Privacy Policy

OPAL provides a social platform via the OPAL website (the “Site”), the OPAL application (the “App”) and related Internet services (collectively, the “Service(s)”). The Service is operated by IOHQ. (the “Company”, “we” or “us”) for users of the Service (“you”). This Privacy Policy sets forth our policy with respect to information that is collected from visitors to the Site and users of the App and/or the Services. Under applicable law, IOHQ is the “data controller” of personal data collected through the Services.

INFORMATION WE COLLECT

When you interact with us through the Services, we may collect information from you, as further described below:

We collect information from you when you voluntarily provide such information, such as when you register for access to the Services or use certain Services. Information we collect may include but not be limited to username, email address, and any messages, images, transient VOIP data (to enable communication delivery only) or other content you send via the chat feature.

OTHER INFORMATION

Data We Collect Automatically: When you interact with us through the Services, we receive and store certain information such as an IP address, Browser identification, device ID, and your activities within the Services. We may store such information or such information may be included in databases owned and maintained by affiliates, agents or service providers. The Services may use such information and pool it with other information to track, for example, the total number of visitors to our Site, the number of messages users have sent, as well as the sites which refer visitors to OPAL.

Aggregated Information: In an ongoing effort to better understand and serve the users of the Services, we may conduct research on our user demographics, interests and behavior based on the information collected. This research may be compiled and analyzed on an aggregate basis. We may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes. This data is completely anonymous. No user avatars, usernames or real names are disclosed in these statistics.

Info through other Services: You may give us permission to collect your information in other services. For example, you may connect a social networking service ("SNS") such as Facebook or Twitter to your OPAL account. When you do this, it allows us to obtain information from those accounts (for example, your friends or contacts). This data is stored with your account only visible by you, unless permission is otherwise granted.

Cookies: We employ cookies, localStorage and similar technologies to keep track of your local computer’s settings such as which account you have logged into and notification settings. Cookies are pieces of data that sites and services can set on your browser or device that can be read on future visits. We may expand our use of cookies to save additional data as new features are added to the Service. In addition, we use technologies such as web beacons and single-pixel gifs to record log data such as open rates for emails sent by the system.

Advertisements: You may see our Service advertised in other applications or websites. After clicking on one of these advertisements you will become a user of the Service. Advertising platforms, which include Twitter and Facebook (and whose SDKs are integrated within our Service), may collect information for optimizing advertising campaigns outside of the Service.

If you do not wish to receive personalized advertising that is delivered by third parties outside of the OPAL Service, you may be able to exercise that choice through opt-out programs that are administered by third parties, including the Network Advertising Initiative (NAI), the Digital Advertising Alliance (DAA). Our Services currently do not respond to “Do Not Track” (DNT) signals and operate as described in this Privacy Policy whether or not a DNT signal is received, as there is no consistent industry standard for compliance.

WHERE INFORMATION IS PROCESSED

The Company is based in the United States. No matter where you are located, you consent to the processing and transferring of your information in and to the U.S. and other countries. The laws of the U.S. and other countries governing data collection and use may not be as comprehensive or protective as the laws of the country where you live.

OUR USE OF YOUR INFORMATION

We use the information you provide in a manner that is consistent with this Privacy Policy. If you provide information for a certain reason, we may use the information in connection with the reason for which it was provided. For instance, if you contact us by email, we will use the information you provide to answer your question or resolve your problem. Also, if you provide information in order to obtain access to the Services, we will use your information to provide you with access to such services and to monitor your use of such services. The Company and its subsidiaries and affiliates (the “Related Companies”) may also use your information collected through the Services to help us improve the content and functionality of the Services, to better understand our users and to improve the Services. The Company and its affiliates may use this information to contact you in the future to tell you about services we believe will be of interest to you. If we do so, each marketing communication we send you will contain instructions permitting you to "opt-out" of receiving future marketing communications. In addition, if at any time you wish not to receive any future marketing communications or you wish to have your name deleted from our mailing lists, please contact us as indicated below.

OUR LEGAL BASES FOR HANDLING OF YOUR PERSONAL DATA

The laws in some jurisdictions require companies to tell you about the legal ground they rely on to use or disclose your personal data. To the extent those laws apply, our legal grounds are as follows:

To honor our contractual commitments to you: Much of our processing of personal data is to meet our contractual obligations to our users, or to take steps at users’ request in anticipation of entering into a contract with them. For example, we handle personal data on this basis to create your account and provide our Services.

In many cases, we handle personal data on the ground that it furthers our legitimate interests in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals: This includes:

• Providing a safe and enjoyable user experience;
• Customer service;
• Marketing, e.g. sending emails or other communications to let you know about new features;
• Protecting our users, personnel, and property;
• Analyzing and improving our business, e.g. collecting information about how you use our Services to optimize the design and placement of certain features;
• Managing legal issues.
• Legal compliance: We need to use and disclose personal data in certain ways to comply with our legal obligations.
• To protect the vital interests of the individual or others: For example, we may collect or share personal data to help resolve an urgent medical situation.
• Consent: Where required by law, and in some other cases, we handle personal data on the basis of your implied or express consent.

OUR DISCLOSURE OF YOUR INFORMATION

The Company is not in the business of selling your information. We consider this information to be a vital part of our relationship with you.However, we may disclose your information 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, (ii) protect and defend the rights or property of the Company or Related Companies, (iii) protect the personal safety of users of the Services or the public, or (iv) protect against legal liability.

CHILDREN

Our Services are for users age 13 and over and we do not knowingly collect personal information from children under the age of 13. If you are a parent or guardian of a child under the age of 13 and believe he or she has disclosed personal information to us please contact us at dis.gd/request and select "Parent of a user" as your report type option. Note: In some countries, the age of digital consent is older than 13. If you are in those countries, you must be at least that age to use the Services. For example, for residents of the EEA, where processing of personal information is based on consent, OPAL will not knowingly engage in that processing for users under the age of consent established by applicable data protection law. If we learn that we are engaged in that processing with such users, we will halt such processing and will take reasonable measures to promptly remove applicable information from our records.

LINKS TO OTHER WEB SITES

This Privacy Policy applies only to the Services. The Services may contain links to other web sites not operated or controlled by us (the “Third Party Sites”). The policies and procedures we described here do not apply to the Third Party Sites. The links from the Services do not imply that we endorse or have reviewed the Third Party Sites. We suggest contacting those sites directly for information on their privacy policies.

DATA RETENTION

We generally retain personal data for so long as it may be relevant to the purposes identified herein. To dispose of personal data, we may anonymize it, delete it or take other appropriate steps. Data may persist in copies made for backup and business continuity purposes for additional time.

SECURITY

We take reasonable steps to protect the information provided via the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. In particular, email sent to or from the Services may not be secure. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing any information via the Internet.

CHANGES TO THIS PRIVACY POLICY

We reserve the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Please review this policy periodically, and especially before you provide any information. This Privacy Policy was last updated on the date indicated above. Your continued use of the Services after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.