EchoLine Support
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Privacy Policy
Effective date: June 04, 2024
1. INTRODUCTION
This Privacy policy (“Policy”) is an integral part of the Terms of Use available here: https://www.echoline.app/terms-of-use (“Agreement”). Any definitions herein shall have the same meaning as in the Agreement, unless otherwise stated. Here at Echoline we want to provide You with good, quality services and we understand how it is important for You to keep Your “privacy – private”. This Policy is designed to outline the main principles and features of our data collection and use and to give you a comprehensive overview of the practices used. By using any of our Services, you acknowledge the privacy practices we describe in this Policy.
By using the Service, you agree that collection and processing of your data will be covered by the terms of this Policy. In some circumstances, we may provide you with additional or supplemental privacy notices to the extent they apply to you because of the products and services You obtain from us or different laws that may apply to you.
We designed this Police keeping in mind the best practices described by the privacy experts, and we aimed to cover all the disclosure required by the state legislations (The California Privacy Rights Act of 2020 – California residents, Va. Code §§ 59.1-575—59.1-585. – for Virginia residents, and so on), however we acknowledge that these legislations are often amended and the new legislations for States being introduced. Therefore, if there are any legislation or regulation applicable to You which grant You a specific privacy right or entitle for the disclosure from 3rd parties, and it is not mentioned in this Policy – please feel free to contact us at legal@echoline.app, and we will gladly help You with execution of Your privacy rights. In any case, please, read this Policy carefully and if you have any ongoing questions about how to exercise your rights, etc.,
You may always contact us at support@echoline.app if You have any questions or concerns.
2. CHANGES TO THE POLICY
YOU EXPRESSLY AGREE THAT THIS POLICY MAY BE MODIFIED BY US AT ANY TIME AND AT OUR SOLE DISCRETION. We will use commercially reasonable efforts to generally notify You of any material changes to these Agreement, such as through a notice on our website, however, you should look at the Agreement regularly to check for such changes. We will also update the “Last Updated” date at the top of these Agreement, which reflect the effective date of such Agreement. Your continued access or use of the Application after the date of the new Agreement constitutes your acceptance of the new Agreement. If you do not agree to the new Agreement, you must stop accessing or using the Application.
3. CATEGORIES OF PERSONAL INFORMATION COLLECTED
In the preceding 12 month, we collected the following categories of personal information (for California residents we include reference to the CA Civ Code § 1798.140 (2022):
Some information from this list may be considered as sensitive information in accordance with the applicable legislation. This information is needed for us to provide you with services or engage in activities required from us (such as content moderation). Therefore, by accepting this Policy you agree for our collection and processing of your sensitive personal information and for the disclosure of the sensitive personal information to our partners where necessary to provide you with Services.
CATEGORY
TYPES OF DATA COLLECTED
PURPOSE
(A) Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
• unique personal identifier (User ID; Account ID)
• Online identifier
• IP address
• Email address
• Phone number
• To make available account creation within the Application
• To provide customer support services
• To analyses the functionality and availability of the Application
• To resist malicious, deceptive, fraudulent, or illegal actions directed at the business and to prosecute those responsible for those actions
(B) name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information or other information that identifies, relates to, describes, or is capable of being associated with, a particular individual.
• Country
• Region
• City
• Language
• To maintain in-App functionalities
• To analyses the functionality and availability of the Application
• To resist malicious, deceptive, fraudulent, or illegal actions directed at the business and to prosecute those responsible for those actions
(C) Characteristics of protected classifications under California or federal law (e.g. race, color, ancestry, national origin, sexual orientation, gender identity and expression, sex, pregnancy, childbirth and related medical conditions, religion, disability, age (for persons 40 and older), military or veteran status, status as a victim of domestic violence, assault or stalking, genetic information, political affiliation or activities, medical or health conditions, marital status.
N/A
N/A
(D) Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
N/A
N/A
(E) Biometric information.
N/A
N/A
(F) Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website application, or advertisement.
• First in-App login
• Last in-App login
• Total number of the sessions
• Average usage time
• Device type
• OS and version
• Platform
• Device ID
• Content of in-app messages
• Contact list
• To maintain in-App functionalities
• To analyses the functionality and availability of the Application
• To record in-App events necessary to provide the Services
• To resist malicious, deceptive, fraudulent, or illegal actions directed at the business and to prosecute those responsible for those actions
(G) Geolocation data.
N/A
N/A
(H) Audio, electronic, visual, thermal, olfactory, or similar information.
N/A
N/A
(I) Professional or employment-related information.
N/A
N/A
(J) Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99).
N/A
N/A
(K) Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
N/A
N/A
(L) Sensitive information (a) consumer’s Social Security or other state identification number; (b) a consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; (c) consumer’s geolocation; (d) consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership; (e) the contents of a consumer’s mail, email, or text messages, unless the business is the intended recipient of the communication; and (f) consumer’s genetic data.
• First & last consumer’s account log-in
• Password
• To perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services;
• To prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted personal information;
• To resist malicious, deceptive, fraudulent, or illegal actions directed at the business and to prosecute those responsible for those actions;
• To verify or maintain the quality or safety of Services;
4. CATEGORIES OF SOURCES FROM WHICH YOUR PERSONAL INFORMATION IS COLLECTED
We may collect the personal information from the following sources:
- Directly from You – we collect Your personal information when you provide is through interaction with our Application or customer support (for e.g. – email & password data, billing details);
- Automatically from You – we collect Your personal information when you register and/or log-in to the Application (for e.g. – in-App events, device details, information about Application usage, etc.);
5. PERSONAL INFORMATION SELL, SHARE AND DISCLOSURE
We do not sell or share any of Your Personal information. By “selling” personal information we referred to any of the following: selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to a third party for monetary or other valuable consideration. By “sharing” personal information we referred to any of the following sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by us to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged
However, we may disclose some of your personal information to our contractors or services providers (“3rd Parties”) if this is needed for the performance of the Services. Usually, it is done in aggregated or un-identifiable way so that such 3rd parties is provided only on “need-to-have” basis. Here are the 3rd Parties we work with:
CONTRACTOR
SERVICES
LOCATION
PRIVACY POLICY
Twilio Inc.
Cloud communications service provider/ telecommunication services outsource
U.S.A.
Apple Inc.
Cloud storage provider (for iOS devices)
U.S.A.
Amazon.com Inc.
Cloud storage provider
U.S.A.
Amplitude Inc.
Analytics service provider
U.S.A.
Castle Global, Inc.
Inappropriate content tagging
U.S.A.
We do not sell or share any of Your Sensitive Personal information, but we may disclose it to the 3rd Parties if this is inline with purpose of its collection.
We rely on the 3rd party services provider - Twilio Inc. to provide our Services. We do not run live monitoring of the content produced/received through the Application; however, we need to have access to Your content produced/received through the Application to comply with several purposes outlined below. You understand, acknowledge, agree and give your consent to the collection, processing, storing, and monitoring the content of all messages You receive using phone numbers you got via the App, by Us and the Twilio Inc. for the following purposes:
- Revision of the adherence to the requirements set by the applicable laws, regulations, industry standards, as well as compliance with Our Terms of Use and as well as with Twilio Acceptable Use Policy and Twilio Messaging Policy.
- Prevention of spam, abuse, illegal and fraudulent activity;
- Assistance to the enforcement bodies during any kinds of investigations;
THIS CONDITIONS ARE CRUCIAL FOR THE PROVISION OF THE SERVICES IN CASE BY US. IF YOU DISAGREE WITH ANY OF THE ABOVEGIVEN – PLEASE DO NOT START USING THE SERVICES AND/OR DELET OUR APPLICATION.
The safety of the communication environment and proper tagging of inappropriate content forbidden by the Messaging policy is conducted by the content tagging and/or labeling services, artificial intelligence (AI)-based classification service “HIVE” run by the Castle Global, Inc. (https://thehive.ai/privacy). We may disclose the content of messages sent through the Application to HIVE for the purposes of content tagging and labeling services for the possible violations of our Policies, or for other purposes as deemed necessary by Us. For more information about the use of the data by the HIVE please visit: https://thehive.ai/privacy.
6. YOUR PRIVACY RIGHTS AND HOW TO USE THEM
You have specific privacy rights granted by the applicable legislation and regulations. Depending on the State You are residing at the scope and applicability of rights may vary. Typically, Your privacy rights are presented as follows:
- Right to Know What Personal Information is Being Collected;
- Right to access Personal Information;
- Right to Correct Inaccurate Personal Information
- Right to Delete Personal Information
- Right to Know What Personal Information is Sold or Shared and to Whom;
- Right to Opt Out of Sale or Sharing of Personal Information;
- Right to Limit Use and Disclosure of Sensitive Personal Information;
- Right of No Retaliation Following Opt Out or Exercise of Other Rights;
If you are would like to use any of your rights hereunder, such as: (1) request to know more about the categories and specific pieces of personal information we collect, use, disclose and sell, (2) request deletion of your personal information, (3) opt out of "sales" or “share” of your personal information (4) limit the usage of your sensitive information, (5) request the correction of inaccurate personal information and (6) not to be discriminated against for exercising these rights – you can contact us via the support@echoline.app or mail us to the following address: 16192 Coastal Highway, Lewes, DE 19958, or You can also contact us via: legal@echoline.app directly. Please note that we might require to verify your identity by asking you to provide some information about our interactions with You.
Please note that we might require to verify your identity by asking you to provide some information about our interactions with you.
The Shine the Light law in California, specified in Civil Code section 1798.83, mandates that specific businesses must address inquiries from California customers regarding their procedures for sharing personal information with third parties for the purpose of direct marketing. If you are interested in learning more about your rights under California Civil Code section 1798.83, please feel free to reach out to us at support@echoline.app
Please be advised that it may take us some time to process your requests. You may be also required to provide us some pieces of information necessary for us to identify that the person making the request is the consumer about whom we have collected information or is a person authorized by you to act on such consumer’s behalf.
If we receive your request from an authorized agent, we may ask for evidence that you've provided such agent with a power of attorney, or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. If you're an authorized agent seeking to make a request, please contact us as set out above.
7. LOCATION AND DURATION FOR PROCESSING
Your data will be retained for the duration of your use of our Services, until such time as you and Echoline mutually agree to terminate your usage, including actions such as account deletion, blocking, or suspension, thereby preventing further use of the Application. We will cease processing your personal information unless specific legal requirements necessitate a longer storage period for such data.
Upon termination of your profile or after two years of continuous inactivity, we endeavor to delete or anonymize your information. However, there may be exceptions, such as when:
- We are obligated to retain your data to comply with applicable laws.
- We need to maintain your data to demonstrate compliance with relevant laws.
- There is an ongoing issue, claim, or dispute necessitating the retention of relevant data until resolution.
- Your data must be retained for our legitimate business interests, such as fraud prevention and enhancing user safety and security.
Please note that even after your account and data are deleted from our Services, copies may still exist if shared with others or stored by third parties. We cannot control this and disclaim any responsibility for such instances. Additionally, if you have granted third-party applications or websites access to your data, they may retain it according to their own privacy policies.
Our servers are located in the United States (USA) and the European Union (EU), which means your data may be processed and hosted outside the EU. For users in the EU and the UK, we primarily utilize EU-based servers for data collection and processing, while data from users in other countries is collected and processed on our USA-based servers. If you are located outside the United States, your information is initially collected in your country and subsequently transferred to the United States or another country where we (or our affiliates or service providers) operate.
8. AGE LIMITATION
We do not knowingly process personal data from persons under 18 years of age. If you learn that anyone younger than 18 has provided us with personal data, please contact us at legal@echoline.app
9. “DO NOT TRACK” SIGNALS
Except as otherwise stipulated in this Privacy Policy, the Service does not support “Do Not Track” requests.
10. CONTACT US
Mnboost Corp.
16192 Coastal Highway, Lewes, DE 19958
Mnboost Ltd.
7 Florinis, Greg Tower, 2nd Floor, 1065 Nicosia, Republic of Cyprus