/Google Earth Additional Terms of Service (including Google Privacy Policy). You can opt out of Google’s collection and Processing of data generated by your use of the Products by going to https://tools.google.com/dlpage/gaoptout.
Mixpanel. We may use services by Mixpanel , Inc. to obtain analytics data regarding users’ interactions with our Site and Services. You may opt-out of Mixpanel’s automatic retention of data that is collected while using the Site or Services by visiting https://mixpanel.com/optout/. To track opt-outs, Mixpanel uses a persistent opt-out cookie placed on your device. Please note that if you get a new computer, install a new browser, erase or otherwise alter the browser’s cookie file (including upgrading certain browsers), you may delete the Mixpanel opt-out cookie.

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

Operationally Necessary. We may use cookies, web beacons, or other similar technologies that are necessary to the operation of our sites, services, applications, and tools. This includes technologies that allow you access to our sites, 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 shopping-carts, saved search, or similar functions;

Performance Related. We may use cookies, web beacons, or other similar technologies to assess the performance of our websites, applications, services, and tools, including as part of our analytic practices to help us understand how our visitors use our websites, determine if you have interacted with our messaging, determine whether you have viewed an item or link, or to improve our website content, applications, services, or tools;

Functionality Related. We may use cookies, web beacons, or other similar technologies that allow us to offer you enhanced functionality when accessing or using our sites, services, applications, or tools. This may include identifying you and distinguishing you from other users when you sign into our sites or keeping track of your specified preferences, interests, or past items viewed so that we may enhance the presentation of content on our sites;

Advertising or Targeting Related. We may use first-party or Third-Party cookies and web beacons to deliver content, including ads relevant to your interests, on our sites or on Third-Party sites. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.

If you would like to opt out of the Technologies we employ on our sites, services, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits.

3.4 THIRD-PARTY WEBSITES AND SOCIAL MEDIA PLATFORMS

The Products may enable access to Third-Party (other than Voxer Affiliates) services/technologies/websites (collectively “Third Party Sites”) (including via links available through the Products or Voxer Site) and this Privacy Policy does not apply to any data that may be collected or used by such Third Parties. You should always review the policies of Third-Party Apps and websites to make sure you are comfortable with the ways in which they use information you share with them. We have no control over Third-Party Apps and we are not responsible for the privacy practices of Third Party Sites, and we encourage you to read their privacy policies. Visiting these other websites or applications is at your own risk.

3.5 THIRD-PARTY PAYMENT PROCESSING

We may sell subscription services through our Products. When you make purchases through the Products, we process your payments through a Third-Party application, including the Apple App Store, Google Play App Store, Amazon App Store (together with any similar applications, “App Stores”), Stripe, Inc., Recurly, Inc. and SNS such as Facebook. The Third-Party application may collect certain financial information from you to process a payment on behalf of Voxer, including your name, email address, address and other billing information.

4. ONWARD TRANSFER-VOXER MAY DISCLORE YOUR INFORMATION

4.1 INFORMATION WE SHARE

We may share your information as described in this Privacy Policy (e.g., with our Third-Party service providers; to comply with legal obligations; to protect and defend our rights and property) or with your permission. We will share your information with Third Parties only in the ways that are described in this Privacy Policy.

We Use Vendors and Service Providers. We may share any information we receive with vendors and service providers. The types of service providers 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) payment processing; (iv) customer service activities; and (v) in connection with the provision of the Site, the Apps, or other Products. Voxer’s service providers work on our behalf and have agreed to adhere to the rules set forth in this Privacy Policy.

Helping You to Add Contacts and Helping Your Contacts to Find You. Voxer is designed to make it easy for you to find and connect and communicate with others. For this reason, your name and profile picture may be publicly shared and other users of the Products will be able to see your name and profile picture once you register directly or through a Third-Party. Other users may also provide us contact information they have about you, such as your email address, phone number or your name, which we use to determine if you use Voxer Products. If you are already use Voxer Products, then we may share your name with others so that they can add you to their contact list by choosing your name off of a list of users available via our Products. If you enable “Privacy Mode” in the App, you will no longer be searchable by other users and your information will not be shared in this way.

Inviting Contacts. We give you an opportunity to invite your contacts to register at the Voxer Site and download the Apps and Products, and in connection with that activity you may provide us access to Third-Party contact information. When you click to invite one or more friends to join Voxer or a Service, an SMS invite is sent from you from your phone. This SMS invite may result in your phone number being shared with the invitee and in charges to you and/or your invitee.

Communicating with Other Users. The Products can be used to communicate with others. Voice messages, text messages and photos (“Communications Content”) you send to other users may be seen by the recipients. Communications Content you create and transmit will be stored on your device, recipients’ device, and on our servers. Even if you remove this content from your device or account, copies of this User Communications Content will remain viewable on the devices of Third-Party users with whom you have communicated and will be stored on our servers for a period of time.

Displaying to Other Users. The content you post to the Site may be displayed on the Site. Other users of the Site may be able to see some information about you, such as your name if you submit a review. We are not responsible for privacy practices of the other users who will view and use the posted information.

Marketing – Interest-Based Advertising and Third Party Marketing. We use Third-Party service providers to serve advertisements (banners or links) on our behalf across the Internet. These service providers collect information about your visits to our website. This information is collected through use of a web beacon, which is industry standard technology used by most major websites. Web beacons do not collect names or contact information, but may record other information about your visit (e.g., your IP address, page(s) visited, time of day). We may also share such de-identified information as well as selected Personal Information (such as demographic information and past purchase history) we have collected with Third-Party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit non-Voxer related websites within their networks. In addition to the information about your visits to our website, our service providers may also use information about your visits to other websites to target advertisements from Voxer. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising. We may allow access to other data collected by the Site to facilitate transmittal of information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer that we do not share your Personal Information with Third-Party advertising partners, you may opt out of such sharing at no cost by following the instructions in Section 5 below.

Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures). 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) as required by law, such as to comply with a subpoena, or similar legal process; (ii) respond to your requests; (iii) protect yours’, ours’ or others’ rights, property, or safety; (iv) to enforce Voxer policies or contracts; (v) to collect amounts owed to Voxer; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm, fraud 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, sale of company 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. In such event, Voxer will endeavor to direct the transferee to use Personal Information in a manner that is consistent with the Privacy Policy in effect at the time such Personal Information was collected.

4.2 INTERNATIONAL DATA TRANSFERS

You agree that all Personal Information collected via or by Voxer may be transferred, Processed, and stored anywhere in the world, including but not limited to, the United States, the European Union, 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. By providing information to Voxer, you explicitly consent to the storage of your Personal Information in these locations.

5. OPT-OUT (RIGHT TO OBJECT TO PROCESSING)

5.1 GENERAL

You have the right to object to and opt out of certain uses and disclosures of your Personal Information. Where you have consented to Voxer’s Processing of your Personal Information or Sensitive Personal Information, you may withdraw that consent at any time and opt out of further Processing by contacting us at: privacy@voxer.com. Even if you opt out, we may still collect and use non-Personal Information regarding your activities on our Sites and/or information from the advertisements on Third-Party websites for non-interest based advertising purposes, such as to determine the effectiveness of the advertisements.

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. We will process your request within a reasonable time after receipt. 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 Voxer and our Products and you will not be able to opt out of those communications (e.g., communications regarding updates to our Terms or this Privacy Policy).

We would honor “do-not-call” and “do-not-mail” requests should you request it.

5.3 MOBILE DEVICES

Voxer may occasionally send you push notifications through our mobile applications with notices that may be of interest to you. You may at any time opt out from receiving these types of communications by changing the settings on your mobile device. Voxer 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. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. The Voxer Site does not collect Personal Information regarding users’ online activities over time and across Third-Party websites. As such, browser DNT signals are not relevant to the Site and Products.

5.5 COOKIES AND INTERNET-BASED ADVERTISING

As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings.

The online advertising industry also provides websites from which you may opt out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, or https://www.youronlinechoices.eu/ and www.aboutads.info/choices/. You can also choose not to be included in Google Analytics here.

To be clear, whether you are using our opt-out or an online industry opt-out, these cookie-based opt-outs must be performed on each device and browser that you wish to have opted-out. For example, if you have opted-out on your computer browser, that opt-out will not be effective on your mobile device. You must separately opt out on each device. Advertisements on Third-Party websites that contain the AdChoices link and that link to this Privacy Policy may have been directed to you based on anonymous, non-Personal Information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt out of the advertising partners’ use of this information for interest-based advertising purposes.

6. RIGHTS OF ACCESS, RECTIFICATION, ERASURE, AND RESTRICTION

You may inquire as to whether Voxer is Processing Personal Information about you, request access to Personal Information, and ask that we correct, amend or delete your Personal Information where it is inaccurate. Where otherwise permitted by applicable law, you may contact us at: privacy@voxer.com or use any of the methods set out in this Privacy Policy to request access to, receive (port), seek rectification, or request erasure of Personal Information held about you by Voxer. Please include your full name, email address associated with your Account, and a detailed description of your data request. Such requests will be processed in line with local laws. You can also view your profile in the Products and correct any inaccurate data that appears in your Profile.

Although Voxer makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which Voxer is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If Voxer determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, Voxer will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.

Through the Products, you can also close your account by using the “Deactivate Account” function. If you do so, you will no longer have access to the App. Voxer may retain your personal information even after you have closed your account if retention is reasonably necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes between users, prevent fraud and abuse, or enforce this Privacy Policy and our Terms of Service. We may retain personal information, for a limited period of time, if requested by law enforcement. Voxer’s Customer Service may retain information for as long as is necessary to provide support to users. We will delete your contacts data from our servers. Communications Content that you have sent via the Products will be deleted from your device, but will remain accessible to the recipients of those messages and will not be deleted from their devices or our servers.

7. DATA RETENTION

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

8. SECURITY OF YOUR INFORMATION

Voxer takes reasonable steps to protect personally identifiable information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. We keep your account information and content on a secure server behind a firewall. When you enter sensitive information (such as passwords), we encrypt that information using secure socket layer technology (SSL) while it is being transmitted. However, you should keep in mind that no Internet transmission is ever completely secure or error-free. In particular, messages sent to or from the Voxer Site and Products may not be secure. We do not accept liability for unintentional disclosure.
By using the Site 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 Site. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Site or sending an e-mail to you. You may have a legal right to receive this notice in writing.

9. INTERNATIONAL USERS

By using the Site and/or the Products, Voxer will transfer data to the United States and other locations as Voxer may add from time to time as indicated in this Privacy Policy. By choosing to visit the Site, utilize the Products or otherwise provide information to us, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the laws of State of California without regard to the conflicts of laws provisions therein, and the adjudication of any disputes arising in connection with Voxer or the Site will be in accordance with the Terms.

If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and to Processing of your data globally. By providing your Personal Information, you consent to any transfer and Processing in accordance with this Policy.

10. CHILDREN'S PRIVACY

Minors should not use the Products. The Products are not directed to children under 13 years of age (or other minimum age as required by local law), and Voxer does not knowingly collect Personal Information from children under 13. If you learn that your child has provided us with Personal Information without your consent, you may alert us at: privacy@voxer.com. If we learn that we have collected any Personal Information from children under 13, we will promptly take steps to delete such information and terminate the child’s Account.

11. REDRESS/COMPLIANCE AND ACCOUNTABILITY

If you have any questions about our privacy practices, this Privacy Policy, or how to lodge a complaint with the appropriate authority, please contact Voxer by email at privacy@voxer.com. We will address your concerns and attempt to resolve any privacy issues in a timely manner.

12. OTHER RIGHTS AND IMPORTANT INFORMATION

12.1 CHANGES TO OUR PRIVACY POLICY AND PRACTICES

This Privacy Policy may change from time to time. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you use the Products after the updated Privacy Policy is posted on the Products. If at any point you do not agree to any portion of the Privacy Policy then in effect, you must immediately stop using the Products.

Revision to the Privacy Policy. We may revise this Privacy Policy in our sole discretion, so review it periodically. If you continue to visit this Site and use the services made available to you after such changes have been made, you hereby provide your consent to the changes.

Posting of Revised Privacy Policy. If there are any material changes to this Privacy Policy, Voxer will notify you by email or as otherwise required by applicable law. We will post any adjustments to the Privacy Policy at https://voxer.com/legal/consumer/privacy/, and the revised version will be effective immediately when it is posted (or upon notice as applicable). If you are concerned about how your information is used, bookmark this page and read this Privacy Policy periodically.

New Uses of Personal Information. Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will endeavor to provide information regarding the new purpose and give you the opportunity to opt out. Where consent of the Individual for the Processing of Personal Information is otherwise required by law or contract, Voxer will endeavor to comply with the law or contract.

13. DEFINITIONS

The following capitalized terms shall have the meanings herein as set forth below.

“Agent” means any Third Party that Processes Personal Information pursuant to the instructions of, and solely for, Voxer or to which Voxer discloses Personal Information for use on its behalf.

“Personal Information” is any information relating to an identified or identifiable natural person (“Individual”).

“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.

“Sensitive Data” or “Sensitive Personal Information” is a subset of Personal Information which, due to its nature, has been classified by law or by policy as deserving additional privacy and security protections. Sensitive Personal Information includes Personal Information regarding EU residents that is classified as a “Special Category of Personal Data” under EU law, which consists of the following data elements: (1) race or ethnic origin; (2) political opinions; (3) religious or philosophical beliefs; (4) trade union membership; (5) genetic data; (6) biometric data where Processed to uniquely identify a person; (6) health information; (7) sexual orientation or information about the Individual’s sex life; or (8) information relating to the commission of a criminal offense.

“Third Party” is any company, natural or legal person, public authority, agency, or body other than the Individual, Voxer or Voxer’s Agents.

14. REVISION HISTORY

Title	Effective Date
Voxer Privacy Policy	Effective: 3/31/2015
Updated Voxer Privacy Policy	Effective: 06/07/2018