Privacy Policy (Previous Version)
Below is the previous version of Firework's Privacy Policy. The current version of Firework's Privacy Policy is available at: https://firework.com/legal/privacypolicy
We are Loop Now Technologies, Inc, trading as Firework, based at 2635 Broadway Street, Redwood City, CA 94063, United States of America. All references in this policy to "Firework", "Company", "our", "us" or "we" refer to Loop Now Technologies, Inc.
Our Privacy Policy explains how we collect, use, share and protect information in relation to our Service. Our Service refers to all mobile software applications that Loop Now Technologies, Inc. dba Firework services (the “Company”) makes available for download (each, an “App,” and together, the “Apps”) and the related website located at www.fw.tv and/or any other website(s) owned or controlled by or on behalf of the Company (collectively, “Sites”) as well as instances of all or portions of our service that are available on or via websites, applications or devices of third party publishers or distributors (such Apps, Sites and third party instances of our service are collectively referred to as the “Service”). This Privacy Policy also explains your choices about the collection and use of your information.
By using our Service you understand and agree that we are providing a platform for you to either view and/or post content, including photos, videos, comments and other materials ("User Content"), to the Service and/or 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 this Privacy Policy. It also means that, subject to your selection of privacy settings available within the App, we may make your User Content publicly available to third parties that are not owned nor operated by Firework, consistent with this Privacy Policy. By viewing User Content on our Service, you are also subject to the terms of this Privacy Policy. If you are based in the UK or EU, the Company is the controller of, and responsible for, your personal information.
Categories Of Information We Collect
Personal information and other information you provide us.
- Account Information, including your username, password and email address, such as when you register for a Firework account.
- Profile Information that you provide for your user profile, including identifiers such as your first and last name, age, gender, and phone number.
- Communications between you and Firework. For example, we may send you Service-related emails (e.g., account verification, changes/updates to features of the Service, technical and security notices), marketing, and other communications.
- Identifiers, which we automatically collect when you use the Service, including your IP address (not using GPS data), and internet or other electronic network activity information, such as your device information, or other unique device identifiers, cookies (as defined below), browsing records, mobile carrier, time zone setting and geolocation data, mobile or device model, operating system and platform as well as information regarding your use of the Service, e.g. the comments you make on our App or any other user-generated content and video content that you broadcast on our App.
- Business contact information where you are an employee, agent or officer of one of our business partners, publishers or suppliers (or prospective business partners, publishers or suppliers), contact information to be used in the course of our business such as your name, email address, phone number, address, job title, LinkedIn profile information.
Analytics information
We use third-party analytics tools to help us measure traffic and usage trends for the Service. These tools collect information sent by your device or our Service, including the web pages you visit, add-ons, and other information that assists us in improving the Service. We collect and use this analytics information with analytics information from other Users so that it cannot reasonably be used to identify any particular individual User.
We use third party analytics tool Google Analytics and Firebase provided by Google, Inc (1600 Amphitheatre Parkway Mountain View, CA 94043, USA). We also further use Facebook Analytics and "Facebook Pixel" of Facebook Inc. (1 Hacker Way, Menlo Park, CA 94025, USA) ("Facebook") and Amplitude Analytics (631 Howard Street, 5th floor, San Francisco, CA 94105).
Cookies
When you visit the Service, we may use cookies like pixels, web beacons, and local storage to collect information about how you use Firework and provide features to you.
Cookies are small files that are placed on your computer by websites that you visit or certain emails you open. They are widely used in order to make websites function properly, as well as to provide business and marketing information to the owners of the site and other third parties.
Firework may ask advertisers or other partners to serve ads or services to your devices, which may use cookies or similar technologies placed by us or the third party. We also may ask analytics providers to use cookies.
Several types of cookies are used for our Service:
- Essential Cookies: These cookies enable you to use our Service. These cookies are essential to enable you to browse our Service and use certain features. Disabling them may prevent you from using certain parts of the Service. These cookies also help keep our Service safe and secure.
- Preference Cookies: These cookies store information such as your preferred country and language selection, login data and website preferences. Without these cookies, our Service may not be able to remember certain choices you’ve previously made or personalize your browsing experience by providing you with relevant information. These cookies can also be used to recognize your device so that you do not have to provide the same information more than once.
- Performance Cookies: These cookies collect information about how you use our Service, such as which pages you visit regularly. These cookies are used to provide you with a high-quality experience by doing things such as tracking page load, response times, and error messages.
- Content/Advertising Cookies: These cookies gather information about your use of our Service so we may improve your experience and provide you with more relevant content and advertising. They are also used to gather feedback through surveys. They remember that you’ve visited our Services and help us understand usage of our Service.
You may refuse to accept cookies by altering the settings on your internet browser, or such other mechanisms that we provide via our Services. For further information about cookies, please see http://www.allaboutcookies.org
More Cookie And Log File Information
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 web page or app is downloaded to your browser or device.
When you use our Service, our servers automatically record certain log file information, including your web request, Internet Protocol ("IP") address, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed, and other such information. 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 the Service.
Do-Not-Track Signals and Similar Mechanisms: Some web browsers transmit “do-not-track” signals to websites. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. We currently do not take action in response to these signals.
Device identifiers
When you use a mobile device like a 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 Firework.
A device identifier may deliver information to us or to a third party partner about how you browse and use the Service and may help us or others provide reports or personalized content and ads. For more information about personalized or interest-based advertising, please see the “Sharing of Your Information” section below. Some features of the Service may not function properly if use or availability of device identifiers is impaired or disabled.
Metadata
Metadata is usually technical data that is associated with User Content. For example, Metadata can describe how, when and by whom a piece of User Content was collected and how that content is formatted.
Users can add or may have Metadata added to their User Content including a hashtag (e.g., to mark keywords when you send a photo), geotag (e.g., to mark your location to a photo), or other data. This makes your User Content more searchable by others and more interactive.
TrueDepth Camera
We use TrueDepth technologies with our camera SDK to provide real-time face filters within the App. From time to time, we may use information from Apple’s TrueDepth camera to improve the quality of lenses. None of the information collected by the TrueDepth ever leaves the user’s device. Information from TrueDepth camera is used in real time - this information is not stored in our servers or shared with third parties. For more information about TrueDepth technologies, you may visit https://support.apple.com/en-us/HT208108.
Purposes of Data Processing and How We Use Your Information
In addition to some of the specific uses of information we describe elsewhere in this Privacy Policy, we may use information that we receive to:
- help you efficiently access your information after you sign in to our Service
- remember information so you will not have to re-enter it during your visit or the next time you visit the Service
- communicate with you or third parties, or allow third parties to communicate with you provide, improve, test, and monitor the effectiveness of our Service
- develop and test new products and features
- monitor metrics such as total number of visitors, traffic, and demographic patterns
- in the case of business contact information, do business with partners, publishers and suppliers
- take the appropriate technical and organizational security measures in order to protect the Service or your personal information
- comply with legitimate requests or orders from competent public authorities and courts, including data protection authorities
- carry out internal corporate reporting, business administration, ensure adequate insurance coverage for our business, ensure the security of company facilities, research and development, and identify and implement business efficiencies (where it is in our legitimate interests to do so)
- establish, exercise or defend our legal rights – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others, as well as where we are legally required to do so
- diagnose or fix technology problems
- make User Content available to third parties that are non-owned and non-operated by Firework, subject to your opting out by notifying our Support Team at support@fireworkhq.com
- automatically update the Firework application on your device.
In cases where we make our Service available on or via websites, applications or devices of third party publishers or distributors, we may provide some or all of the following information to such third parties: number of videos viewed on their site or application, video preferences, and duration of video views.
Before using your personal information for any purposes which fall outside those set out in this Privacy Policy, we will undertake an analysis to establish if our new use of your personal information is compatible with the purposes set out in this Privacy Policy. Please contact us using the details towards the end of this Privacy Policy if you want further information on the analysis we will undertake.
Legal Basis for Processing Your Personal Information
Our legal basis for processing your personal information for the purposes described above includes processing that is: necessary for the performance of our contract with you (such as where necessary to provide you with our products or services); necessary for our legitimate interests (such as to carry out analytics in order to improve our Service, run, grow and develop our business and Service, select appropriately skilled and qualified suppliers, carry out marketing, market research and business development and for internal administrative purposes); and necessary to comply with our legal obligations (such as to respond to a subpoena or other legal process). In some cases (e.g., for the purposes of sharing information with third-party advertising partners), we may rely on your consent to process your information, which may subsequently be withdrawn at any time by contacting us at the details listed below. Withdrawing your consent does not affect the lawfulness of processing based on consent before it was withdrawn, and, where it is in compliance with applicable laws, we may have another valid legal basis to continue processing your information.
Sharing of Your Information
Whom we may share your information with:
- Our suppliers/service providers: We may share User Content and your information (including but not limited to, information from cookies, log files, device identifiers, location data, and usage data) with other entities, including entities that we do not own or operate. You may limit sharing through contacting Firework at privacy@fw.tv to opt out. Firework may use this information to help provide, understand, and improve the Service. We also may share your information as well as information from tools like cookies, log files, and device identifiers and location data, with third-party organizations like online advertising platforms, analytics services, suppliers of technical and support services and cloud hosting providers that help us provide the Service to you ("Service Providers"). Our Service Providers will be given access to your information as is reasonably necessary to provide the Service under reasonable confidentiality terms.
- Corporate affiliates: We may also share your information with our corporate affiliates.
- Advertising partners: We may also share certain information such as cookie data with third-party advertising partners. This information would allow third-party ad networks to, among other things, deliver targeted advertisements that they believe will be of most interest to you. Some of these cookies are from third parties that collect information (including internet browsing information) about users of our Service across different websites and over time in order to provide advertising (on our Service and elsewhere) based on users’ online activities (so-called “interest-based advertising”) on our Service and elsewhere online. We are not responsible for the privacy practices of these third parties, and the information practices of these third parties are not covered by this Privacy Policy. Some of these companies are members of the Network Advertising Initiative, which offers a single location to opt out of ad targeting from member companies. To learn more, please click here or here. To learn about how Google processes your personal information and what choices you may have, visit their site here.
- On a change of control of the Company: If we sell or otherwise transfer part or the whole of Firework or our assets to another organization (e.g., in the course of a transaction like a merger, acquisition, bankruptcy, dissolution, or liquidation), your information such as name and email address, User Content and any other information collected through the Service may be among the items sold or transferred.
- Responding to legal requests and preventing harm: We may access, preserve and share your information 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. This may include responding 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. We may also access, preserve and share information when we have a good faith belief it is necessary to: detect, prevent and address fraud and other illegal activity; to protect ourselves, you and others, including as part of investigations; and to prevent death or imminent bodily harm. 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.
- Where you consent: We may also share your information for any other purposes disclosed to you with your consent.
- Anonymized and aggregated data: We may also disclose and use anonymized, aggregated reporting and statistics about users of our Service for the purpose of internal reporting or reporting to our corporate affiliate or other third parties (including clients), and for our marketing and promotion purposes. None of these anonymised, aggregated reports or statistics will enable our users to be personally identified.
How We Store, Transfer, and Secure Your Information
Your information collected through the Service may be stored and processed in the United States or any other country in which Firework maintains facilities.
Firework may transfer 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. If you are located in the UK or European Economic Area ("EEA") or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including personal information, to parties located in a country or jurisdiction that does not have the same data protection laws as your jurisdiction (for example the United States). We take appropriate steps to ensure that such personnel and third-party vendors are bound to duties of confidentiality and we implement measures such as EU Standard Contractual Clauses to ensure that any transferred personal information remains protected and secure. A copy of these clauses can be obtained by contacting us at the details listed below.
We also use commercially reasonable safeguards to help keep the information collected through the Service secure from loss, interference, misuse, unauthorized access, disclosure, alteration, or destruction. We also maintain reasonable procedures to help ensure that such data is reliable for its intended use and is accurate, complete, and current.
How Long We Store Your Personal Information
How long we keep your User Content
Following termination or deactivation of your account, Firework or its Service Providers may retain information (including your profile information) and User Content for a commercially reasonable time for backup, archival, and/or audit purposes, in accordance with applicable laws.
How long we keep other personal data
We keep your personal information for no longer than necessary for the purposes for which the personal information is processed. The length of time for which we retain personal information depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights.
Choices About Your Information and Your Rights
Update your account at any time by logging in and changing your profile settings.
Unsubscribe from email communications from us by clicking on the "unsubscribe link" provided in such communications. You may not opt out of Service-related communications (e.g., account verification, changes/updates to features of the Service, technical and security notices).
What rights do you have related to the processing of your personal information?
You may be entitled, in accordance with applicable law, to object to or request restriction of processing of your personal information, and to request access to, rectification, erasure and portability of your personal information.
Specifically, users in the UK or EEA have the following rights:
- Right of access. You have a right of access to any personal information we hold about you. You can ask us for a copy of your personal information, confirmation as to whether your personal information is being used by us, details about how and why it is being used, and details of the safeguards which are in place if we transfer your information outside of the United Kingdom or the EEA.
- Right to update your information. You have a right to request an update to any of your personal information which is out of date or incorrect.
- Right to delete your information. You have a right to ask us to delete any personal information which we are holding about you in certain specific circumstances. You can ask us for further information on these specific circumstances by contacting us using the details set out below. We will pass your request onto other recipients of your personal information unless that is impossible or involves disproportionate effort. You can ask us who the recipients are, using the contact details set out below.
- Right to restrict use of your information: You have a right to ask us to restrict the way that we process your personal information in certain specific circumstances. You can ask us for further information on these specific circumstances by contacting us using details set out below.
We will pass your request onto other recipients of your personal information unless that is impossible or involves disproportionate effort. You can ask us who the recipients are using the contact details set out below. - Right to stop marketing: You have a right to ask us to stop using your personal information for direct marketing purposes. If you exercise this right, we will stop using your personal information for this purpose.
- Right to data portability: You have a right to ask us to provide your personal information to a third party provider of services. This right only applies where we use your personal information on the basis of your consent or performance of a contract and where our use of your information is carried out by automated means.
- Right to object. You have a right to ask us to consider any valid objections which you have to our use of your personal information where we process your personal information on the basis of our or another person's legitimate interest.
We will consider all such requests and provide our response within a reasonable period (and in any event within one month of your request unless we tell you we are entitled to a longer period under applicable law). Please note, however, that certain personal information may be exempt from such requests in certain circumstances, for example if we need to keep using the information to comply with our own legal obligations or to establish, exercise or defend legal claims.
If an exception applies, we will tell you this when responding to your request. We may request you provide us with information necessary to confirm your identity before responding to any request you make.
Users in the UK or EEA may also lodge a complaint with a supervisory authority if they consider that our processing of their personal information infringes applicable law.
Please send an email to us if you would like to exercise any of your rights (privacy@fw.tv).
Your California Privacy Rights
California residents are entitled once a year, free of charge, to request and obtain certain information regarding our disclosure, if any, of certain categories of personal information to third parties for their direct marketing purposes in the preceding calendar year. We do not share personal information with third parties for their own direct marketing purposes. To request a copy of your personal information maintained by us, please contact us as at the e-mail address in the How to Contact Us section below.
California residents may also request access to, deletion, and portability of their personal information in accordance with applicable law by contacting us at the email address in the How to Contact Us section below. We will not discriminate against you for exercising your rights, although some of the functionality and features on the Service may change or no longer be available to you. Any differences in the Service are related to the value provided.
Once we receive your request, we may verify it by requesting information sufficient to confirm your identity. If you would like to use an authorized agent registered with the California Secretary of State to exercise your rights, we may request evidence that you have provided such agent with power of attorney or that the agent otherwise has valid written authority to exercise rights on your behalf.
We do disclose personal information for business purposes, including but not limited to services performed on our behalf, to provide advertising on our Service and elsewhere based on users’ online activities over time and across different sites, services, and devices (so-called “interest-based advertising”), and to protect against fraud and malicious activity. In addition, your information may be accessible to third parties with whom you interact or direct us to share your information through our Services. The information practices of these third parties are not covered by this privacy policy.
Other Web Sites and Services
We are not responsible for the practices employed by any websites or services linked to or from our Service, including the information or content contained within them. Please remember that when you use a link to go from our Service to another website or service, our Privacy Policy does not apply to those third-party websites or services. Your browsing and interaction on any third-party website or service, including those that have a link on our website, are subject to that third party’s own rules and policies. In addition, you agree that we are not responsible and do not have control over any third-parties that you authorize to access your User Content. If you are using a third-party website or service and you allow them to access your User Content you do so at your own risk.
How to Contact Us
If you have any questions about this Privacy Policy or the Service, please contact us through email: privacy@fw.tv or mail: 2635 Broadway Street, Redwood City, CA 94063.
Changes to Our Privacy Policy
Firework may modify or update this Privacy Policy from time to time, so please review it periodically. When we update the Privacy Policy, we will revise the “Updated” date above and post the new Privacy Policy. We may provide you additional forms of notice of modifications or updates as appropriate under the circumstances. Your continued use of Firework or the Service after any modification to this Privacy Policy will constitute your acceptance of such modification.
Below is the previous version of Firework's Privacy Policy. The current version of Firework's Privacy Policy is available at: https://firework.com/legal/privacypolicy
We are Loop Now Technologies, Inc, trading as Firework, based at 2635 Broadway Street, Redwood City, CA 94063, United States of America. All references in this policy to "Firework", "Company", "our", "us" or "we" refer to Loop Now Technologies, Inc.
Our Privacy Policy explains how we collect, use, share and protect information in relation to our Service. Our Service refers to all mobile software applications that Loop Now Technologies, Inc. dba Firework services (the “Company”) makes available for download (each, an “App,” and together, the “Apps”) and the related website located at www.fw.tv and/or any other website(s) owned or controlled by or on behalf of the Company (collectively, “Sites”) as well as instances of all or portions of our service that are available on or via websites, applications or devices of third party publishers or distributors (such Apps, Sites and third party instances of our service are collectively referred to as the “Service”). This Privacy Policy also explains your choices about the collection and use of your information.
By using our Service you understand and agree that we are providing a platform for you to either view and/or post content, including photos, videos, comments and other materials ("User Content"), to the Service and/or 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 this Privacy Policy. It also means that, subject to your selection of privacy settings available within the App, we may make your User Content publicly available to third parties that are not owned nor operated by Firework, consistent with this Privacy Policy. By viewing User Content on our Service, you are also subject to the terms of this Privacy Policy. If you are based in the UK or EU, the Company is the controller of, and responsible for, your personal information.
Categories Of Information We Collect
Personal information and other information you provide us.
- Account Information, including your username, password and email address, such as when you register for a Firework account.
- Profile Information that you provide for your user profile, including identifiers such as your first and last name, age, gender, and phone number.
- Communications between you and Firework. For example, we may send you Service-related emails (e.g., account verification, changes/updates to features of the Service, technical and security notices), marketing, and other communications.
- Identifiers, which we automatically collect when you use the Service, including your IP address (not using GPS data), and internet or other electronic network activity information, such as your device information, or other unique device identifiers, cookies (as defined below), browsing records, mobile carrier, time zone setting and geolocation data, mobile or device model, operating system and platform as well as information regarding your use of the Service, e.g. the comments you make on our App or any other user-generated content and video content that you broadcast on our App.
- Business contact information where you are an employee, agent or officer of one of our business partners, publishers or suppliers (or prospective business partners, publishers or suppliers), contact information to be used in the course of our business such as your name, email address, phone number, address, job title, LinkedIn profile information.
Analytics information
We use third-party analytics tools to help us measure traffic and usage trends for the Service. These tools collect information sent by your device or our Service, including the web pages you visit, add-ons, and other information that assists us in improving the Service. We collect and use this analytics information with analytics information from other Users so that it cannot reasonably be used to identify any particular individual User.
We use third party analytics tool Google Analytics and Firebase provided by Google, Inc (1600 Amphitheatre Parkway Mountain View, CA 94043, USA). We also further use Facebook Analytics and "Facebook Pixel" of Facebook Inc. (1 Hacker Way, Menlo Park, CA 94025, USA) ("Facebook") and Amplitude Analytics (631 Howard Street, 5th floor, San Francisco, CA 94105).
Cookies
When you visit the Service, we may use cookies like pixels, web beacons, and local storage to collect information about how you use Firework and provide features to you.
Cookies are small files that are placed on your computer by websites that you visit or certain emails you open. They are widely used in order to make websites function properly, as well as to provide business and marketing information to the owners of the site and other third parties.
Firework may ask advertisers or other partners to serve ads or services to your devices, which may use cookies or similar technologies placed by us or the third party. We also may ask analytics providers to use cookies.
Several types of cookies are used for our Service:
- Essential Cookies: These cookies enable you to use our Service. These cookies are essential to enable you to browse our Service and use certain features. Disabling them may prevent you from using certain parts of the Service. These cookies also help keep our Service safe and secure.
- Preference Cookies: These cookies store information such as your preferred country and language selection, login data and website preferences. Without these cookies, our Service may not be able to remember certain choices you’ve previously made or personalize your browsing experience by providing you with relevant information. These cookies can also be used to recognize your device so that you do not have to provide the same information more than once.
- Performance Cookies: These cookies collect information about how you use our Service, such as which pages you visit regularly. These cookies are used to provide you with a high-quality experience by doing things such as tracking page load, response times, and error messages.
- Content/Advertising Cookies: These cookies gather information about your use of our Service so we may improve your experience and provide you with more relevant content and advertising. They are also used to gather feedback through surveys. They remember that you’ve visited our Services and help us understand usage of our Service.
You may refuse to accept cookies by altering the settings on your internet browser, or such other mechanisms that we provide via our Services. For further information about cookies, please see http://www.allaboutcookies.org
More Cookie And Log File Information
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 web page or app is downloaded to your browser or device.
When you use our Service, our servers automatically record certain log file information, including your web request, Internet Protocol ("IP") address, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed, and other such information. 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 the Service.
Do-Not-Track Signals and Similar Mechanisms: Some web browsers transmit “do-not-track” signals to websites. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. We currently do not take action in response to these signals.
Device identifiers
When you use a mobile device like a 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 Firework.
A device identifier may deliver information to us or to a third party partner about how you browse and use the Service and may help us or others provide reports or personalized content and ads. For more information about personalized or interest-based advertising, please see the “Sharing of Your Information” section below. Some features of the Service may not function properly if use or availability of device identifiers is impaired or disabled.
Metadata
Metadata is usually technical data that is associated with User Content. For example, Metadata can describe how, when and by whom a piece of User Content was collected and how that content is formatted.
Users can add or may have Metadata added to their User Content including a hashtag (e.g., to mark keywords when you send a photo), geotag (e.g., to mark your location to a photo), or other data. This makes your User Content more searchable by others and more interactive.
TrueDepth Camera
We use TrueDepth technologies with our camera SDK to provide real-time face filters within the App. From time to time, we may use information from Apple’s TrueDepth camera to improve the quality of lenses. None of the information collected by the TrueDepth ever leaves the user’s device. Information from TrueDepth camera is used in real time - this information is not stored in our servers or shared with third parties. For more information about TrueDepth technologies, you may visit https://support.apple.com/en-us/HT208108.
Purposes of Data Processing and How We Use Your Information
In addition to some of the specific uses of information we describe elsewhere in this Privacy Policy, we may use information that we receive to:
- help you efficiently access your information after you sign in to our Service
- remember information so you will not have to re-enter it during your visit or the next time you visit the Service
- communicate with you or third parties, or allow third parties to communicate with you provide, improve, test, and monitor the effectiveness of our Service
- develop and test new products and features
- monitor metrics such as total number of visitors, traffic, and demographic patterns
- in the case of business contact information, do business with partners, publishers and suppliers
- take the appropriate technical and organizational security measures in order to protect the Service or your personal information
- comply with legitimate requests or orders from competent public authorities and courts, including data protection authorities
- carry out internal corporate reporting, business administration, ensure adequate insurance coverage for our business, ensure the security of company facilities, research and development, and identify and implement business efficiencies (where it is in our legitimate interests to do so)
- establish, exercise or defend our legal rights – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others, as well as where we are legally required to do so
- diagnose or fix technology problems
- make User Content available to third parties that are non-owned and non-operated by Firework, subject to your opting out by notifying our Support Team at support@fireworkhq.com
- automatically update the Firework application on your device.
In cases where we make our Service available on or via websites, applications or devices of third party publishers or distributors, we may provide some or all of the following information to such third parties: number of videos viewed on their site or application, video preferences, and duration of video views.
Before using your personal information for any purposes which fall outside those set out in this Privacy Policy, we will undertake an analysis to establish if our new use of your personal information is compatible with the purposes set out in this Privacy Policy. Please contact us using the details towards the end of this Privacy Policy if you want further information on the analysis we will undertake.
Legal Basis for Processing Your Personal Information
Our legal basis for processing your personal information for the purposes described above includes processing that is: necessary for the performance of our contract with you (such as where necessary to provide you with our products or services); necessary for our legitimate interests (such as to carry out analytics in order to improve our Service, run, grow and develop our business and Service, select appropriately skilled and qualified suppliers, carry out marketing, market research and business development and for internal administrative purposes); and necessary to comply with our legal obligations (such as to respond to a subpoena or other legal process). In some cases (e.g., for the purposes of sharing information with third-party advertising partners), we may rely on your consent to process your information, which may subsequently be withdrawn at any time by contacting us at the details listed below. Withdrawing your consent does not affect the lawfulness of processing based on consent before it was withdrawn, and, where it is in compliance with applicable laws, we may have another valid legal basis to continue processing your information.
Sharing of Your Information
Whom we may share your information with:
- Our suppliers/service providers: We may share User Content and your information (including but not limited to, information from cookies, log files, device identifiers, location data, and usage data) with other entities, including entities that we do not own or operate. You may limit sharing through contacting Firework at privacy@fw.tv to opt out. Firework may use this information to help provide, understand, and improve the Service. We also may share your information as well as information from tools like cookies, log files, and device identifiers and location data, with third-party organizations like online advertising platforms, analytics services, suppliers of technical and support services and cloud hosting providers that help us provide the Service to you ("Service Providers"). Our Service Providers will be given access to your information as is reasonably necessary to provide the Service under reasonable confidentiality terms.
- Corporate affiliates: We may also share your information with our corporate affiliates.
- Advertising partners: We may also share certain information such as cookie data with third-party advertising partners. This information would allow third-party ad networks to, among other things, deliver targeted advertisements that they believe will be of most interest to you. Some of these cookies are from third parties that collect information (including internet browsing information) about users of our Service across different websites and over time in order to provide advertising (on our Service and elsewhere) based on users’ online activities (so-called “interest-based advertising”) on our Service and elsewhere online. We are not responsible for the privacy practices of these third parties, and the information practices of these third parties are not covered by this Privacy Policy. Some of these companies are members of the Network Advertising Initiative, which offers a single location to opt out of ad targeting from member companies. To learn more, please click here or here. To learn about how Google processes your personal information and what choices you may have, visit their site here.
- On a change of control of the Company: If we sell or otherwise transfer part or the whole of Firework or our assets to another organization (e.g., in the course of a transaction like a merger, acquisition, bankruptcy, dissolution, or liquidation), your information such as name and email address, User Content and any other information collected through the Service may be among the items sold or transferred.
- Responding to legal requests and preventing harm: We may access, preserve and share your information 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. This may include responding 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. We may also access, preserve and share information when we have a good faith belief it is necessary to: detect, prevent and address fraud and other illegal activity; to protect ourselves, you and others, including as part of investigations; and to prevent death or imminent bodily harm. 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.
- Where you consent: We may also share your information for any other purposes disclosed to you with your consent.
- Anonymized and aggregated data: We may also disclose and use anonymized, aggregated reporting and statistics about users of our Service for the purpose of internal reporting or reporting to our corporate affiliate or other third parties (including clients), and for our marketing and promotion purposes. None of these anonymised, aggregated reports or statistics will enable our users to be personally identified.
How We Store, Transfer, and Secure Your Information
Your information collected through the Service may be stored and processed in the United States or any other country in which Firework maintains facilities.
Firework may transfer 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. If you are located in the UK or European Economic Area ("EEA") or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including personal information, to parties located in a country or jurisdiction that does not have the same data protection laws as your jurisdiction (for example the United States). We take appropriate steps to ensure that such personnel and third-party vendors are bound to duties of confidentiality and we implement measures such as EU Standard Contractual Clauses to ensure that any transferred personal information remains protected and secure. A copy of these clauses can be obtained by contacting us at the details listed below.
We also use commercially reasonable safeguards to help keep the information collected through the Service secure from loss, interference, misuse, unauthorized access, disclosure, alteration, or destruction. We also maintain reasonable procedures to help ensure that such data is reliable for its intended use and is accurate, complete, and current.
How Long We Store Your Personal Information
How long we keep your User Content
Following termination or deactivation of your account, Firework or its Service Providers may retain information (including your profile information) and User Content for a commercially reasonable time for backup, archival, and/or audit purposes, in accordance with applicable laws.
How long we keep other personal data
We keep your personal information for no longer than necessary for the purposes for which the personal information is processed. The length of time for which we retain personal information depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights.
Choices About Your Information and Your Rights
Update your account at any time by logging in and changing your profile settings.
Unsubscribe from email communications from us by clicking on the "unsubscribe link" provided in such communications. You may not opt out of Service-related communications (e.g., account verification, changes/updates to features of the Service, technical and security notices).
What rights do you have related to the processing of your personal information?
You may be entitled, in accordance with applicable law, to object to or request restriction of processing of your personal information, and to request access to, rectification, erasure and portability of your personal information.
Specifically, users in the UK or EEA have the following rights:
- Right of access. You have a right of access to any personal information we hold about you. You can ask us for a copy of your personal information, confirmation as to whether your personal information is being used by us, details about how and why it is being used, and details of the safeguards which are in place if we transfer your information outside of the United Kingdom or the EEA.
- Right to update your information. You have a right to request an update to any of your personal information which is out of date or incorrect.
- Right to delete your information. You have a right to ask us to delete any personal information which we are holding about you in certain specific circumstances. You can ask us for further information on these specific circumstances by contacting us using the details set out below. We will pass your request onto other recipients of your personal information unless that is impossible or involves disproportionate effort. You can ask us who the recipients are, using the contact details set out below.
- Right to restrict use of your information: You have a right to ask us to restrict the way that we process your personal information in certain specific circumstances. You can ask us for further information on these specific circumstances by contacting us using details set out below.
We will pass your request onto other recipients of your personal information unless that is impossible or involves disproportionate effort. You can ask us who the recipients are using the contact details set out below. - Right to stop marketing: You have a right to ask us to stop using your personal information for direct marketing purposes. If you exercise this right, we will stop using your personal information for this purpose.
- Right to data portability: You have a right to ask us to provide your personal information to a third party provider of services. This right only applies where we use your personal information on the basis of your consent or performance of a contract and where our use of your information is carried out by automated means.
- Right to object. You have a right to ask us to consider any valid objections which you have to our use of your personal information where we process your personal information on the basis of our or another person's legitimate interest.
We will consider all such requests and provide our response within a reasonable period (and in any event within one month of your request unless we tell you we are entitled to a longer period under applicable law). Please note, however, that certain personal information may be exempt from such requests in certain circumstances, for example if we need to keep using the information to comply with our own legal obligations or to establish, exercise or defend legal claims.
If an exception applies, we will tell you this when responding to your request. We may request you provide us with information necessary to confirm your identity before responding to any request you make.
Users in the UK or EEA may also lodge a complaint with a supervisory authority if they consider that our processing of their personal information infringes applicable law.
Please send an email to us if you would like to exercise any of your rights (privacy@fw.tv).
Your California Privacy Rights
California residents are entitled once a year, free of charge, to request and obtain certain information regarding our disclosure, if any, of certain categories of personal information to third parties for their direct marketing purposes in the preceding calendar year. We do not share personal information with third parties for their own direct marketing purposes. To request a copy of your personal information maintained by us, please contact us as at the e-mail address in the How to Contact Us section below.
California residents may also request access to, deletion, and portability of their personal information in accordance with applicable law by contacting us at the email address in the How to Contact Us section below. We will not discriminate against you for exercising your rights, although some of the functionality and features on the Service may change or no longer be available to you. Any differences in the Service are related to the value provided.
Once we receive your request, we may verify it by requesting information sufficient to confirm your identity. If you would like to use an authorized agent registered with the California Secretary of State to exercise your rights, we may request evidence that you have provided such agent with power of attorney or that the agent otherwise has valid written authority to exercise rights on your behalf.
We do disclose personal information for business purposes, including but not limited to services performed on our behalf, to provide advertising on our Service and elsewhere based on users’ online activities over time and across different sites, services, and devices (so-called “interest-based advertising”), and to protect against fraud and malicious activity. In addition, your information may be accessible to third parties with whom you interact or direct us to share your information through our Services. The information practices of these third parties are not covered by this privacy policy.
Other Web Sites and Services
We are not responsible for the practices employed by any websites or services linked to or from our Service, including the information or content contained within them. Please remember that when you use a link to go from our Service to another website or service, our Privacy Policy does not apply to those third-party websites or services. Your browsing and interaction on any third-party website or service, including those that have a link on our website, are subject to that third party’s own rules and policies. In addition, you agree that we are not responsible and do not have control over any third-parties that you authorize to access your User Content. If you are using a third-party website or service and you allow them to access your User Content you do so at your own risk.
How to Contact Us
If you have any questions about this Privacy Policy or the Service, please contact us through email: privacy@fw.tv or mail: 2635 Broadway Street, Redwood City, CA 94063.
Changes to Our Privacy Policy
Firework may modify or update this Privacy Policy from time to time, so please review it periodically. When we update the Privacy Policy, we will revise the “Updated” date above and post the new Privacy Policy. We may provide you additional forms of notice of modifications or updates as appropriate under the circumstances. Your continued use of Firework or the Service after any modification to this Privacy Policy will constitute your acceptance of such modification.