Privacy Policy

Effective April 20, 2020

Here (or “Here.fm”) is a real-time social platform and work tool that provides fast and fun ways to express yourself, communicate with others and have fun together!

When you use these services, you’ll share some information with us. So we want to be upfront about the information we collect, how we use it, whom we share it with, and the controls we give you to access, update, and delete your information.

That’s why we’ve written this Privacy Policy. And it’s why we’ve tried to write it in a way that’s blissfully free of the legalese that often clouds these documents. Of course, if you still have questions about anything in our Privacy Policy, just contact us at weare @ here.fm

Information We Collect

There are three basic categories of information we collect:

• Information you provide.
• Information we get when you use our services.
• Information we get from third parties.

Here’s a little more detail on each of these categories.

Information You Provide

When you interact with our services, we collect information that you provide to us. For example, most of our services require you to set up a Here account, so we need to collect a few important details about you, such as your name, username, password, email address, phone number, and date of birth. We may also ask you to provide us with some additional information that will be publicly visible on our services, such as a profile picture or avatar. Other services, such as commerce products, may require you to provide us with a debit or credit card number and its associated account information.

Of course, you’ll also provide us whatever information you send through our services, such as image uploads, files, links and chat messages. Keep in mind that the users in shared rooms with you are able to see whatever content you post, and those users can always save that content or copy it outside the app. So, the same common sense that applies to the internet at large applies to Here as well: Don’t send messages or share content that you wouldn’t want someone to save or share.

When you contact customer support or communicate with us in any other way, we’ll collect whatever information you volunteer or that we need to resolve your question.

Information We Get When You Use Our Services

When you use our services, we collect information about which of those services you’ve used and how you’ve used them. We might know, for instance, that you selected a particular GIF, enabled video for 21 minutes with a specific group of users, or just wrote a message.  Here’s a fuller explanation of the types of information we collect when you use our services:

• Usage Information. We collect information about your activity through our services. For example, we may collect information about:

• how you interact with our services, such as which backgrounds you prefer for Rooms, or how long your Here sessions typically are.
• how you communicate with other Users, such as their names, the time and date of your communications, and the length of your video chats

• Content Information. We collect content you create on our services, such as custom stickers, and information about the content you create or provide, such as if the recipient has viewed the content and the metadata that is provided with the content.
• Device Information. We collect information from and about the devices you use. For example, we collect:

• information about your hardware and software, such as the hardware model, operating system version, device memory, advertising identifiers, unique application identifiers, apps installed, unique device identifiers, browser type, language, battery level, and time zone;
• information from device sensors, such as accelerometers, gyroscopes, compasses, microphones, and whether you have headphones connected; and
• information about your wireless and mobile network connections, such as mobile phone number, service provider, IP address, and signal strength.

• Device Addressbook. Because Here is all about communicating with friends and coworkers, we may—with your permission—collect information from your device’s addressbook or contact list.
• Camera, Mic, Photos and Files. Many of our services require us to access your device camera and microphone to enable video chats.  We also may need to access your image files and other files on your device so you can share them with other Users on the Service.
• Location Information. When you use our services we may collect information about your location. With your permission, we may also collect information about your precise location using methods that include GPS, wireless networks, cell towers, Wi-Fi access points, and other sensors, such as gyroscopes, accelerometers, and compasses.
• Information Collected by Cookies and Other Technologies. Like most online services and mobile applications, we uses cookies and similar technologies like single-pixel gifs and web beacons, to record log data. We use both session-based and persistent cookies.  Cookies are small text files sent by us to your computer and from your computer or mobile device to us each time you visit our website or use our desktop application. They are unique to your account or your browser. Session-based cookies last only while your browser is open and are automatically deleted when you close your browser. Persistent cookies last until you or your browser delete them or until they expire.  Some cookies are associated with your account and personal information in order to remember that you are logged in and which teams you are logged into. Other cookies are not tied to your account but are unique and allow us to carry out site analytics and customization, among other similar things. If you access the Services through your browser, you can manage your cookie settings there but if you disable some or all cookies you may not be able to use the Services.  Here sets and accesses our own cookies on the domains operated by Here and its corporate affiliates. In addition, we use third parties like Google Analytics for website analytics. You may opt-out of third party cookies from Google Analytics on its website. We do not currently recognize or respond to browser-initiated Do Not Track signals as there is no consistent industry standard for compliance.
• Log Information. We also collect log information when you use our website, such as:

• details about how you’ve used our services;
• device information, such as your web browser type and language;
• access times;
• pages viewed;
• IP address;
• identifiers associated with cookies or other technologies that may uniquely identify your device or browser; and
• pages you visited before or after navigating to our website.

Information We Collect from Third Parties

We may collect information about you from other users, our affiliates, and third parties. This might be aggregate level information, such as which IP addresses go with which zip codes, or it might be more specific information, such as about how well an online marketing or email campaign performed.

To provide YouTube functionality for search and playback within Here, Here uses YouTube's API Services. By using this functionality, you are subject to the YouTube Terms of Service and Google Privacy Policy.

How We Use Information

What do we do with the information we collect? We use it to provide you with an amazing set of products and services that we relentlessly improve. Here are the ways we do that:

• develop, operate, improve, deliver, maintain, and protect our products and services.
• send you communications, including by email. For example, we may use email to respond to support inquiries or to share information about our products, services, and promotional offers that we think may interest you.
• monitor and analyze trends and usage.
• enhance the safety and security of our products and services.
• verify your identity and prevent fraud or other unauthorized or illegal activity.
• use information we’ve collected from cookies and other technology to enhance our services and your experience with them.
• enforce our Terms of Service and other usage policies and comply with legal requirements.

How We Share Information

We may share information about you in the following ways:

• With other Here users potentially including:

• information about you, such as your username, name, and avatar image.
• information about how you have interacted with our services
• any additional information you have directed us to share. For example, Here will share your information when you connect your Here account to a third-party app, and if you share information or content from Here to the third-party app.
• content you post in a Room (this will be shared only with users that have access to that Room).

• With our affiliates.
• With third parties. We may share information about you with service providers who perform services on our behalf,

• We may share information about you with business partners that provide services and functionality on our services.
• We may share information about you, such as device and usage information, to help us and others prevent fraud.
• We may share information about you for legal, safety, and security reasons. We may share information about you if we reasonably believe that disclosing the information is needed to:

• comply with any valid legal process, governmental request, or applicable law, rule, or regulation.
• investigate, remedy, or enforce potential Terms of Service violations.
• protect the rights, property, or safety of us, our users, or others.
• detect and resolve any fraud or security concerns.

• We may share information about you as part of a merger or acquisition. If Here.fm gets involved in a merger, asset sale, financing, liquidation or bankruptcy, or acquisition of all or some portion of our business to another company, we may share your information with that company before and after the transaction closes.

We may also share with third parties that provide services to us or perform business purposes for us aggregated, non-personally identifiable, or de-identified information.

Where we store your data

Here transfers, processes and stores data about you on servers operated by our hosting provider located in the United States of America. Your Personal Information may therefore be transferred to, processed and stored in a country different from your country of residence, and be subject to privacy laws that are different from those in your country of residence. Information collected within the European Economic Area (“EEA”) and Switzerland may, for example, be transferred to and processed by third parties referred to below that are located in a country outside of the EEA and Switzerland, where you may have fewer rights in relation to your Personal Information. By using the Service and providing us with your Personal Information, you are consenting to the transfer, processing and storage of your Personal Information in countries outside of your country of residence.

Security

We value your trust in providing us your Personal Information, thus we strive to use all commercially acceptable means of protecting it. However, no method of transmission over the internet, or method of electronic storage is 100% secure and reliable, and we cannot guarantee its absolute security. We encourage you to use precautions such as strong passwords and a password manager for our service, or two-factor authentication when using third party logins.

Third-Party Content and Integrations

Our services may contain third-party content and integrations. Examples include third-party integrations with Gif providers or media content providers. Through these integrations, you may be providing information to the third party as well as to Here. We are not responsible for how those third parties collect or use your information. As always, we encourage you to review the privacy policies of every third-party service that you visit or use, including those third parties you interact with through our services.

How Long We Keep Your Information

Here allows any user of a room to delete any content added to a room.  We currently do not record or save video chats.  

Here is a list of some of the information we store:

• We store your basic account information—like your name, phone number, and email address—until you ask us to delete them.
• We store location information for different lengths of time based on how precise it is and which services you use.
• We’re constantly collecting and updating information about the things you might like and dislike, so we can provide you with more relevant content.

If you ever decide to stop using Here, you can just email us to delete your account. We’ll also delete most of the information we’ve collected about you after you’ve been inactive for a while—but don’t worry, we’ll try to contact you first!

Keep in mind that, while our systems are designed to carry out our deletion practices automatically, we cannot promise that deletion will occur within a specific timeframe. There may be legal requirements to store your data and we may need to suspend those deletion practices if we receive valid legal process asking us to preserve content, if we receive reports of abuse or other Terms of Service violations, or if your account or content created by you is flagged by our automated systems for abuse or other Terms of Service violations. Finally, we may also retain certain information in backup for a limited period of time or as required by law.

California Residents

If you’re a California resident, you have certain privacy rights under California law, including the California Consumer Privacy Act of 2018 (“CCPA”). Our California Privacy Notice specifies these rights, check it out.

Children

Our services are not intended for—and we don’t direct them to—anyone under 13. And that’s why we do not knowingly collect personal information from anyone under 13. In addition, we may limit how we collect, use, and store some of the information of EU users between 13 and 16. In some cases, this means we will be unable to provide certain functionality to these users. If we need to rely on consent as a legal basis for processing your information and your country requires consent from a parent, we may require your parent’s consent before we collect and use that information.

Revisions to the Privacy Policy

We may change this Privacy Policy from time to time. But when we do, we’ll let you know one way or another. Sometimes, we’ll let you know by revising the date at the top of the Privacy Policy that’s available on our website and mobile application. Other times, we may provide you with additional notice (such as adding a statement to our websites’ homepages or providing you with an in-app notification).

California Privacy Notice

We’ve created this California Privacy Notice specifically for California residents (“Notice”). California residents have certain privacy rights as specified under California law, including the California Consumer Privacy Act of 2018 (“CCPA”). Our Privacy Policy and the privacy controls we offer to all users are in line with these laws--this Notice makes sure we cover the California-specific requirements. For example, all users can request a copy of their data, request deletion, and control their privacy settings in the app. For the full picture, check out our Privacy Policy.

We’ll start with a summary of your rights and get into the details later.

• You have the right to know whether we sell your data and opt-out of a sale if we do. Good news! We don’t sell your data.
• You have the right to receive an overview of the personal information we collect, how we use it, and who we share your data with.
• You can request access to your data, get a copy, and ask us to delete your personal information.
• Reach out to us to exercise your California rights, which you can do at ccpa@here.fm

By the way, we’ll update this Notice every 12 months and let you know when we’ve made updates consistent with our Privacy Policy .

Your Rights

Let’s start with your rights.

• Right to know what personal information we collect. You have the right to request details on the specific personal information we’ve collected about you. We provide this information in our Privacy Policy, but you can also get this information by contacting us. In addition, you can request a copy of your data.
• Right to know who we share your data with. We do not sell your data, but we do share your information with others for legitimate business purposes. For example, we use service providers to store and host your data.
• Right to deletion. You have the right to request deletion of your data, unless an exception applies. Examples of exceptions include when we need to keep data to meet legal obligations, detect fraud, investigate reports of abuse or other Terms of Service violations, or fix security issues. Once we’ve verified your request, we’ll delete your personal information (unless an exception applies) and will direct our service providers to do the same.
• Get a timely response. You have the right to make two free requests in any 12-month period. We will respond to your request within 45 days, and in more difficult cases we may extend our response time by another 45 days. Our support team is pretty great, so they tend to respond a lot quicker. The easiest way to get information is by following the instructions above, but you can also email privacy @ here.fm.
• Non-Discrimination. It goes without saying, but we will not hold it against you when you exercise any of your rights. In fact, we encourage you to review your privacy settings closely and reach out to us with your questions.

The easiest way to exercise your rights is by logging into your account so we can verify your identity. You can also email us, but then we’ll require some additional information to authenticate your identity and ownership of your account.

We Don’t Sell Your Data

We don’t sell your data.

Information We Collect

As detailed in our Privacy Policy, we collect personal information for a wide range of purposes, but the main reason we collect information is to offer you the best possible products and services. Privacy by design is the starting point. This means we make sure we don’t collect more information than necessary or collect information for purposes that are different, unrelated, or incompatible with what’s detailed in our Privacy Policy.

In the last 12 months, we’ve collected the following personal information:

1. Identifiers, such as your name, display name, postal address, unique personal identifier, online identifier, IP address, email address, username, or other similar identifiers. We mainly use these to offer our services, for example to create your account and send messages to your real friends.
2. Personal information categories listed in the California Customer Records provisions, such as your name, address, telephone number, payment number (last 4 digits only). Keep in mind that some personal information included in this category may overlap with other categories.
3. Characteristics of protected classifications under California or federal law, such as your gender and age. The main purpose for collecting this information is to verify your age, ensure you are eligible to use our services.
4. Internet or other electronic network activity information, such as session logs, search history, information on a consumer's interaction with a website, application, or advertisement.
5. Geolocation data, such as your physical location.
6. Electronic, visual, or similar information, such as Images and Files you uploaded to our Service.

We may collect this data when you provide it to us, when you use our services, or when we receive it from third parties. For more details on the sources, see the Information We Collect section in our Privacy Policy.

For your information, personal information does not include publicly available information from government records and de-identified or aggregated consumer information.

Sharing Your Information

We may share your personal information to a third party for a business purpose or at your direction. For example, we share your personal information with our data hosting and storage providers. We enter into agreements with our service providers in which they can only use your information for specific purposes and are required to ensure its confidentiality.