Privacy

Last updated: Jul 18, 2023

This Privacy Policy applies to Ballroom services (the “Platform”), which include Ballroom apps, websites, software and related services accessed via any platform or device that link to this Privacy Policy. The Platform is provided and controlled by FRE Studios LLC. (“Ballroom”, “we” or “us”). We are committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, share, and otherwise process the personal information of users and other individuals age 18 and over in connection with our Platform.

What Information We Collect

We may collect information from and about you, including information that you provide, information from other sources, and automatically collected information.

Information You Provide

When you create an account, upload content, contact us directly, or otherwise use the Platform, you may provide some or all of the following information:

• Account and profile information, such as name, age, username, password, language, email, phone number, social media account information, and profile image.
• User-generated content, including comments, photographs, livestreams, audio recordings, videos, text, hashtags, and virtual item videos that you choose to create with or upload to the Platform (“User Content”) and the associated metadata, such as when, where, and by whom the content was created. Even if you are not a user, information about you may appear in User Content created or published by users on the Platform. When you create User Content, we may upload or import it to the Platform before you save or post the User Content (also known as pre-uploading), for example, in order to recommend audio options, generate captions, and provide other personalized recommendations. If you apply an effect to your User Content, we may collect a version of your User Content that does not include the effect.
• Messages, which include information you provide when you compose, send, or receive messages through the Platform’s messaging functionalities. They include messages you send through our chat functionality when communicating with merchants who sell goods to you, and your use of virtual assistants when purchasing items through the Platform. That information includes the content of the message and information about the message, such as when it was sent, received, or read, and message participants. Please be aware that messages you choose to send to other users of the Platform will be accessible by those users and that we are not responsible for the manner in which those users use or share the messages.
• Information, including text, images, and videos, found in your device’s clipboard, with your permission. For example, if you choose to initiate information sharing with a third-party platform, or choose to paste content from the clipboard onto the Platform, we access this information stored in your clipboard in order to fulfill your request.
• Purchase information, including payment card numbers or other third-party payment information (such as PayPal) where required for the purpose of payment, and billing and shipping address. We also collect information that is required for extended warranty purposes and your transaction and purchase history on or through the Platform.
• Your phone and social network contacts, with your permission. If you choose to find other users through your phone contacts, we will access and collect information such as names, phone numbers, and email addresses, and match that information against existing users of the Platform. If you choose to find other users through your social network contacts, we will collect your public profile information as well as names and profiles of your social network contacts.
• Your choices and communication preferences.
• Information to verify an account such as proof of identity or age. 
• Information in correspondence you send to us, including when you contact us for support.
• Information you share through surveys or your participation in challenges, research, promotions, marketing campaigns, events, or contests such as your gender, age, likeness, and preferences.

Information From Other Sources

We may receive the information described in this Privacy Policy from other sources, such as:

• If you choose to sign-up or log-in to the Platform using a third-party service such as Facebook, Twitter, Instagram, or Google, or link your Ballroom account to a third-party service, we may collect information from the service–for example, your public profile information (such as nickname), email, and contact list.
• Advertisers, measurement and other partners share information with us about you and the actions you have taken outside of the Platform, such as your activities on other websites and apps or in stores, including the products or services you purchased, online or in person. These partners also share information with us, such as mobile identifiers for advertising, hashed email addresses and phone numbers, and cookie identifiers, which we use to help match you and your actions outside of the Platform with your Ballroom account.
• We may obtain information about you from certain affiliated entities within our corporate group, including about your activities on their platform.
• We may receive information about you from others, including where you are included or mentioned in User Content, direct messages, in a complaint, appeal, request or feedback submitted to us, or if your contact information is provided to us. We may collect information about you from other publicly available sources.

Automatically Collected Information

We automatically collect certain information from you when you use the Platform, including internet or other network activity information such as your IP address, geolocation-related data, unique device identifiers, browsing and search history (including content you have viewed in the Platform), and Cookies

• Usage Information. We collect information regarding your use of the Platform and any other User Content that you generate through or upload to our Platform. 
• Device Information. We collect certain information about the device you use to access the Platform, such as your IP address, user agent, mobile carrier, time zone settings, identifiers for advertising purposes, model of your device, the device system, network type, device IDs, your screen resolution and operating system, app and file names and types, keystroke patterns or rhythms, battery state, audio settings and connected audio devices. We automatically assign you a device ID and user ID. Where you log-in from multiple devices, we will be able to use information such as your device ID and user ID to identify your activity across devices. We may also associate you with information collected from devices other than those you use to log-in to the Platform. 
• Location Data. We collect information about your approximate location, including location information based on your SIM card and/or IP address. In addition, we collect location information (such as tourist attractions, shops, or other points of interest) if you choose to add the location information to your User Content. Current versions of the app do not collect precise GPS information from users.
• Image and Audio Information. We may collect information about the videos, images and audio that are a part of your User Content, such as identifying the objects and scenery that appear, the existence and location within an image of face and body features and attributes, the nature of the audio, and the text of the words spoken in your User Content. We may collect this information to enable special video effects, for content moderation, for demographic classification, for content and ad recommendations, and for other non-personally-identifying operations. We may collect biometric identifiers and biometric information as defined under U.S. laws, such as faceprints and voiceprints, from your User Content. Where required by law, we will seek any required permissions from you prior to any such collection.
• Metadata. When you upload or create User Content, you automatically upload certain metadata that is connected to the User Content. Metadata describes other data and provides information about your User Content that will not always be evident to the viewer. For example, in connection with your User Content the metadata can describe how, when, where, and by whom the piece of User Content was created, collected, or modified and how that content is formatted. It also includes information, such as your account name, that enables other users to trace back the User Content to your user account. Additionally, metadata includes data that you choose to provide with your User Content, e.g., any hashtags used to mark keywords to the video and captions.
• Cookies. We and our service providers and business partners use cookies and other similar technologies (e.g., web beacons, flash cookies, etc.) (“Cookies”) to automatically collect information, measure and analyze how you use the Platform, including which pages you view most often and how you interact with content, enhance your experience using the Platform, improve the Platform, provide you with advertising, and measure the effectiveness of advertisements and other content. We and our partners also use Cookies to promote the Platform on other platforms and websites. Cookies enable the Platform to provide certain features and functionality. Web beacons are very small images or small pieces of data embedded in images, also known as “pixel tags” or “clear GIFs,” that can recognize Cookies, the time and date a page is viewed, a description of the page where the pixel tag is placed, and similar information from your computer or device.

We may link your contact or account information with your activity on and off our Platform across all your devices, using your email or other log-in or device information. We may use this information to display advertisements on our Platform tailored to your interests, preferences, and characteristics.

We are not responsible for the privacy practices of our service providers and business partners, and the information practices of these service providers and business partners are not covered by this Privacy Policy.

We may aggregate or de-identify the information described above. Aggregated or de-identified data is not subject to this Privacy Policy.

How We Use Your Information

As explained below, we use your information to improve, support and administer the Platform, to allow you to use its functionalities, and to fulfill and enforce our Terms of Service. We may also use your information to, among other things, show you suggestions, promote the Platform, and customize your ad experience.

We generally use the information we collect:

• To fulfill requests for products, services, Platform functionality, support and information for internal operations, including troubleshooting, data analysis, testing, research, statistical, and survey purposes and to solicit your feedback.
• To customize the content you see when you use the Platform. For example, we may provide you with services based on the country settings you have chosen or show you content that is similar to content that you have liked or interacted with.
• To send promotional materials from us or on behalf of our affiliates and trusted third parties.
• To improve and develop our Platform and conduct product development.
• To measure and understand the effectiveness of the advertisements we serve to you and others and to deliver advertising, including targeted advertising, to you on the Platform.
• To make suggestions and provide a customized ad experience.
• To support the social functions of the Platform, including to permit you and others to connect with each other (for example, through our Find Friends function), to suggest accounts to you and others, and for you and others to share, download, and otherwise interact with User Content posted through the Platform.
• To use User Content as part of our advertising and marketing campaigns to promote the Platform.
• To understand how you use the Platform, including across your devices.
• To infer additional information about you, such as your age, gender, and interests.
• To help us detect abuse, fraud, and illegal activity on the Platform.
• To promote the safety and security of the Platform, including by scanning, analyzing, and reviewing User Content, messages and associated metadata for violations of our Terms of Service, Community Guidelines, or other conditions and policies.
• To verify your identity in order to use certain features, such as livestream or verified accounts, or when you apply for a Pro Account, to ensure that you are old enough to use the Platform (as required by law), or in other instances where verification may be required.
• To communicate with you, including to notify you about changes in our services.
• To announce you as a winner of our contests or promotions if permitted by the promotion rule, and to send you any applicable prizes.
• To enforce our Terms of Service, Community Guidelines, and other conditions and policies.
• Consistent with your permissions, to provide you with location-based services, such as advertising and other personalized content.
• To train and improve our technology, such as our machine learning models and algorithms.
• To combine all the information we collect or receive about you for any of the foregoing purposes.
• To facilitate sales, promotion, and purchases of goods and services and to provide user support.
• For any other purposes disclosed to you at the time we collect your information or pursuant to your consent.

Data Security and Retention

We use reasonable measures to help protect information from loss, theft, misuse, unauthorized access, disclosure, alteration, or destruction. You should understand that no data storage system or transmission of data over the Internet or any other public network can be guaranteed to be 100 percent secure. Please note that information collected by third parties may not have the same security protections as information you submit to us, and we are not responsible for protecting the security of such information.

We retain information for as long as necessary to provide the Platform and for the other purposes set out in this Privacy Policy. We also retain information when necessary to comply with contractual and legal obligations, when we have a legitimate business interest to do so (such as improving and developing the Platform, and enhancing its safety, security and stability), and for the exercise or defense of legal claims.

The retention periods are different depending on different criteria, such as the type of information and the purposes for which we use the information. For example, when we process your information such as your profile information to provide you with the Platform, we keep this information for as long as you have an account. If you violate our Terms of Service, Community Guidelines, or other conditions or policies, we may remove your profile immediately, but may keep other information about you to process the violation.

Ballroom may transmit your data to its servers or data centers outside of the United States for storage and/or processing. Other entities with whom Ballroom may share your data as described herein may be located outside of the United States.