PRIVACY POLICY

Last modified: January 21, 2016

Thank you for using Privates.

This document, our Privacy Policy, governs how RXN, LLC d/b/a Privates (“we,” “us,” etc.) handles our users (“you,” “your,” etc.) data both in the Privates app itself (the “Privates App”) and on our website/servers (collectively, the “Services”).

Our Privacy Policy is incorporated into and is subject to the Privates Terms of Service, so please read both documents carefully. Your use of the Privates Services indicates your consent to this Privacy Policy and our Terms of Service. If you do not want to be bound by these agreements, you may not use our Services.

We work very hard to preserve your privacy and security, and we do our best to be as transparent as possible in explaining how we use your data in providing our Services. Please contact us if you have any questions at info@rxn.nyc.

Our Privacy Practices, in Brief:

Privates has to collect some information from you in order to provide our Services to you, but we do so in a highly limited, highly secure way.

What Information Does Privates Collect and How Is It Used?

We are committed to limiting our collection of your information to what is necessary to provide you with our Services.

We only collect information from users who create Privates Accounts. You must create a Privates Account to use the Privates App.

What We Donʼt Collect: We do not collect any location information or have access to the contents of the communications you send using the Privates App. After messages are deleted (or after they expire), they are forensically deleted and are not retrievable by us or anyone else. (Remember, however, that if you send a Privates message to another Privates user, that message might remain on their device even after you delete it from yours, depending on the value you set for the self-destruct time of that message and whether the recipient took a screenshot of the message.)

User-Provided Information: We collect some very limited information from you after you download the Privates App in order to allow you to create a Privates Account, and begin using the Privates App.

Optional User-Provided Information: Within the Privates App, we provide a few optional features for your convenience. Some of these features, described below, will ask for personal information. If you want to keep your use of Privates as anonymous as possible, please read these sections carefully in order to understand how we associate information you provide with your Privates Account.

Automatically Collected Information: Privates collects two types of information automatically during your setup and use of the Privates App: Device Information and Aggregate Usage Data.

What Information Does Privates Share with Third Parties?

We do not share any user information we have with third parties, with the exception of the third-party service with whom we share your phone number for the sole purpose of sending you an SMS confirmation when you associate your phone number with your [Privates ID]. Please note that the provision of a phone number is currently required for account creation.

Law Enforcement

We will always notify you of any third party requests for your information unless legally unable to do so. As soon as legally permitted to do so, we will notify our users of requests for their information. We require a warrant before handing over the contents of your communication, however, because of the nature of our technology, the contents of your communication will difficult to decipher if obtained.

You Can Deactivate Your Account

You can deactivate your account at any time. Once deactivated your account will be irrevocably suspended, ensuring that nobody can use that [Privates ID] again in order to prevent impersonation. If you wish to deactivate your Privates account, go to Privates Settings, Account, tap “Terminate Account” and verify by entering your password.

We Retain As Little Data As Possible, for the Least Time Possible

Data Retention on Privates’ Servers: Our servers store the encrypted messages that you send and receive only long enough to ensure their reliable delivery to each device associated to your account. Undelivered messages are deleted after [24] hours. We retain non- message data (i.e. Types of messages) for as long as you use the Privates Services and for an indefinite time thereafter.

Data Retention on Your Device: All messages are stored in encrypted form on end users’ devices. You choose your own retention policy for your messages by choosing how long a message is viewable before it is deleted (via the self-destruct time for sent messages and manual deletion for your device). Deleted messages cannot be recovered.

Security

We are concerned about safeguarding the confidentiality of your information. We provide physical, electronic, and procedural safeguards to protect information we process and maintain. For example, we limit access to this information to authorized employees who need to know that information in order to operate, develop, or improve our Services. No sensitive information is in the clear: we take reasonable efforts (as described herein) to ensure that everything we store is not retrievable by us or anyone else.

No security system can prevent all potential security breaches. Therefore we have limited the potential implications of such a breach by designing our system so that in the event of a breach, we would have the least possible information about you.

Children’s Privacy

We do not direct our Services to children under the age of 13. If you are the parent or guardian of a child and you believe that we have inadvertently received personal information about that child, please contact us as described in the Contact Us section below and we will delete the information from our records.

Customer Service

Any information provided to us by our users voluntarily when they request customer support (e.g., an email address) will be used to respond to that individual request and may be logged as part of our effort to improve our customer service and solve any product-related issues. These email addresses cannot be linked to our users’ Privates accounts, unless users voluntarily include their Privates account information in their customer service-related requests. We strongly discourage our users from disclosing their login and password information.

We Can Change This Privacy Policy

This Privacy Policy may be updated from time to time, for any reason. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy here along with information about what has changed and an archive of past policies. You are advised to consult this Privacy Policy regularly for any changes.

Users Outside the US

If you use our Services and reside outside the U.S., your information will be transferred to the U.S. and will be processed and stored there under U.S. privacy standards. By using our Services and providing information to us, you consent to such transfer to and processing in the U.S. You are responsible for complying with any laws or regulations in your country that govern use of applications and services like Privates.

Contact Us

If you have any questions regarding privacy while using our Services, or have questions about our practices, please contact us via email at info@rxn.nyc.