This privacy policy ("Policy") describes how Joya Communications Inc. ("Joya") collects, uses, and shares personal information of people who visit any of the Joya Communications Inc. websites where this Policy is posted (including, but not limited to, certain websites relating to the Marco Polo® mobile application) (each a "Site") and video sharing and other mobile applications ("Apps") (collectively, the "Service").

This Policy applies to anyone who accesses the Service. Please read the Policy carefully to understand our practices regarding your information and how we will treat it. By visiting the Sites or Apps and/or using the Service, you acknowledge and agree that the collection, use, and sharing of your information will take place as described in this Policy.

So we are clear about the terminology we are using, when we use the phrase "Personal Information" in this Privacy Policy, we mean information about an individual that (either by itself or when combined with information from other available sources) allows that individual to be identified, including, your name, telephone number, or email address.

What we collect

We require certain information to provide the Service to you. We collect information about you in several ways. We use this information to operate the Service and enhance your experience with our Service.

Information You Give Us

We may collect Personal Information you choose to provide to us, such as your‎ name, email address, mobile phone number,‎ your photo, your friends' contact information as stored on your phone, and the content that you create, such as your texts, photos, and videos.

Information We Get from Others

We may get Personal Information about you from other sources, including from social networks you link to through the Service. If, as part of your use of the Service, you connect your Service account with an account from a supported social network account, such as Facebook (a "Social Media Account"), we may receive Personal Information from the corresponding social network that relates to your Social Media Account. Such Personal Information may be about you and/or your Social Media Account contacts. Please check the policies of the applicable social network in order to understand what information we receive. Even if you later disconnect your Service account from your Social Media Account, we may still keep a copy of the Personal Information (such as your Social Media Account profile photo and your contact list) that we received from the connection of the two accounts, so that we may more easily connect you with your Social Media Account contacts who register with the Service in the future.

Personal Information Automatically Collected

We use a third-party Service Provider (defined below) to automatically log information about you and your computer or mobile device, and how you use and interact with the Service. For example, when you access the Service, we may log‎ your operating system type,‎ browser type and‎ language,‎ the pages you viewed,‎ how long you spent on a page,‎ access times,‎ Internet protocol (IP) address, your mobile device ID, mobile device serial number, unique user ID, wireless carrier, and information about your use of and actions on the Service.

We may also use third party advertisements to support our Service. Some of these advertisers may use technology such as cookies, web beacons, pixel tags, or log files when they advertise on our Service, which may send these advertisers information, including your non-personal information.


We may log information using "cookies." Cookies are small data files stored on your hard drive by a website. Cookies help us improve your experience with our Service. We use cookies to see which parts of our Service people use and like and to count visits to our Service.

Web Beacons

We may log information using digital images called Web beacons on our Service or in our emails. We use Web beacons to manage cookies, count visits, and to learn what marketing works and what does not. We also use Web Beacons to tell if you open or act on our emails. Similar to cookies, we use web beacons to improve your experience with our Service.

Tracking Options and California Do Not Track Disclosures. You may adjust your browser or operating system settings to limit this tracking or to decline cookies, but by doing so, you may not be able to use certain features on the Service or take full advantage of all of our offerings. Check the "Help" menu of your browser or operating system to learn how to change your tracking settings or cookie preferences. To learn more about the use of cookies or other tracking technologies to deliver more relevant advertising and your choices about not having this information used by certain Service Providers (defined below), please click here. On your mobile device, you can adjust your privacy and advertising settings to limit your tracking for advertising or control whether you receive more relevant advertising. Note that our systems may not recognize Do Not Track headers or requests from some or all browsers.

Use of Personal Information

We use the information that we have about you to operate, provide, support, personalize, and make our Service more relevant and useful to you and others.

We may use the Personal Information we collect from and about you to (1) operate, maintain, and improve our Service; (2) allow you to find and connect with your friends (when instructed by you); (3) let your friends know about your activity on the Service; (4) monitor and analyze usage and trends and personalize and improve the Service and your experience using the Service; (5) respond to your comments and questions and provide customer service; (6) send information including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages; (7) protect, investigate, and deter against fraudulent, unauthorized, or illegal activity; and (8) provide and deliver products and services that you request.

Sharing of Personal Information

We may share the Personal Information we collect from and about you (1) with other Service users and social networking services, according to your account preferences; (2) with your consent; (3) for legal, protection, and safety purposes; (4) to comply with laws and in response to lawful requests and legal processes; (5) to protect the rights and property of Joya Communications Inc., our agents, customers, and others, including by enforcing our agreements, policies, and terms of service; and (6) with those who need it to do work for us (our Service Providers, as defined below).

We may sell or purchase assets during the normal course of our business. If another entity acquires us or any of our assets, information we have collected about you may be transferred to such entity. In addition, if any bankruptcy or reorganization proceeding is brought by or against us, such information may be considered an asset of ours and may be sold or transferred to third parties. Should such a sale or transfer occur, we will use reasonable efforts to confirm that the transferee use Personal Information provided through this Service in a manner that is consistent with this Policy.

Service providers

We may contract with third parties to perform functions related to the Service ("Service Providers"). Service Providers will have access to your Personal Information needed to perform their business functions, but may not use or share that personal information for purposes outside the scope of their functions related to the Service.

Your California privacy rights

For California residents: We may share your Personal Information with third parties (including affiliated third parties which may not share the Joya Communications Inc. name) for their direct marketing purposes. Under California law, you may request information about our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please contact us at

Information choices and changes

Our marketing emails tell you how to "opt-out." If you opt out, we may still send you non-marketing emails. Non-marketing emails include emails about your accounts and our business dealings with you. You may send requests about Personal Information to our Contact Information below. You can also request to change contact choices, opt-out of our sharing with others, and update your Personal Information.

The Service may contain links to other third-party websites or applications. Any information you provide on those sites is subject to that third party's privacy policy. Our Policy does not apply to such sites, and we are not responsible for the privacy and security practices and policies of those third-party sites or applications.

Our commitment towards children's privacy

We do not direct the Service to, nor do we knowingly collect any Personal Information from, children under 13. Children under 13 are not eligible to use the Service. If we learn that a user is under 13 years of age, we will take steps to remove that user's personal information from our databases and to prevent the user from utilizing the Service.

Security of your Personal Information

We are committed to protecting the security of your personal information. We have taken certain physical, administrative, and technical steps to help safeguard the information we collect from and about you. While we take steps to help ensure the integrity and security of our network and systems, we cannot guarantee our security measures.

General Data Protection Regulation (GDPR)

If you are based within the European Union (EU), in certain circumstances you will also have the following rights:

  1. Right to access: the right to request certain information about, access to and copies of the Personal Information about you that we are holding (please note that you are entitled to request one copy of the Personal Information that we hold about you at no cost, but for any further copies, we reserve the right to charge a reasonable fee based on administration costs);
  2. Right to rectification: the right to have your Personal Information rectified if it is inaccurate or incomplete;
  3. Right to erasure/"right to be forgotten": where the processing of your information is based on your consent, the right to withdraw that consent and the right to request that we delete or erase your Personal Information from our systems (however, this will not apply if we do not rely on your consent to carry out the processing, if we are required to hold on to the information for compliance with any legal obligation, or if we require the information to establish or defend any legal claim);
  4. Right to restriction of use of your information: the right to stop us from using your Personal Information or limit the way in which we can use it;
  5. Right to data portability: the right to request that we return any information you have provided in a structured, commonly used, and machine-readable format, or that we send it directly to another company, where technically feasible; and
  6. Right to object: the right to object to our use of your Personal Information including where we use it for our legitimate interests or, if applicable, for marketing purposes.

The following legal basis apply to the ways in which we use and share an individual's Personal Information:

  1. We process Personal Information on the basis of our performance of our contract with the individual, or in order to create such a contract. Our contract with the individual requires us to collect their data as set out in this Policy and the Terms of Service.
  2. We also process the information provided by an individual in our legitimate interests in ensuring our business is conducted legitimately, to a high standard, and to market our Service.

Although we use your Personal Information for profiling, all we do is propose contacts or affiliations that we will, with your consent, invite to join the Service or a feature of the Service. We do not make decisions by automatic means.


We may retain the Personal Information you provide as long as you have an account with Joya. If you delete your account, your Personal Information will be deleted (excluding any information you have shared with other users through the Service, which will remain accessible to such users as described in the Terms of Service). Upon your deletion of your account, we retain the right to anonymize your data by removing your Personal Information and maintaining the non-personal information in our statistical database.

Requests in relation to the above rights should be sent to:

Contact information

We welcome your comments or questions about this Policy. You may contact us at

Changes to privacy policy

We may modify this Policy from time to time. If we make any changes, we will change the Last Updated date below. We also may provide additional notice, as applicable, depending on the type of change. If you object to any changes, you may stop using the Service. Your continued use of the Service after we publish or otherwise provide notice about our changes to the Policy means that you are consenting to the updated Policy.

Last Updated on May 25th, 2018.