PRIVACY POLICY
Last updated January 31, 2023

The Babz mobile application (the “App”) is provided by Babz LLC. We respect your privacy and have designed the App with your privacy in mind. This Privacy Policy describes how we collect, use, and disclose personal information and what choices you have with respect to the information.

We may update or amend this Privacy Policy in our sole discretion. If we make material changes to this Privacy Policy, we will notify you either by sending a push notification to your smartphone or by notifying you when you log in to the App. Continued use of the App after any such changes to the Privacy Policy have been made shall constitute your consent to such changes. You are responsible for regularly reviewing the most current version of the Privacy Policy, which is
available in the App. When we change this Privacy Policy, we will modify the “Last Updated”date above.

INFORMATION WE COLLECT
We receive or collect various personal data and non-personal data when you install and use the App.
● Account Credentials. To use the App, you must create an account. When you create an account, we require you to provide your mobile phone number, as well as to select a unique username.
● Your Videos. When you record and send a video to other users of the App, the video will be viewable by the recipient(s). After the recipient(s) first react to your video (or a later video in the same conversation), it will be deleted from our servers within 24 hours. However, we may retain videos as necessary under applicable law.
● Customer Support. You may provide us with information related to your use of the App.For example, you may send us an email with information relating to the performance of the App or other issues.
● Device and Connection Information. When you install, access, or use the App, we collect information about your mobile device, such as hardware model, operating system information, IP address, mobile network information, and device identifiers. We may collect device location information for diagnostic and troubleshooting purposes.
● Tokens. We use tokens and similar technologies to keep you logged in to the App and to identify usage behavior to improve our services.
● Usage Logs. We collect service-related, diagnostic, and performance information. This may include information about your use of the App, log files, performance logs, and diagnostic reports.

HOW WE USE INFORMATION
We use personal data that we collect in the following ways:
● To identify you as a user in the App and to identify you as the sender when you send a video to one or more recipients through the App.
● To provide, update, support, and improve the App.
● To communicate with you, including to provide notifications. If you contact us, we may use your contact information to respond. We may also contact you to inform you about changes in the App, our product offerings, and important App-related notices, such as security and fraud notices. You can turn off notifications at any time in the App settings.
● To investigate and help prevent security issues and abuse.
● As otherwise required by applicable law or legal process.
We do not use your information to sign you up for any mailing lists or marketing lists. We do not provide your personal data to any third parties for direct marketing and we do not sell your personal data to any third parties.
We may use information that is aggregated or de-identified so that it is no longer reasonably associated with an identifiable natural person for any legitimate business purpose.

SHARING INFORMATION WITH THIRD PARTIES
We contract with certain third-party service providers in order to operate and provide features through the App. Those service providers may need access to your information, including personal data, to perform fulfillment and other services. We undertake to provide only that portion of your information needed to perform the pertinent service, and we require that all of our service providers
hold your information in confidence and use it only to provide the service for which they have been engaged.
You can find information about these service providers’ privacy policies and practices at the following URLs:

Service Provider Privacy Policy
Amazon Web Services https://aws.amazon.com/privacy/
Cloudinary https://cloudinary.com/privacy
Google https://policies.google.com/privacy
Twilio https://www.twilio.com/legal/privacy

We do not provide your contact information to third-party marketers without your permission. We may share your information when legally required to do so, at the request of governmental authorities conducting an investigation or by applicable law, rule or regulation, to verify or enforce compliance with our terms of service and any other policies governing the App, or to protect against misuse or unauthorized use of the App.

We also may disclose information whenever we believe disclosure is necessary to limit our legal liability; to protect or defend our rights or property; or protect the safety, rights, or property of our users or other third parties.

In the event of a merger, consolidation, or other corporate reorganization in which we participate or a sale of all or substantially all of our stock and/or assets, we may transfer your personal data to the successor entity or purchaser.

LINKS TO THIRD-PARTY CONTENT
We may provide links to websites, software, or services owned or operated by third parties (“ThirdParty Content”).

We are providing these links to you as a convenience, and we do not verify, make any representations, or take any responsibility for such Third-Party Content, including, without limitation, the truthfulness, accuracy, quality, or completeness of the content, products, services,
or information provided therein. The Third-Party Content may be subject to different privacy policies and business practices than the App. Your dealings and communications through the App with any party other than us are solely between you and such third party.

We encourage you to be aware when you leave the App to read the privacy policy of each and every website that collects personally identifiable information. This Privacy Policy applies solely to information collected by us.

INTERNATIONAL TRANSMISSION OF INFORMATION
The internet is a global environment. Your information may be transferred to and maintained on computers located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction.

By using the App and/or communicating electronically with us, you acknowledge and agree to our processing of your information in this manner, and agree to be bound by all applicable privacy laws.

SECURITY
We use a variety of physical, electronic, and procedural safeguards to protect your personal data.
However, no method of electronic storage or method of transmission over the internet or phone lines is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee the protection of any information against unauthorized access, disclosure, alteration, or destruction, or that any information may not be disclosed or accessed by accidental circumstances or by the unauthorized acts of others. Consequently, when you transmit your personal data to us, you do so at your own risk.
If you create an account via the App, your account information will be SMS code-protected. It is important for you to protect against unauthorized access to your username, as well as to your smartphone or other mobile device. We request that you not communicate any confidential or sensitive information to us through email, social media, or any other means.
If we learn of a security system breach, we may attempt to notify you electronically so that you can take appropriate protective steps. By using the App or providing personal data to us, you agree that we can communicate with you electronically regarding security and privacy issues related to the App. We will endeavor to provide notice to you of any security systems breach and efforts to restore the integrity of the App in accordance with applicable law. If you become aware of any breach of data security or have any other questions about the security of the App, please email us
at [email protected].
The security of personal data also depends in part on the security of the smartphone or mobile device you use to communicate with us, the security you use to protect usernames, and the security provided by your internet service provider or mobile carrier. We are not responsible for the security of your internet service provider or mobile carrier.

CHILDREN’S PRIVACY
The App is intended only for users 16 years of age or older. We do not knowingly collect personally identifiable information from anyone under the age of 16.

CALIFORNIA PRIVACY RIGHTS
This section applies solely to users of our App who reside in the State of California.
As a California resident, you are entitled to the following rights under the California Consumer Privacy Act in connection with your personal information:
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. After verifying your request, we will disclose to you:
● The categories of personal information we collected about you;
● The categories of sources for the personal information we collected about you;
● Our business or commercial purpose for collecting your personal information;
● The categories of third parties with whom we share your personal information;
● The specific pieces of personal information that we have collected about you;
● If we have disclosed your personal information for a business purpose, we will provide you with a list which will identify the personal information categories that each category of recipient obtained.

Deletion Rights
You have the right to request that we delete your personal information. Upon confirmation of your request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception under applicable law applies.
Non-Discrimination
You have the right not to be discriminated against for having exercised your rights under the applicable laws.
Exercising Your Rights
To exercise the specific rights described above in relation to your personal information, please submit your request to us at [email protected].
Only you, or a person authorized to act on your behalf, may make a request related to your personal information.
We cannot respond to your request or provide you with the requested personal information if we cannot verify your identity or authority to make the request and confirm that the personal information relates to you. We will only use the personal information provided in your request to verify your identity or authority to make the request.
We endeavor to respond to verifiable requests within 45 days of receipt. If we require more time (up to an additional 45 days), we will inform you of the reason and extension period in writing.
Any disclosures that we provide will only cover the 12-month period preceding receipt of your request. You can make a request for access only twice per 12-month period.
If we are unable to comply with your request, our response will explain the reasons for our inability to comply.
We do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will inform you of the reasons for such decision and provide you with a cost estimate before processing further your request.

GOVERNING LAW
This Privacy Policy is governed by the laws of the State of New York, without giving effect to any choice of law provision or rule. Any dispute arising in connection with this Privacy Policy must be filed in the state or federal courts located in New York.

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