Privacy Policy

YOUR PRIVACY RIGHTS

Effective Date: April 5, 2019

This Privacy Policy describes what information Eturi Corp. (“Eturi”) may collect and how we use such information, when you visit our website at vewapp.com (the “Site”) and/or Vew applications, including those for use on mobile devices, tablets, personal computers and any other devices that connect to the Internet (“Vew Applications”). The Site and Vew Applications are collectively referred to herein as the “Services.”

By using the Services, you consent to the collection, use and sharing of your and your children’s information by Eturi in accordance with this Privacy Policy and consent to the Terms of Use and End User License Agreement, which are incorporated here by reference. For the purpose of this policy, “children” refers to minors under 13. For additional information about our practices regarding children’s personal information, please see Section 1.1.1 (Children’s Personal Information) and Section 7 (Children’s Privacy Rights) below.

The Services are intended solely and exclusively for residents of the United States. Accordingly, this Privacy Policy is directed only towards residents of the United States. By using our Services, you represent that you are not a European Union resident.

It is important for users of the Services to read the Privacy Policy carefully. The Privacy Policy may change over time in coordination with new or different services that we may provide in the future, or for other unforeseeable reasons. We have provided an "effective date," which reflects the date that this Privacy Policy was most recently updated so that users can be aware of the Privacy Policy in effect at all times. We encourage all users to occasionally refer to this Privacy Policy so that they can remain aware of our current practices.

1. INFORMATION WE COLLECT

1.1. Personal Information: Eturi collects “Personal Information” from you at various times and places on the Site and Vew Applications. Personal Information is information that would allow us to identify you personally including, without limitation, your first, middle and last name, email addresses, credit or debit card numbers or other payment methods, billing information, device information, including, for example, IP addresses (an IP address is a number automatically assigned to your device in order to use the Internet), serial numbers and geolocation information, and other information that is not otherwise publicly available. Personal Information also includes your “Children’s Personal Information,” as defined below in Section 1.1.1.

1.1.1. Children’s Personal Information: With your consent and only to provide the Services you request, Eturi may also collect your “Children’s Personal Information,” which means the name you assign your child within the Vew Applications, month and year of birth, device information including Internet Protocol (IP) addresses, serial numbers, and geolocation information, and other internet, device, or other electronic network activity information, including, but not limited to, screenshots generated by your Vew Applications account, as authorized by you (“Screenshots”). Screenshots may capture your children’s browsing activity, search activity, messaging activity, and other information regarding your child’s interaction with an Internet website, application, advertisement, device or interactions with a device in general. For additional information about our practices regarding Children’s Personal Information, please see Section 7 (Children’s Privacy Rights) below.

1.2 Non-Personal Information: This category refers to information that does not identify a specific individual. For instance, this Site may track the total number of visitors to the Site, the number of visitors to a particular page of the Site, and/or other such technical information. This data may be used to diagnose problems with the Site, gather demographic and geographic information to improve our services or marketing efforts, improve our services and product, and for similar purposes. Non-Personal Information also includes the “custom words/phrases” or “custom keywords” designated by you which trigger the Screenshots in the Vew Applications.

2. HOW WE COLLECT INFORMATION

2.1. Voluntarily Provided Information: Eturi may collect information, including Personal Information, whenever you voluntarily provide such information including, for example, when you transact business with us, use the Vew Applications or Site, request information or materials, create or update your Vew Applications profile, when you voluntarily send Screenshots, or when you communicate with us about questions or concerns.

2.2. Active Collection: Eturi may also collect information, including Personal Information, in order to provide the Services you request. This includes, for example, the collection of Screenshots, as defined above in Section 1.1.1 (Children’s Personal Information). It does not include Screenshots you voluntarily provide to us; such Screenshots are considered Voluntarily Provided Information.

2.3. Cookies and Similar Technologies: When you use the Services, we and certain third parties may use cookies and similar technologies like pixels, web beacons, and local storage to collect information about how you use the Services and provide features to you. Additionally, we may use third-party analytics tools including, for example, Google Analytics, to help us measure traffic and usage trends for the Services. These tools collect information sent by your device or our Services that assists us in improving the Services.

You have the right to choose whether or not to accept cookies. However, they are an important part of how the Services work, so you should be aware that if you choose to refuse or remove cookies, it could affect the availability and functionality of the Services.

Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. To do so, please follow the instructions provided by your browser.

Removing or rejecting browser cookies does not necessarily affect third-party flash cookies, which may be used by us or our partners in connection with the Sites. To delete or disable flash cookies, please visit this site for more information. For further information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, you can visit https://www.allaboutcookies.org/.

3. HOW WE USE THE PERSONAL INFORMATION WE COLLECT

Information collected by Eturi is used for the following purposes: (i) to provide you with the Services; (ii) to process customer payments; (iii) to communicate Services related messages; (iv) to enhance and personalize Sites and Vew Applications operations; (v) to enforce agreements, address security hazards, prevent fraud or illegal or improper activities; (vi) for our own marketing purposes; (vii) for administrative purposes; and (viii) for other legally permissible purposes.

4. DISCLOSURE OF YOUR INFORMATION TO THIRD PARTIES

Eturi may share your information in the following situations:

4.1. Service Providers: We may share your information, including Personal Information, with third parties to assist in our business operations (e.g., to process payments, store data, deliver information, and perform other similar functions); administrative functions; marketing functions; and/or to provide the Vew Applications services you have requested. See Appendix A for a non-exhaustive list of service providers that may collect your Children’s Personal Information.

4.2. Major Transactions: We may share your information, including Personal Information, as part, of or in connection with, a merger, acquisition, assignment, as part of debt financing, the sale of company assets, or in any similar transaction, or to the extent as may be required in the unlikely event of insolvency bankruptcy, or a receivership.

4.3. Disclosures Under Special Circumstances: You agree that we, our agents, and independent contractors, may disclose your information, including Personal Information (excluding Screenshots generated in accordance with Section 2.2. Active Collection), to the extent that we, our agents, and independent contractors, in our sole discretion, believe doing so may be appropriate, including but not limited to when it may be legally required, necessary to comply with laws, or in response to lawful requests or legal process. We may also share such information where we believe it may limit our liability in an actual or potential lawsuit, or where otherwise necessary to protect our rights, interests and/or property (including, without limitation, to enforce our agreements), or the rights, interests and/or property of our agents, independent contractors, customers, and others.

5. SECURITY

We maintain reasonable security procedures to protect the confidentiality security, and integrity of the Personal Information we collect. Such practices include using technical controls to secure the information that we collect, as appropriate, including Secure Socket Layer (SSL) and password protections.

Eturi cannot guarantee the security of the information on and sent from the Services. No transmission of data over the Internet is guaranteed to be completely secure. It may be possible for third parties not under the control of Eturi to intercept or access transmissions or private communications unlawfully. Neither Eturi nor any of our service providers can ensure or warrant the security of any information you transmit to us over the internet. Any such transmission is done at your own risk.

6. THIRD-PARTY WEBSITES

The Services may contain third-party links or include third-party integrations. Through these links and integrations, you may be providing information (including Personal Information) directly to the third-party, us, or both. You acknowledge and agree that we are not responsible for how those third parties collect or use your information. You should review the privacy policies of every third-party service that you visit or see, including those third parties you interact with through our Services.

7. CHILDREN’S PRIVACY RIGHTS

Eturi does not sell products or services to children. The Services are not intended for children to submit Personal Information to Eturi without the consent of their legal guardians. In compliance with the Children’s Online Privacy Protection Act (“COPPA”), please see below:

7.1. The types of Personal Information we collect about your children is detailed above in Section 1.1.1 (Children’s Personal Information).

7.2. How we collect information about your children is detailed above in Section 2 (How We Collect Information).

7.3. Children’s Personal Information will only be used or shared to provide you with the Services you request. With the exception of our Service Providers, Eturi does not share or disclose your Children’s Personal Information to any third parties. See Appendix A for a non-exhaustive list of service providers that may collect your Children’s Personal Information. We will not collect more information from your children than is reasonably necessary to provide the Services.

In accordance with COPPA, you may upon request, review the Personal Information we have collected from your child, and direct us to delete such information, and/or refuse us to allow any further collection or use of your child’s Personal Information. To exercise your rights, please contact us by e-mail at dataprotection@vewapp.com.

8. CORRECTING YOUR PERSONAL INFORMATION

You may request to view and, if necessary, correct Personal Information we collect about you. To do so, please contact us by using one of the contact methods provided in Section 10 (Contact Us) below. Please include your full name, mailing address and phone number in all requests.

9. NOTICE TO CALIFORNIA RESIDENTS – YOUR CALIFORNIA PRIVACY RIGHTS

9.1. Shine the Light: We do not sell, disclose, trade, or rent your Personal Information to third parties to market their own products or services.

9.2. Do Not Track: We do not honor do-not-track signals.

10. CONTACT US

If you have any questions regarding this Privacy Policy, please e-mail us at dataprotection@vewapp.com.

Appendix A

Service Provider Name Privacy Policy Website Link
Ably https://www.ably.io/privacy
Drip https://www.drip.com/privacy
Google https://policies.google.com/privacy
Facebook https://www.facebook.com/about/privacy
Branch https://branch.io/policies/#privacy
Sentry https://sentry.io/privacy/