Last updated on August 20, 2014.
1.1 Personal Information. “Personal Information” is information about an identifiable individual such as your name, address, telephone number and email address.
1.2 Children. We do not intentionally gather Personal Information about anyone under the age of 13.
1.3 Jurisdiction of Processing. Your Personal Information may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of Personal Information may be less stringent than the laws in your country.
2.1 Accounts. For some of our Products or Sites, we may require you to create an account with us. We will ask you to provide a phone number, choose a username and a profile photo and (optional) an email address when you register for an account with Cord. After downloading one of our Products or accessing one of our Sites, you may also be asked to verify your account via email.
2.2 Products and Sites.
(a) Contacts Adding Features. Cord Messenger includes an “address book matching feature” and an “add a contact” feature (collectively, the “Contacts Adding Features”), which use your address book contacts to help you connect with your friends. The Contacts Adding Features are optional. When you sign up with Cord Messenger for the first time and whenever you log into your Cord account, you will be prompted to indicate whether you want to use the Contacts Adding Features. If you elect to use the Contacts Adding Features, Cord Messenger will access and upload the phone numbers (but not names) from your mobile device address book to Cord’s servers, and check if those phone numbers are registered to a Cord user. If a phone number in your address book is registered to a Cord user, Cord will inform you of the Cord username (as registered on Cord), after which you can add them to your Cord contacts. Phone numbers are not shared or stored in this process. We rely upon you to obtain whatever consent from your address book contacts that may be required by law to allow us to access and upload the phone numbers as described above for the purpose of generating friend suggestions. Cord will use industry standard practices to securely transmit all data used in the Contacts Adding Features.
(b) Profile Picture. Cord Messenger includes a profile picture feature that allows you to add a profile picture to your account. Your profile picture will be associated with your Cord username. Uploading a profile picture is a mandatory step in the creation of a Cord Account. If you do not upload a profile picture, you will not be able to finish the creation process of a Cord Account and won’t be able to use Cord Messenger. Your profile picture will be available to anyone who looks for your username using our Contacts Adding Features, sends you a message or receives a message from you.
(c) User Profile. When you create an account with Cord, Cord will automatically create a profile for you. Your profile will contain your Cord username, profile picture, and phone number (your “User Profile”). Your photo (and not your phone number) will be displayed within Cord Messenger only to anyone who knows your exact username.
(d) Cord Messages. Cord Messenger permits users to send voice messages to each other from their mobile devices. If you send such content to a user or users, we may retain that content on your behalf and associate it with your Cord username. Content may be stored in our systems for some period of time before being deleted (subject to Section 7). If the message is not delivered, we may retain it on our system.
2.3 Other Information You Provide. We may also collect Personal Information from time to time through the following:
If/when you add a favorite within a Product.
If/when you contact us via email (with feedback, for support, or otherwise), we will collect your name and email address, as well as any other content included in the email, in order to send you a reply.
If/when you participate in one of our surveys, we may collect additional profile information.
If/when you send us a Cord message.
If/when you post messages on our message boards, the information contained in your posting will be stored on our servers and other users will be able to see it.
We may also collect Personal Information at other points in our Sites that state Personal Information is being collected.
2.5 Crash Analytics. We may analyze errors or malfunctions in Products for the purpose of providing Sites and Products, resolving bugs and improving performance. This analysis may result in limited log information (which may include some browsing data and small amounts of Personal Information) being collected by us.
2.6 Information Collected from You About Others. If you decide to invite a third party to create an account with us, you should only do so if you think that third party would want to be contacted by us. If you extend an invitation, we will collect your and the third party’s names and phone numbers in order to let you send a message to the third party. We rely upon you to obtain whatever consent from the third party that may be required by law to allow us to collect the third party’s name and phone number as described above. You or the third party may contact us at firstname.lastname@example.org to request removal of this information from our database.
2.7 Information Collected from Third-party Companies. We may receive information about you from third parties. We may add this information to the information we have already collected from you via our Sites and our Products, for a variety of purposes, including to verify other information about you and to improve the Products we provide. We may use anonymous information to enhance the advertising we provide to you.
2.9 Analytics Partners and Tracking Choices. We may share anonymous data with analytics providers (including Google Analytics) to analyze Site and Product usage by our users and develop and deliver targeted content in our Sites and Products. The information collected may be used to offer you targeted messages, to personalize your user experience by increasing the probability that our Products and Sites will appeal to you, and to undertake analytics (i.e., to analyze traffic and other end user activity to improve your experience). To learn more about Google Analytics you can visit: http://www.google.com/policies/privacy/partners.
3.2 Except for the limited disclosures described in this Policy, we will endeavor to keep your email address private and we do not sell customer lists. We will obtain additional consent prior to any such sale if required under applicable law.
3.3 We may create anonymous information from Personal Information by excluding information (such as your username) that makes the data personally identifiable to you. We may use anonymous information to analyze request and usage patterns so that we may enhance the content of our Sites and our Products, identify or make improvements to our Sites and our Products and/or improve Site navigation. Cord reserves the right to use and disclose anonymous information for any purpose and to any third party in its sole discretion.
In addition to the disclosures described in Section 2, we may additionally disclose your information as follows:
4.1 Our servers and our service providers may be located in the United States or other countries and, as such, your Personal Information may be available to the U.S. or other governments or its or their agencies under a lawful order made in the applicable country (and such information may be further made available by that country to other countries), irrespective of the safeguards we have put in place for the protection of your Personal Information.
4.2 From time to time we may employ third parties to help operate our business, the Sites or our Products. Examples of such service providers include vendors and suppliers that provide us with technology, services and/or content for analyzing data, including user content, research services, advertising and marketing assistance, payment processing (including credit card payments), and customer service. Access to your Personal Information by each of these service providers is limited to the information reasonably necessary to perform its limited function and these service providers may only use your Personal Information to provide services on our behalf.
4.3 We may, and you hereby authorize us to, disclose your Personal Information to a third party without your further consent: (a) if we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other users of our Products or Sites, or anyone else (including the rights or property of anyone else) that could be harmed by such activities; (b) in connection with any legal investigation; (c) when we believe in good faith that such disclosure is required by and in accordance with the law, such as when responding to subpoenas, warrants, production orders, or similar orders issued under U.S. Federal laws or by a court of competent jurisdiction served on the Cord Project; and/or (d) if we believe in good faith that there is an emergency involving loss of security or serious injury to any person.
4.4 We may also disclose your Personal Information in connection with a corporate reorganization, a merger or acquisition with another entity, or a sale of all or a substantial portion of our assets or stock, provided that the information disclosed continues to be used for the purposes permitted by this Policy by the entity acquiring the information. In the unlikely event of an insolvency, bankruptcy or receivership, Personal Information may also be transferred as a business asset. We may share some or all of your Personal Information with a parent company, any subsidiaries, joint ventures, or other companies under common control (collectively, “Affiliates”), in which case we will require our Affiliates to honor this Policy.
5.1 The security of your Personal Information is important to us. We use commercially reasonable efforts to store, use, and maintain your Personal Information using procedures designed to limit loss, theft, or unauthorized access, use, modification, copying, or disclosure of your Personal Information. Despite these measures, you should know that the Cord Project cannot fully eliminate security risks associated with Personal Information. You are also responsible for helping to protect the security of your Personal Information. For instance, never give out your password, and remember to lock your phone when it is not in use.
6.2 If you use Cord Messenger, you may change your profile picture, and your email address if you chose to submit it within Cord Messenger. But you won’t be able to change your username once you’ve attached it to your phone number. You may request deletion of your Personal Information by us, but please note that we may be required to keep this information and not delete it (or keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our archives. We may retain your anonymous information on our system. We will retain your other Personal Information for as long as it remains necessary for the identified purpose or as required by law or regulation, which may extend beyond the termination of our relationship with you.
6.3 We and other third parties may collect information about you through our Sites and Products, including Personal Information about your online activities over time and across different websites and applications.
7.1 This Policy is subject to occasional revision, and if we make any material changes to this Policy or in the way we use your Personal Information, we will notify you by sending you an email to the last email address you provided to us and/or by prominently posting notice of the changes on our Sites. Any changes to this Policy will be effective upon the earlier of 30 calendar days following our dispatch of an email notice to you or 30 calendar days following our posting of notice of the changes on our Sites. These changes will be effective immediately for new users of our Sites or our Products. Please note that at all times you are responsible for updating your Personal Information to provide us with your most current email address. In the event that the last email address that you have provided us is not valid, or for any reason is not capable of delivering to you the notice described above, our dispatch of the email containing such notice will nonetheless constitute effective notice of the changes described in the notice. In any event, changes to this Policy may affect our use of Personal Information that you provided us prior to our notification to you of the changes. If you do not wish to permit changes in our use of your Personal Information, you must notify us prior to the effective date of the changes that you wish to deactivate your account with us. Continued use of our Sites or our Products following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes. The date on which the latest update was made is indicated at the top of this document. We recommend that you print a copy of this Policy for your reference and revisit this Policy from time to time to ensure you are aware of any changes.
8.1 You can help by keeping us informed of any changes such as a change of address or telephone number. If you have any questions, comments, complaints or suggestions or if you find any errors in our information about you, please contact us at:Cord Project, Inc.
You can contact us using the same information if you wish to access your Personal Information.
8.2 We take compliance with the privacy laws seriously and if you have a complaint concerning our compliance we will investigate your complaint and if it is justified, we will take appropriate measures.