TELL WEBSITE AND MOBILE APPLICATION PRIVACY POLICY

Tell Technologies, Ltd. (“Tell”) is concerned about privacy issues and wants you to be familiar with how we collect, use and disclose information. This Privacy Policy describes our practices in connection with information, including Users’ Story information, that we collect through websites operated by us from which you are accessing this Privacy Policy (the “Site”), through the software applications made available by us for use on or through computers and mobile devices (the “Apps”), through any software, data feeds, widgets, materials, content and any other services available on or through the Site and/or App, and through HTML-formatted email messages that we send that link to this Privacy Policy (collectively, including the Websites and Apps, the “Service” or “Services”). By providing Personal Information to us, you agree to the terms and conditions of this Privacy Policy.
When you use the Services and others that Tell may offer in the future, you’ll be sharing some information with us, and that affects your privacy. This privacy policy (“Privacy Policy”) explains how and when Tell may collect, store, use and share your information when you use or access the Services. For purposes of this Privacy Policy, the terms “we,” “us” and “our” refer to Tell. “You” refers to you, as a user of the Services. If you are using the Services on behalf of an organization or company then the term “You” shall be deemed to include such organization or company.

PLEASE SEE BELOW FOR OUR POLICY REGARDING OUR COLLECTION OF INFORMATION FROM CHILDREN.

By using the Services, you understand and agree that we are providing a platform for you to post content to the Services that will be made available publicly. Examples of content that will be publicly available on the Services include, but are not limited to, any story audio files, photographs, text or data included in the story, story meta-data, comments and any other user-generated content that may be collected and uploaded by you, Tell or third party partners. That means that other users of the Services and the general public may search for, see, use or share your content that you make available through the Services, consistent with the terms of this Privacy Policy and our Terms of Use

In order to access certain parts of the Services, Tell may require you to provide personally identifiable information. Personally identifiable information refers to information that, taken alone, identifies you and that can be used to contact you, online or offline (“Personally Identifiable Information”), which may include, for example, your first name, last name, email address, phone number, photograph, username and the contents of any story (as defined in the “Original Content” section of our Terms of Use) you submit.

Tell collects non-personally identifiable information from you as part of the Services. Non-personally identifiable information refers to information about you that cannot be used alone to identify you (“Non-Personally Identifiable Information”), which may include, for example, your location and other demographic information, and information about your use of our Services, which may include, for example, internet connection, your Internet Protocol (“IP”) address and other device identifiers. Aggregated data is considered Non-Personally Identifiable Information for the purposes of this Privacy Policy.

Account Information
When you create an account, you will provide information that could be Personally Identifiable Information (e.g. your username, email address, phone number and photograph) or Non-Personally Identifiable Information (e.g. your gender, hobbies, favorite activities, occupation and any other information you choose to disclose). If you sign into the Services through your Facebook or Google account, we will have access to any information on your account that you grant us permission to, such as your username, photos, and email address.

User Content
Some features of the Services allow you to submit User Content. As Tell seeks to build and share a lasting archive of humanity’s stories, User Content is information that you choose to be made public and non-confidential. When you share User Content via the Services, you should think carefully about what you are making public. You may change your story privacy settings on the Services to make your information more private.

Original story Content
Your account may also contain Original stories (as defined in “Original Content” of the Terms of Use) and related Original story Content. This Original story Content is also public and non-confidential. You may change your story privacy settings on the Services to make your information more private.

Activity
When you use our Services, we may collect information about your activity on the Services, such as story selections and viewing history

Location
When you use our Services, we may collect information about your location. With your consent, 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. You typically have to choose to turn such services on or off. If such device-based location services are on, we may receive and record such information, such as the location where you are creating or uploading User Content.

Camera, photos and audio
Some of the Services allow us to collect images and/or audio from your device’s App, camera and camera roll. For example, you may upload User Content by providing us access to your camera roll for photos and other applications containing the story audio file. IP Address Information and Other Information Collected Automatically. We automatically receive and record certain information from your web browser when you access and use the Services, which may include your IP address, cookie information, hardware model, operating system version, unique device identifiers and mobile network information (including the mobile phone number).

IP Address Information and Other Information Collected Automatically
We automatically receive and record certain information from your web browser when you access and use the Services, which may include your IP address, cookie information, hardware model, operating system version, unique device identifiers and mobile network information (including the mobile phone number).

“Cookies” are small data files that are sent to your web browser when you access a website, and the files stored on your device’s hard drive. We use “session” cookies to keep you logged in while you use our Services, to track your preferences and to track trends and monitor usage and web traffic information on our Services. We may use “persistent” cookies to relate your use of our Services to other information about you and store information about your preferences to make your user experience consistent and customized. For example, we may create a persistent cookie that includes some basic information about you, like whether customer support responded to your inquiry. These cookies stay on your hard drive until you erase them or they expire and associate your information with your account even if you are logged out. Most browsers automatically accept cookies, but you can change your settings on the browser settings to refuse cookies or prompt you before accepting cookies. You can also use your browser settings or other tools to delete cookies you already have. However, if you disable or refuse cookies, then certain features of our Services may be inaccessible or not function properly.
Our cookies do not, by themselves, contain Personally Identifiable Information, and we do not combine the general information collected through cookies with other Personally Identifiable Information to tell us who you are. As noted, however, we do use cookies to identify that your web browser has accessed aspects of the Services and may associate that information with your account if you have one.
We may also use “clear GIFs” (aka “web beacons” or “pixel tags”) or similar technologies on our Services or in our communications with you to enable us to know whether you have visited a part of our Services or received a message. A clear GIF is typically a one-pixel, transparent image (although it can be a visible image as well), located on a website or in an email or other type of message, which is retrieved from a remote website on the Internet enabling the verification of an individual’s viewing or receipt of a website or message. We may also log information using digital images called web beacons on our Services or in our emails. We may use web beacons to manage cookies, count visits, and to learn what marketing works and what does not. We may also use web beacons to tell if you open or act on our emails. We do not track our users across third party websites and thus do not respond to Do Not Track (“DNT”) signals.
This Privacy Policy only covers our use of cookies and does not cover the use of cookies by third parties. We do not control when or how third parties place cookies on your computer. For example, third party websites to which a link points may set cookies on your computer. Information Collected for Push Notifications. When you access the Services through a mobile device, you will also be asked to allow push notifications to be sent to you outside or inside of the App. If you do so, a device token will be generated, which is associated with you until you log out. We will collect and store these device tokens on our servers.

When you access the Services through a mobile device, you will also be asked to allow push notifications to be sent to you outside or inside of the App. If you do so, a device token will be generated, which is associated with you until you log out. We will collect and store these device tokens on our servers.

Any information or content that you voluntarily disclose for posting to the Service, including User Content, becomes available to the public and may be re-shared by others. Subject to your story privacy settings, any story Content that you make public is searchable by other users of the Services and the general public. So, the same common sense that applies to the internet at large applies to Tell and your use of the Service: do not send any messages or share any content that you do not want someone else to save or share.
You may change your privacy settings for your stories and associated story Content (as defined in “Story Privacy Settings” section of our Terms of Use) through your account to make your story Content more private.

If you choose this setting, your story and associated story Content will be public and accessible by anyone.

The default setting for a story is “Tell Registered Users”. Only people with a registered account on the Services can view or access your story and associated story Content. Your story and associated story Content will not be accessible by the general public.

Only you can view or access your story and associated story Content. Your story and associated story Content will not be accessible by the general public or other users of the Services if you choose to make your story private.
Please note that even if you change your story privacy settings on your account, your story Content, including any associated photographs, audio and information, can still be accessed and used by Tell and its partners, funders and sponsors, licensees and researchers for research purposes and any other [non-commercial] purpose.
Also, please be aware that your account profile will remain visible to other users of the Services and the general public regardless of your story privacy settings.

Tell is a story-sharing platform, and we will use the information we collect to provide you with products and services to improve such products and services. Tell will always have access to the Personally Identifiable and Non-Personally Identifiable Information on your account regardless of your story privacy settings and may use your information to maintain and provide the Services to you. For example, we may use your information, in either aggregated or individual form, in the following ways:

• to generally manage individual information and Accounts;
• to respond to questions, comments, and other requests;
• to provide access to certain areas, functionalities, and features of Tell’s Services;
• to archive and share stories with other people, including with other users of the Services by sharing and displaying your username, photograph, location and, depending on your story privacy settings, your audio recording and metadata in connection with any User Content you upload to the Site or App;
• to share with our third party partners in order to provide you with a service you use or request. For example, Tell may share your Personally Identifiable Information and story Content with third parties for data storage and hosting. This Section applies to any and all third party websites, services and applications that you access through the Services or that are used or will be used by Tell to provide the Services, even if not expressly named herein;
• to communicate with you and respond to you regarding the Services, content, features and products you use or that we think may interest you;
• to customize and optimize the content or advertisements you receive or view when you use the Services, and otherwise improve your experience on our Services;
• to provide, maintain, protect, analyze, understand and improve our Services, content, features and products, which may include tracking traffic, trends, usage and navigation patterns;
• to develop new services;
• for research and educational purposes;
• in any other way we may describe when you provide the information;
• for legal reasons, including, but not limited to, in response to a valid law enforcement request or legal process or to protect our rights and property or those of third parties;
• and for any other purpose with your consent.

If you have any questions regarding how we use your User Content, please contact us at cs@tellapp.com.

We may share your information as described in this Privacy Policy (e.g., with our third-party service providers; to comply with legal obligations; to protect and defend our rights and property) or with your permission.

• We Use Vendors and Service Providers. We may share any information we receive with vendors and service providers. The types of service providers (processors) to whom we entrust Personal Information include service providers for: (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) payment processing; (iv) customer service activities; and (v) in connection with the provision of the Site and App. Tell has executed appropriate contracts with the service providers that prohibit them from using or sharing Personal Information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.
• Business Partners. Tell may share Personal Information with our business partners and affiliates for our and our affiliates’ internal business purposes or to provide you with a service that you have requested. Tell may also provide Personal Information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you. In such cases, our business partner’s name will appear, along with Tell. Tell requires our affiliates and business partners to agree in writing to maintain the confidentiality and security of Personal Information they maintain on our behalf and not to use it for any purpose other than the purpose for which Tell provided them.
• Marketing – Interest-Based Advertising and Third-Party Marketing. Through our Services, Tell may allow third-party advertising partners to set tracking tools (e.g., cookies) to collect information regarding your activities (e.g., your IP address, page(s) visited, time of day). We may also share such de-identified information as well as selected Personal Information (such as demographic information and past purchase history) we have collected with third-party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit non-Tell related websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising. We may allow access to other data collected by the Site to facilitate transmission of information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer that we do not share your Personal Information with third-party advertising partners, you may opt-out of such sharing at no cost by following the instructions in Section 5 below.
• Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures). We may access, preserve, and disclose your Personal Information, other Account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect yours’, ours’ or others’ rights, property, or safety; (iv) to enforce Tell policies or contracts; (v) to collect amounts owed to Tell; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
• Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. In such an event, Tell will endeavor to direct the transferee to use Personal Information in a manner that is consistent with the Privacy Policy in effect at the time such Personal Information was collected.

In addition, from time to time, server logs may be reviewed for security purposes—e.g., to detect unauthorized activity on the Services. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.

All Personal Information collected via or by Tell may be stored anywhere in the world, including but not limited to the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to Tell, you consent to the storage of your Personal Information in these locations.

You have the right to opt out of certain uses and disclosures of your Personal Information. Where you have consented to Tell’s Processing of your Personal Information, you may withdraw that consent at any time and opt-out to further Processing by contacting cs@tellapp.com. Even if you opt-out, we may still collect and use non-Personal Information regarding your activities on our Sites and/or information from the advertisements on third-party websites for non-interest based advertising purposes, such as to determine the effectiveness of the advertisements.

If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt-out of receiving future emails. We will process your request within a reasonable time after receipt. Note that you will continue to receive transaction-related emails regarding Services you have requested. We may also send you certain non-promotional communications regarding Tell and our Services and you will not be able to opt out of those communications (e.g., communications regarding updates to our Terms or this Privacy Policy).

Tell may occasionally send you push notifications through our App with other notices that may be of interest to you. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device. Tell may also collect location-based information if you use our App. You may opt-out of this collection by changing the settings on your mobile device.

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, App users may opt out of certain mobile ads via their device settings.
The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, or www.youronlinechoices.eu/ and www.aboutads.info/choices/. You can also choose not to be included in Google Analytics chrome.google.com/webstore/detail/google-analytics-opt-out/fllaojicojecljbmefodhfapmkghcbnh?hl=en.
To be clear, whether you are using our opt-out or an online industry opt-out, these cookie-based opt-outs must be performed on each device and browser that you wish to have opted-out. For example, if you have opted-out on your computer browser, that opt-out will not be effective on your mobile device. You must separately opt-out on each device. Advertisements on third-party websites that contain the AdChoices link and that link to this Privacy Policy may have been directed to you based on anonymous, non-Personal Information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt-out of the advertising partners’ use of this information for interest-based advertising purposes.

You may inquire as to whether Tell is Processing Personal Information about you, request access to Personal Information, and ask that we correct, amend or delete your Personal Information where it is inaccurate. Where otherwise permitted by applicable law, you may send an e-mail to cs@tellapp.com or use any of the methods set out in this Privacy Policy to request access to, receive (port), seek rectification, or request erasure of Personal Information held about you by Tell. Please include your full name, email address associated with your Account, and a detailed description of your data request. Such requests will be processed in line with local laws.
Although Tell makes good faith efforts to provide individuals with access to their Personal Information, there may be circumstances in which Tell is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question or where it is commercially proprietary. If Tell determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, Tell will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.

Even if you change your story privacy settings through your account to be private, your story Content may still be retained by Tell and accessed by Tell and its partners, funders and sponsors, licensees, researchers and other third parties for research purposes and any other [non-commercial] purpose. If you remove information that you posted to the Services, copies may remain viewable in cached and archived pages of the Services, or if other users or third parties have copied or saved that information prior to removal.

If you wish to cancel your account or request that TELL no longer uses your information to provide Products or services, please send an email to help@tellapp.com. TELL will promptly delete the information as requested.
If you cancel your account and discontinue your use of the Services, we and our third-party partners may continue to retain story Content submitted, uploaded or otherwise provided by you prior to your cancellation of your account and/or discontinuance of your use of the Services.
If you have any questions regarding how your story Content may be retained or accessed, please contact us at cs@tellapp.com.

This Privacy Policy does not apply to the practices of third parties including any third party websites, services and applications that you access through the Services. We cannot take responsibility for the content or privacy policies of those third parties and encourage you to carefully review the privacy policies of any third parties websites, services and applications you access.

We have used reasonable efforts to help safeguard your information. However, we make no guarantee that these reasonable efforts will make your information completely secure. Please do your part to help us. You are responsible for maintaining the secrecy of your unique password and account information. Again, we encourage users to think carefully before electing to share content on the internet.

You must be at least 13 years of age or older to register to the Tell service. Minors may only use the service with the involvement, supervision, and approval of a parent or legal guardian.
We are sensitive to the privacy and child protection issues that arise from being provided with information that uniquely identifies an individual child: we do not wish to be put in a position whereby we hold that kind of information. Therefore, we strongly recommend that Users identify Children’ accounts by names that are anonymous or incomplete. Do not use children’s full names.
We do not knowingly collect, solicit or store Personally Identifiable Information from anyone under the age of 13 or knowingly allow such persons to register for the Services. If you are under 13, please do not attempt to register on the Services; no one under the age of 13 may provide any Personally Identifiable Information to the Company or on the Services.
In the event that we learn that we have collected Personally Identifiable Information from a child under age 13, we will delete that information where reasonably possible. If you believe that we might have any information from or about a child under 13, please send a detailed message to help@tellapp.com.

To support and enhance the Services, we may serve advertisements and allow third party advertisements through the Services. These advertisements are sometimes targeted and served to particular users and may come from third party companies called “ad networks.” Ad networks include third party ad servers, ad agencies, ad technology vendors and research firms.
Advertisements served through the Services may be targeted to users who fit a certain general profile category and may be based on (1) anonymized information inferred from information provided to us by a user, (2) usage patterns of particular users, or (3) your activity on a third party website. We do not provide Personally Identifiable Information to any ad networks for use outside of the Services.

As we continue to develop our business, we may sell, transfer or otherwise share your Personally Identifiable Information in connection with a merger, reorganization, bankruptcy or sale of either our company, Services, App or Site. In such transactions, customer information is often one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy Policy (unless the customer consents otherwise). You acknowledge and consent that such transfers are permitted by this Privacy Policy, and that any acquirer of ours or our current assets may continue to receive, store, and process your information as set forth in this Privacy Policy. You also consent to us providing access to your information as part of diligence or review processes conducted by potential acquirers, entities providing financing to them, their advisors, us and our advisors.

This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. It may be necessary from time to time for us to modify this Privacy Policy to reflect changes in the way we collect and use information or changes in privacy-related laws, regulations and industry standards. Accordingly, we reserve the right to change this policy at any time by posting the revised policy on the Services and updating the “last modified” date at the top of this page. We may provide you additional forms of notice of modifications or updates as appropriate under the circumstances. We encourage you to refer to this Privacy Policy on an ongoing basis so that you understand our current privacy policy. If revisions to the Privacy Policy are unacceptable to you, you must cease using the Services.

You may choose to request certain information regarding our disclosure of Personally Identifiable Information to third parties for their direct marketing purposes, choose to opt-out of such disclosure, or simply contact us with questions or suggestions regarding our Privacy Policy. To do so, please contact us at cs@tellapp.com or Tell, 85 Great Portland Street, London W1W 7LT, UK. Our policy is not to disclose Personally Identifiable Information collected online to a third party for direct marketing without your approval.