Privacy Policy
Genghis Technologies, LLC.
Last
Updated Apr 30, 2021
Hi there! Welcome to the website (the “
Site”) of
Genghis Technologies, LLC. , Inc. (dba “Speakeasy”), (“
Company,” “
we,”
“
us,” or “
our”). Through our mobile application (the
“
App”), we allow users to engage in audio conversations with friends and other people
around the world (such services, including
http://www.myspeakeasy.com (the “
Site”) and the
App, are referred to collectively in this Privacy Policy as the “
Service”).
This
Privacy Policy explains what Personal Data (defined below) we collect, how we use and share that data, and
your choices concerning our data practices. This Privacy Policy is incorporated into and forms part of our
Terms of Service.
Before using the Service or submitting any Personal Data to Company, please
review this Privacy Policy carefully and contact us if you have any questions. By using the Service, you
agree to the practices described in this Privacy Policy. If you do not agree to this Privacy Policy, please
do not access the Site or otherwise use the Service.
1.
PERSONAL DATA WE
COLLECT
We collect information that alone or in combination with other information
in our possession could be used to identify you (“
Personal Data”) as
follows:
Personal Data You Provide: We collect the following categories of
Personal Data from you when you use our Service, including when you sign up for an account, create or share
content, and message or communicate with others:
-
Information you provide: We
collect content, communications, and other information you provide, including when you sign up for an
account, create or share content, and message or communicate with others. To create and manage an account,
you may provide us with personal data, including your name, phone number, a photo of yourself, an email
address, and a username. We use your contact information to authenticate your account and keep it secure and
to communicate with you about the Service
-
Audio: Solely for the purpose of
supporting incident investigations, we temporarily record the audio in a room while the room is live. If a
user reports a Trust and Safety violation while the room is active, we retain the audio for the purposes of
investigating the incident, and then delete it when the investigation is complete. If no incident is
reported in a room, we delete the temporary audio recording when the room ends. Audio from (i) muted
speakers and (ii) audience members is never captured, and all temporary audio recordings are
encrypted.
-
Networks and connections: We collect information about the people,
accounts, and shows you are connected to and how you interact with them through our Service. If you choose
to upload, sync, or import device information to Speakeasy (such as contacts in your address book), we may
use this information to enhance your experience in various ways, including, but not limited to, notifying
you when a contact has joined the waitlist or the Service. In addition, other users who have your contact
information and have chosen to upload, sync, or import it from their device may be notified of when you join
our Service (e.g., so they can join your “welcome room”); they may be able to know the number of people on
the Service who have your number in their uploaded contacts, so that they can choose to invite people with
many friends already on the Service. Finally, may we use your list of contacts (if you choose to provide us
with access to them) to recommend other users you might want to follow and to recommend your account and
content to others.
-
Usage: We may choose to collect information about how you use our
Service, such as the types of conversations you engage in, content you share, features you use, actions you
take, people or accounts you interact with, and the time, frequency, and duration of your use.
-
Communication Data: We may choose to collect information when you contact us with questions
or concerns and when you voluntarily respond to requests for your opinion and feedback.
-
Social Media Data: We have pages on social media sites like Instagram, Facebook, Medium,
Twitter, Tiktok, and LinkedIn (“
Social Media Pages”). When you interact with our Social
Media Pages, we will collect Personal Data that you elect to provide to us, such as your contact details. In
addition, the companies that host our Social Media Pages may provide us with aggregate information and
analytics regarding the use of our Social Media Pages.
-
Payment Information: We may
offer certain portions of the Service for a fee, or allow you to transact with other users on the Service.
If applicable, we may prompt you to provide financial information necessary to ensure payments can be
processed by our payment processor, Stripe, Inc. (“Stripe”). Accordingly, in addition to this Privacy Policy
and our Terms of Service, information related to your payments or purchases is also processed according to
Stripe’s services agreement and privacy
policy.
Internet Activity Data: When you visit, use, and interact with the
Service, we may receive certain information about your visit, use, or interactions. For example, we may
monitor the number of people that visit the Service, peak hours of visits, which page(s) are visited, the
domains our visitors come from (e.g.,
google.com,
yahoo.com, etc.), and which browsers people use to access the Service
(e.g., Chrome, Firefox, Microsoft Internet Explorer, etc.), broad geographical information, and navigation
patterns. In particular, the following information is created and automatically logged in our
systems:
-
Log Data: Information that your browser automatically sends whenever
you visit the Site. Log Data includes your Internet Protocol address, browser type and settings, operating
system, the date and time of your request, how you interacted with the Site, and how you interacted with
mobile or email notifications.
-
Cookies Data: Please see the “Cookies” section below
to learn more about how we use cookies.
-
Device Data: Includes name of the device,
operating system, and browser you are using. Information collected may depend on the type of device you use
and its settings.
-
Usage Data: We collect information about how you use our Service,
such as the types of content that you view or engage with, the features you use, the actions you take, and
the time, frequency, and duration of your activities.
-
Location Data: We derive a
rough estimate of your location from your IP address.
-
Email Open/Click Data: We may
use pixels in email campaigns that allow us to collect your email and IP address as well as the date and
time you open an email or click on any links in the email.
Internet Activity
Data: When you visit, use, and interact with the Service, we may receive certain information
about your visit, use, or interactions. For example, we may monitor the number of people that visit the
Service, peak hours of visits, which page(s) are visited, the domains our visitors come from (e.g.,
google.com,
yahoo.com, etc.), and which
browsers people use to access the Service (e.g., Chrome, Firefox, Microsoft Internet Explorer, etc.), broad
geographical information, and navigation patterns. In particular, the following information is created and
automatically logged in our systems:
-
Log Data: Information that your browser
automatically sends whenever you visit the Site. Log Data includes your Internet Protocol address, browser
type and settings, operating system, the date and time of your request, and how you interacted with the
Site.
-
Cookies Data: Please see the “Cookies” section below to learn more about how
we use cookies.
-
Device Data: Includes name of the device, operating system, and
browser you are using. Information collected may depend on the type of device you use and its
settings.
-
Usage Data: We collect information about how you use our Service, such as
the types of content that you view or engage with, the features you use, the actions you take, and the time,
frequency, and duration of your activities. We only store audio from conversations if a user reports an
incident during a conversation; otherwise all audio is deleted.
-
Email Open/Click
Data: We may use pixels in email campaigns that allow us to collect your email and IP address
as well as the date and time you open an email or click on any links in the
email.
Personal Data Collected from Third Parties/Publicly Available
Sources:
When you create your account, and/or authenticate with a third-party
service like Twitter, we may collect, store, and periodically update information associated with that
third-party account, such as your lists of friends or followers. We will never publish something through one
of your third-party accounts without your express permission.
Derived Data: We
may infer your preferences for content and features of the Service, or future products and services, based
on the Personal Data we collect about you.
Cookies: We may use cookies to
operate and administer our Site, gather usage data on our Site, and improve your experience on it. “Cookies”
are small text files containing a string of characters that can be placed on your computer or mobile device
that uniquely identifies your browser or device. Cookies can be stored on your computer or mobile device for
different periods of time. Some cookies expire after a certain amount of time, or upon logging out (session
cookies), others survive after your browser is closed until a defined expiration date set in the cookie (as
determined by the third-party placing it), and help recognize your computer or mobile device when you open
your browser and browse the Internet again (persistent cookies).
Cookies and other technologies
allow a site or services to know if your computer or device has visited it before. These technologies can
then be used to deliver products, services, and ads, help us understand how the site or service is being
used, help you navigate between pages efficiently, help remember your preferences, and generally improve
your experience in using our services. If you limit the ability of websites to set cookies, you may be
unable to access certain parts of the Site and you may not be able to benefit from the full functionality of
the Site.
Advertising networks may use cookies to collect Personal Data. Most advertising
networks offer you a way to opt out of targeted advertising. If you would like to find out more information,
please visit the Network Advertising Initiative’s online resources at
http://www.networkadvertising.org and follow the opt-out
instructions there.
If you access the Site on your mobile device, you may not be able to control
tracking technologies through the settings.
Analytics: We use Google Analytics,
a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help us
analyze how users use the Site and enhance your experience when you use the Site. For more information on
how Google uses this data, go to
www.google.com/policies/privacy/partners/.
Online
Tracking and Do Not Track Signals: We and our third-party service providers may use cookies,
pixels, or other tracking technologies to collect information about your browsing activities over time and
across different websites following your use of the Site and use that information to send targeted
advertisements. We make reasonable commercial efforts to recognize and support “Do Not Track”
signals.
2.
HOW WE USE PERSONAL DATA
We may use Personal Data for
the following purposes:
- To provide the Service;
- To create your account, facilitate
network connections, recommend content, and further personalize the Service for you;
- To respond to
your inquiries, comments, feedback, or questions;
- To send administrative information to you, for
example, information regarding the Service and changes to our terms, conditions, and policies;
- To
analyze how you interact with our Service;
- To maintain and improve the Service;
- To develop new
products and services;
- To authenticate your account and keep it secure;
- To enforce our Terms
of Service;
- To prevent spam, fraud, abuse, criminal activity, or misuses of our Service, and to
ensure the security of our IT systems, architecture, and networks; and
- To comply with legal
obligations and legal process and to protect our rights, privacy, safety, or property, and/or that of our
affiliates, you, or other third parties.
Aggregated Information. We may
aggregate Personal Data and use the aggregated information to analyze the effectiveness of our Service, to
improve and add features to our Service, and for other similar purposes. In addition, from time to time, we
may analyze the general behavior and characteristics of users of our Service and share aggregated
information like general user statistics with prospective business partners. We may collect aggregated
information through the Service, through cookies, and through other means described in this Privacy
Policy.
3.
SHARING AND DISCLOSURE OF PERSONAL DATA
Company does not
sell your Personal Data. In certain circumstances we may share the categories of Personal Data described
above without further notice to you, unless required by the law, with the following categories of third
parties:
-
Vendors and Service Providers: To assist us in meeting business
operations needs and to perform certain services and functions, we may share Personal Data with vendors and
service providers, including providers of hosting services, audio applications and infrastructure, cloud
services, and other information technology services providers, event management services, email
communication software and email newsletter services, advertising and marketing services, payment
processors, customer relationship management and customer support services, and web analytics services.
Pursuant to our instructions, these parties will access, process, or store Personal Data in the course of
performing their duties to us. We take commercially reasonable steps to ensure our service providers adhere
to the security standards we apply to your Personal Data.
-
Business Transfers: If we
are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership,
sale of all or a portion of our assets, or transition of service to another provider (collectively a
“Transaction”), your Personal Data and other information may be shared in the diligence process with
counterparties and others assisting with the Transaction and transferred to a successor or affiliate as part
of that Transaction along with other assets.
-
Legal Requirements: If required to do
so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation,
including to meet national security or law enforcement requirements, (ii) protect and defend our rights or
property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of users of
the Service, or the public, or (v) protect against legal liability.
-
Other Users:
certain actions you take may be visible to other users of the Service. For example, when you upload profile
photos or update information in your profile, other users will have access to this content and
information.
4.
DATA RETENTION
We keep Personal Data for as long as
reasonably necessary for the purposes described in this Privacy Policy, while we have a business need to do
so, or as required by law (e.g. for tax, legal, accounting, or other purposes), whichever is
longer.
5.
UPDATE YOUR INFORMATION
Please log in to your account or
contact us (at
support@myspeakeasy.com) if you need to change
or correct your Personal Data, or if you wish to delete your account.
6.
CALIFORNIA
PRIVACY RIGHTS DISCLOSURES
Where provided for by law and subject to any applicable
exceptions, California residents may have the right:
- To know the categories of Personal Data
that Company has collected about you, the business purpose for collecting your Personal Data, and the
categories of sources from which the Personal Data was collected;
- To access the specific pieces of
Personal Data that Company has collected about you;
- To know whether Company has disclosed your
Personal Data for business purposes, the categories of Personal Data so disclosed, and the categories of
third parties to whom we have disclosed your Personal Data;
- To have Company, under certain
circumstances, delete your Personal Data; and
- To be free from discrimination related to the exercise
of these rights.
If you would like to exercise any or all of these rights, you may do so by
contacting us at
support@myspeakeasy.com. Your authorized agent
may submit requests in the same manner. Once we receive your request, we will verify your identity by
sending an email to the email address you provide to us.
Please contact us if you have questions
about your rights or our disclosures under the CCPA, or to request access to an alternative format of this
Privacy Policy.
7.
CHILDREN
Our Service is not directed to
individuals who are under the age of 18. Company does not knowingly collect Personal Data from individuals
under the age of 18. If you have reason to believe that an individual under the age of 18 has provided
Personal Data to Company through the Service please contact us and we will endeavor to delete that
information from our databases.
8.
LINKS TO OTHER WEBSITES
The
Service may contain links to other websites not operated or controlled by Company, including social media
services (“Third-party Sites”). The information that you share with Third-party Sites will be governed by
the specific privacy policies and terms of service of the Third-party Sites and not by this Privacy Policy.
By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the
Third-party Sites directly for information on their privacy practices and policies.
9.
SECURITY
You use the Service at your own risk. We implement commercially
reasonable technical, administrative, and organizational measures to protect Personal Data both online and
offline from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no
Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from us
may not be secure. Therefore, you should take special care in deciding what information you send to us via
the Service or e-mail. Please keep this in mind when disclosing any Personal Data to Company via the
Internet. In addition, we are not responsible for circumvention of any privacy settings or security measures
contained on the Service, or third-party websites. Finally, we cannot control the actions of users on the
platform, who may seek to use third-party apps or devices to record, store, or share content or
communication without other users' prior consent. Please keep this in mind when using the
Service.
10.
INTERNATIONAL USERS
By using our Service, you
understand and acknowledge that your Personal Data will be transferred from your location to our facilities
and servers in the United States, and where applicable, to the servers of the technology partners we use to
provide our Service.
11.
YOUR CHOICES
In certain circumstances
providing Personal Data is optional. However, if you choose not to provide Personal Data that is needed to
use some features of our Service, you may be unable to use those features. You can also contact us to ask us
to update or correct your Personal Data. You may also delete your account. Please note that we will need to
verify that you have the authority to delete the account and certain activity generated prior to deletion
may remain stored by us and may be shared with third parties as detailed in this Privacy
Policy.
12.
CHANGES TO THE PRIVACY POLICY
The Service and our
business may change from time to time. As a result, we may change this Privacy Policy at any time. When we
do we will post an updated version on this page, unless another type of notice is required by the applicable
law. By continuing to use our Service or providing us with Personal Data after we have posted an updated
Privacy Policy, or notified you by other means if applicable, you consent to the revised Privacy Policy and
practices described in it.
13.
CONTACT US
If you have any questions
about our Privacy Policy or information practices, please feel free to contact us anytime via e-mail at
support@getspeakeasy.com.
Thank you!