Joya has two fundamental principles when it comes to personal information:
- We don't sell your personal information or use it to show you ads.
- We only store the personal information that we need to operate our Service so you can communicate with the people you choose.
This Policy applies to anyone who accesses the Service. By visiting the Website and/or using the Apps or Service, you acknowledge that the collection, use, and sharing of your information will take place as described in this Policy.
What we collect
Marco Polo is a communication service. To operate the Service, we may collect Personal Information you choose to provide us.
1. Marco Polo App
a. Basic Account Data
To create a Marco Polo account (“Account”), you provide your mobile number, your name and your email address, and may choose to provide your photo, birth day and birth month. Only other registered Marco Polo users that:
- already have your phone number in their phone’s address book,
- are in a group with you, or
- you invited to Marco Polo
may see your name, photo, mobile number, email, birth day and/or birth month. Note that users who have you in their contacts will see you by the name they’ve saved and not by the name you provided to Marco Polo. For example, your spouse will still see you as “Love” when they use the app if that’s how you appear in their phone’s address book. If you chose to provide them, we collect your birth day and month so people you know get reminded when it’s your birthday.
b. Polo Messages and Scrapbooks
Marco Polo is a cloud service. We may collect and store the content you create, including videos (or “Polos”), photos, short video clips you share with selected contacts (or “Scrapbook moments”), and text messages. We store this Personal Information on our servers so that you can access your data anytime from any of your devices that have the Marco Polo App without having to rely on third-party backups or use up your phone’s memory. Our servers are located in the United States.
You may choose to provide us with your friends' contact information as stored on your phone. Marco Polo uses mobile phone numbers and email addresses as unique identifiers so that it is easy for you to find and communicate with other people you know. We ask your permission before syncing your contacts, and you can still use the app without giving it access to your contacts (though you will have a harder time finding people you know who also use Marco Polo).
We store your contacts on our servers in order to notify you as soon as one of your contacts creates a Marco Polo Account and to properly display their names. We store their name, phone number(s), email address(es), and/or birth day and month for this to work.
Our automatic algorithms also use this data to suggest which of your contacts you might like to communicate with on Marco Polo. We use this information to suggest people to invite to join Marco Polo but we do not contact anyone in your phone’s contact list without your permission. Other than our Service Providers that we describe below, we do not share your contacts with third parties unless required to do so in response to valid legal requests, such as through a court order or search warrant.
2. Channels App
Through Channels, you can be a leader or member of a Channels group. Leaders facilitate learning and/or provide guidance on various topics. You can subscribe to become a Channels member by joining a particular leader’s group and paying the subscription fee set by that leader.
a. Basic Account Data
To create a Marco Polo Channels member account (“Account”), you provide your mobile number, your name, and your email address, and may choose to provide your photo and other social media identifiers. Channel leaders will have access to this data while you maintain an active paid membership to their channel.
Other Channels group members will see your name and photo, but your email and mobile number will not be shared with other Channels group members unless you explicitly choose to do so.
b. Other Data
If you subscribe to a Channels group, the Channels leader and other members will also receive any other personal information you choose to share with the group.
3. User Support
If you contact Marco Polo support, any Personal Information you may share with us is used only for the purposes of researching the issue and contacting you about your request.
4. Additional Technical Information
We use third-party analytics Service Providers (as more fully described below, and including Google Analytics and amplitude.com) to automatically log information about you and your computer or mobile device, and how you 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. Marco Polo collects this additional technical data to analyze usage trends and give us more information about how people use the Service to better the user experience.
4.2 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 which emails are read and used by our users and which are 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 are welcome to adjust your browser or operating system settings to limit this tracking or to decline cookies and doing so will not change your experience in the Marco Polo App or Website.
Check the "Help" menu of your browser or operating system to learn how to change your tracking settings or cookie preferences. For example:
- At the top right, click More Settings.
- At the bottom, click Advanced.
- Under "Privacy and security," turn on "Do Not Track."
With Firefox, follow the instructions here.
Managing your Information
You can manage your Personal Information in the Apps’ Settings.
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 don't use your Personal Information for ad targeting. Marco Polo only stores the Personal Information it needs to operate the Service.
We may use the Personal Information we collect from and about you to:
- Operate, maintain, and improve our Service;
- Allow you to find and connect with your friends (when instructed by you);
- Let your friends know about your activity on the Service;
- Analyze usage and trends and personalize and improve the Service and your experience using the Service;
- Respond to your comments and questions and provide customer service;
- Send information including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages;
- Send marketing emails that promote the use of Marco Polo from which you can opt-out as described below;
- Protect, investigate, and deter against fraudulent, unauthorized, or illegal activity; and
- Provide and deliver products and services that you request.
Our marketing emails tell you how to opt-out or unsubscribe. If you opt-out of marketing emails, we may still send you non-marketing emails and notifications, which may include information about your account, our business dealings with you, and updates regarding our policies.
Sharing of Personal Information
We may share the Personal Information we collect from and about you (1) with other App users, according to your account preferences and consistent with our Terms of Service; (2) for legal, protection, and safety purposes; (3) to comply with laws and in response to lawful requests and legal processes; (4) 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 (5) with those who need it to do work for us (our Service Providers, as defined below).
Other Marco Polo Users
If Marco Polo or substantially all of our assets are acquired by a third party, Personal Information held by us about our users will be one of the transferred assets. Such third party will be required to treat that Personal Information in a manner consistent with this Policy.
We work with third parties to provide some of our Service ("Service Providers"). For example, we use Third-Party SMS Providers to send a verification code to your phone number when you register on the Marco Polo App. 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.
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 that user from utilizing the Service.
By default, Marco Polo sends you emails and notifications regarding activities on the Service, e.g., when you receive a Polo from one of your contacts or when a Channels group leader you subscribe to posts a new video.
We may also communicate with you via informational, transactional, or marketing emails and/or text messages.
You may choose to unsubscribe from emails by clicking “Unsubscribe” from the email or in the Marco Polo App by going to Settings and selecting the “Send me fewer emails” option or the Channels App by going to Notifications and then to Settings and unselecting whichever notifications you do not want to receive.
If you unsubscribe, we may still need to send you non-marketing emails about your account or our business dealings with you (e.g., emails regarding AppStore or Google Play subscriptions you have with us).
We may also send you text notifications. You may opt out of receiving text messages by replying to the last message received or by emailing us at firstname.lastname@example.org with your mobile number and a request to stop sending messages.
You may also send requests about your Personal Information to email@example.com. You can also request to change your contact choices, opt-out of our sharing with others, and update your Personal Information.
Links to Other Sites
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.
California Consumer Privacy Act (CCPA) and General Data Protection Regulation (GDPR)
The CCPA and GDPR provides rights to certain individuals located in California and the European Union. We apply these rights to all of our users. You can contact us about these rights at firstname.lastname@example.org.
We do not disclose Personal Information beyond what is described in this Policy. All our users, including those in California, have the following rights.
- Right to access: You have the right to know and see what data we have collected about you over the past 12 months including:
- categories of personal information we have collected about you;
- categories of sources from which the personal information is collected;
- the business or commercial purpose for collecting your personal information;
- the categories of third parties with whom we have shared your personal information; and
- the specific pieces of personal information we have collected about you.
- Right to deletion: You have the right to request that we delete in certain circumstances the personal information we have collected from you.
- Right not to be discriminated against: You have the right not to be discriminated against for exercising any of these rights.
To request access to or deletion of your personal information, or to exercise any other data rights under the CCPA, please contact us at email@example.com.
General Data Protection Regulation (GDPR)
We, Joya, are the data controller of your Personal Information. Our contact information can be found at the end of this Policy.
Information according to GDPR Article 27 and UK laws
Joya Communications Inc is a company located outside of the European Union. In order to comply with GDPR Article 27 and UK laws, Prighter has been engaged as our representative in the European Union and the UK. If you want to contact us via our representative Prighter or make use of your data subject rights (e.g. requests to access or erase personal data), please visit the https://prighter.com/q/14211202 or simply email us at firstname.lastname@example.org.
We also have an appointed Data Protection Officer, who can be contacted at email@example.com.
All our users, including those in the European Economic Area (EEA), have the following rights, about which you can contact us at firstname.lastname@example.org.
- Right to access: the right to request certain information about, access to and copies of the Personal Information about you that we are holding;
- Right to request that we rectify, limit, cease processing or erase information we hold about you in certain circumstances;
- 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;
- 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; and
- Right to lodge a complaint about us to a supervisory body in your country of work or residence (for instance, the Information Commissioner’s Office in the UK).
Legal Basis for Processing
We process your Personal Information on the ground that such processing is necessary to further our legitimate interests (including: (1) providing an effective and innovative Service to our users; and (2) to detect, prevent or otherwise address fraud or security issues in respect of our provision of the Service), unless those interests are overridden by your interest or fundamental rights and freedoms that require protections of Personal Information.
We also process your Personal Information where it is necessary on the basis of performing under our contract with you in accordance with our Terms of Service, or in order to create a contract with you.
Automated decision making: Our software operates an algorithm to determine which of your contacts may be most relevant to you, who you might wish to connect with and/or invite to the Service.
Recipients of Personal Information and transfers to third countries:as set out in the sections above called Sharing of Personal Information and Service Providers, we share your Personal Information with certain third party providers in the United States, and such transfers are subject to appropriate safeguards.
We may retain the Personal Information you provide as long as you have an Account.
a. Marco Polo App
If you delete your Account, your Personal Information and any Scrapbooks you recorded will be deleted plus you will be removed from any Marco Polo groups; Polos, your name, profile picture, messages and information you have shared with other users through Marco Polo will remain accessible to them as described in the Terms of Service. If you delete your Account and had earlier synced your phone’s contact list with Marco Polo, the contact data and names of any of your contacts who have not registered on Marco Polo will also be deleted from our servers.
You can also permanently delete any Polo or message you create, and that is still available to you in the Marco Polo App by pressing on the Polo tile, holding down, and then selecting and confirming “Delete.” Doing so will permanently remove it from our servers and the Marco Polo accounts of whomever you sent it to.
Polos you have shared with other users through Marco Polo will remain accessible to them as described in the Terms of Service.
b. Channels App
If you delete your Account, your Personal Information will be deleted plus you will be removed from any Channels groups; information you have shared with leaders and other members through any Channels groups will remain accessible to them.
We welcome your comments or questions about this Policy. You may contact us at email@example.com.
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 have read and understood the updated Policy.