Effective Date: April 16, 2022
1. COLLECTION OF INFORMATION
When you download the App and create an account (“Account”), we may collect certain information (“Registration Information”) about you, such as:
- Email address;
- Phone number;
- Gender identity;
- Date of birth;
- Photographs and videos;
- Friendship region (city, state, zip);
- Individual or couple status;
- Why you want to use our services;
- How you heard about Aloe;
- Location; and
- Login and related information for social media accounts that you connect to your Account (this could include, for example, your Facebook, LinkedIn, and Apple accounts). For more information about this, see “Linking other Accounts to Aloe” in section 7 below.
You will also be required to create a password in connection with the registration of your Account. Once you register, you will be able to review and change this information (with the exception of your name, date of birth, education and profession) at any time just by logging in to Aloe and clicking on Settings under your profile photo. If you want to change your name, education or profession, you may do so by changing them on your LinkedIn profile which will save the changes to your Aloe account. You will also have the option to add a coronavirus vaccination status to your profile under Settings on your account. It is your responsibility to ensure that your account details are kept up to date.
The information we collect helps to enhance the App and authenticate our Users via third parties. Registration Information such as your first name, last name, age, profile photo, individual or couple status, description about yourself, interests, last time you were on Aloe, location, profession, education, what organizations you are in and public hub content you create on your “about me” section will be visible to Users who are presented with your profile.
If you have given Aloe access to your location in your device settings, we will collect information using WiFi access points and GPS coordinates to offer certain features to you such as our Find Friends service. This information helps us identify your physical location and we use it to personalize the App and make it easier for you to interact with other Users, by enabling the general locality information (neighborhood level only) to be displayed to Users seeing your profile and prioritizing the profiles of other Users who are near you.
If you have given Aloe access to your location, but wish to turn this off, you can do so by the following method:
- Login to your account on Aloe: Click on your Profile photo – Settings – Settings tab – Turn off Location Sharing
Device and Internet Activity Information
We may collect information about your device when you use the App including the unique device identifier, IP address, advertising identifier, device model, operating system, and MAC address, for a number of purposes, as set out in this policy. If you permit us to do so, the App may access your device’s address book solely in order to add someone to your contacts. In addition, we may collect the following information about you to improve our services:
- Internet or electronic network activity information, such as information about your device and your use of our Services, as well as how often you are online
- Electronic, visual, or similar information, such as your profile picture or photos
- Professional or employment information, when you link your account to other accounts
- Inferences we draw or derive about Users, such as your interests or preferences
- Other information you provide, such as your bio, hubs, and comments
We may keep track of how you interact with links available on Aloe including within hubs, within conversations or through third-party services by tracking redirected clicks or through other means. We may share aggregate click statistics such as how many times a particular link was clicked on.
Clickstream Data and Inferences
When you’re on Aloe, we use your activity—such as your saved User profiles, new connections you make, your conversations, which hubs you click on, hubs you create, and any text that you add in a comment or description—along with information you provided when you first signed up and information from our partners to make inferences about you and your preferences. For example, if you create a hub about travel, we may infer you are a travel enthusiast. We may also infer information about your education or professional experience based on your activity when you link your account to accounts you have with third parties such as Facebook or Apple.
Aloe Success Stories, Surveys, and other Contributions
We will collect any information you provide in response to research surveys or requests for feedback testimonials, or participation in marketing campaigns (for example, if you let us know that you have found a friend on the App, we may contact you to ask if you would be happy to be featured in advertising for Aloe).
When you Contact Customer Support
If you contact our Customer Support team by emailing email@example.com, we will receive your email address as well as the information you send to us to help resolve your query.
Cookies and Similar Technologies
What we do with the Information we Collect
We also have a legitimate interest in making Aloe safe and improving our product features. We all benefit when we use your information to:
- Suggest other people who have similar interests. For example, if you have certain interests, we may suggest people with other interests to you for you to connect with them.
- Help your friends, organizations and contacts find you on Aloe. For example, if you sign up using a Facebook account, we can help your Facebook friends find you on Aloe when they first sign up for Aloe. Or people can invite you to use Aloe by inputting your phone number or email.
- Help organizations know their member base better by sharing the information on your profile to the organization and other members in that organization. Organizations will also see the hubs you publicly share and we will also anonymously share top interests of members within that organization. We are not responsible for how the organization uses your information and any questions pertaining to this topic should be sent to them.
- Work with law enforcement and keep Aloe safe. We may get requests for account information from law enforcement authorities like the police or courts. To find out more about how we respond to law enforcement requests, please email firstname.lastname@example.org.
- Review your messages on Aloe to detect activity that poses a risk to the safety of you, our community and/or members of the public.
- Conduct analytics and research on who is using Aloe and what they are doing. For example, by logging how often people use two different versions of a feature on Aloe, we can understand which version is better.
- Improve Aloe and offer new features.
- Send you updates (such as when certain activity, like saves or comments, happens on Aloe) and news by email or push notification, depending on your settings. For example, we may send weekly updates that include hubs you may like. You can decide to stop getting these notifications by updating your settings.
In addition to the specific circumstances above, we’ll only use your information with your consent in order to:
- Send you marketing materials by email, text, push notification or phone call depending on your account or operating system settings. Each time we send you marketing materials, we give you the option to unsubscribe.
- Identify your precise location and customize the content we show you.
We may infer certain information about you (such as your salary) based on the information we collect.
As described in Section 7, if you use a third-party account to sign in to Aloe (such as Facebook), or link a third-party account to your Account, we may receive information (such as your name, birthday, location, phone number, handle and profile photos) from that third party.
2. USE OF YOUR INFORMATION
We use your personal information for:
Service delivery. We use your personal information to provide our services, including to:
- Provide, operate and improve the Sites and our business;
- Maintain and manage private and public hubs and their content;
- To create, maintain, and authenticate your account;
- Process your payments (through third-party vendors) and complete transactions with you;
- Communicate with you, including by sending announcements, updates, security alerts, and support and administrative messages;
- Understand your needs and interests, and personalize your experience with the App and our communications; and
- Provide support for the Sites, and respond to your requests, questions, and feedback.
Research and development. We may anonymize personal information and use the anonymized information for research and development, including to analyze and improve the Sites and promote our business.
Compliance and protection. We may use your personal information to:
- Comply with applicable laws, lawful requests, and legal processes, such as responding to subpoenas or requests from government authorities;
- Protect our, your or others’ rights, privacy, safety, or property (including by making and defending legal claims);
- Audit our internal processes for compliance with legal and contractual requirements and internal policies;
- Enforce the terms and conditions that govern the Sites; and
- Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks and identity theft.
How long we keep your information
We keep your information only so long as we need it to provide Aloe to you and fulfill the purposes described in this policy. This is also the case for anyone that we share your information with and who carries out services on our behalf. When we no longer need to use your information and there is no need for us to keep it to comply with our legal or regulatory obligations, we’ll either remove it from our systems or depersonalize it so that we can’t identify you.
3. DISCLOSURE OF INFORMATION
Aloe does not sell and has never sold your personal information. Aloe uses the Registration Information you provide to operate our Service but Aloe does not disclose your personal contact information to other users such as your email address and phone number.
Our policy is to not disclose your Registration Information or personal information to anyone outside of Aloe except in the limited circumstances described here:
|Circumstances where data may be disclosed||Disclosed data|
|Service Providers – We engage certain trusted third parties to perform functions and provide services to us. We may share your Registration Information or personal information with these third parties, but only for the purposes of performing these functions and providing such services. More information about this is available directly below.||This could include all information listed above|
|Business Transfers – In the event that Aloe or any of its affiliates undergoes a business transition or change of ownership, such as a merger, acquisition by another company, re-organization, or sale of all or a portion of its assets, or in the event of insolvency or administration, we may be required to disclose your personal information.||This could include all personal information that Aloe holds about you|
|Anti-Spam and Anti-Fraud – Your data may be shared with other Aloe verified partners, for example, to block accounts and suspected fraudulent payment transactions as part of our anti-spam and anti-fraud procedures.||Email address, phone number, IP address, and IP session information, social network ID, username, user agent string, and transaction and payment data|
Aggregated Information – We may share aggregated information with third parties that includes your personal information (but which doesn’t identify you directly) together with other information including log data for industry analysis and demographic profiling.
MORE INFORMATION ABOUT DISCLOSURES
Sharing your personal information with Service Providers
We engage certain trusted third parties to perform functions and provide services to us (“Service Providers”). The suppliers with which Aloe shares User personal information vary depending on a variety of factors, such as which of our App, Sites, and services a User engages with. For example, to provide our services to Users, we typically use the following suppliers:
- Authentication services – to allow customers to authenticate their account and offer users a higher level of confidence in the user’s identity
- Product improvement and market research – we use third party platforms and agencies to carry out customer surveys and market research to improve our products and services
- IT services – some of the third-party software providers used in the operation of our business may process Users’ personal information
4. WHAT OTHERS MAY SEE ABOUT YOU
When using the Aloe App, you should assume that anything you post or submit on the App may be publicly viewable and accessible, both by Users and non-users of the App. Accordingly, we suggest that our Users be careful about posting information that may eventually be made public.
Please be careful about posting sensitive details about yourself on your profile such as your phone number or email address. Please remember that photographs and videos that you post on Aloe may reveal information about yourself as well. When you do upload and choose to tell us sensitive information about yourself in your profile, you are explicitly consenting to our processing of this information and making it public to other Users.
Please also note that Users can obtain a copy of any conversation or hub content history. Aloe has no control over how users may then publish or use that information.
If you log in to or access the App through your Facebook account or another third-party account on a device that you share with others, remember to log out of the App and the relevant third-party account when you leave the device in order to prevent other users from accessing your Account.
5. AGE 18 OR OLDER
You must be at least 18 years old to use Aloe.
Aloe does not knowingly collect any information about or market to children, minors, or anyone under the age of 18. If you are less than 18 years old, we request that you do not submit information to us. If we become aware that a child, minor, or anyone under the age of 18 has registered with us and provided us with personal information, we will take steps to terminate that person’s registration and delete their Registration Information from Aloe. If we do delete a profile because you violated our no children rules, we may retain your email and IP address to ensure that you do not try to get around our rules by creating a new profile.
We strive to take appropriate security measures to help protect your information against loss, misuse, and unauthorized access, or disclosure. We use reasonable security measures to safeguard the confidentiality of your personal information such as secured servers using firewalls.
Unfortunately, no website or Internet transmission is ever completely 100% secure and even we cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur, but here are some tips to help keep your data secure:
- Please make sure you log out of your Account after use, especially if you share devices.
- Please don’t share the password you use to access your Account with anyone else.
- Change your password periodically.
If you ever think someone has had access to your password or Account, please email email@example.com. We cannot guarantee the security of your personal information while it is being transmitted to the Sites and any transmission is at your own risk.
7. LINKING OTHER ACCOUNTS TO ALOE
Using your social media details to sign in to Aloe
When you sign in to our App using your Facebook account, you give permission to Facebook to share with us your name and profile picture. Unless you opt-out, you also give permission to Facebook to share with us your email address (if there is one associated with your Facebook account), date of birth, profile photos, gender, Page likes, and current town/city.
If you register or sign in with your LinkedIn account, you give LinkedIn permission to share your LinkedIn login, a name (that can be edited by you), and an email. This email address will be linked to your Account and will be used to retrieve your Account.
If you register or sign in with your Apple ID, you give Apple permission to share your Apple login, a name (that can be edited by you), and an email (you can choose to hide your email and Apple will create a random email address so your personal email can stay private). This email address will be linked to your Account and will be used to retrieve your Account.
We will then use this personal information to activate your Account. If you remove Aloe from your Facebook settings or from your Apple ID, we will no longer have access to this data. Your LinkedIn account information cannot be deleted from Aloe unless if you delete your Aloe Account. However, we will still have the personal information that we received when you first set up your Account using your Facebook or Apple ID (you must delete your Account entirely for us to no longer have access to this data).
Linking social media accounts to your Account
You may link your Account with your Facebook, Apple or LinkedIn accounts. This allows you to share some information from those accounts directly to your Account.
We only receive the limited information that these parties permit to be transferred (as detailed by each third party and agreed by you when you first connect your account from such platforms with your Account).
If you no longer want to link your Account to your Facebook account, please visit the settings in your Facebook account and follow the instructions to remove Aloe access permissions. Please note that any information already added to your Account from those platforms will not be deleted unless you completely delete your Account as well via the Settings section. Your LinkedIn account information cannot be deleted from Aloe unless if you delete your Aloe Account. For other linked services, you can unlink your Account within the app by navigating to settings and clicking ‘unlink’.
8. YOUR CALIFORNIA PRIVACY RIGHTS
For Users who are California residents, you have the following rights (in addition to those listed in section 9 below) under the California Consumer Privacy Act, and you have the right to be free from unlawful discrimination for exercising your rights under the Act:
- You have the right to request that we disclose certain information to you and explain how we have collected and used your personal information over the past 12 months.
- You have the right to request that we delete your personal information that we collected from you, subject to certain exceptions.
California’s “Shine the Light” law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the businesses’ practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes. If you have any questions about our non-disclosure of User personal information to third parties at this time, you can write to us at firstname.lastname@example.org.
In addition, under California law, operators of online services are required to disclose how they respond to “do not track” signals or other similar mechanisms that provide consumers the ability to exercise choice regarding the collection of personal information of a consumer over time and across third-party online services, to the extent the operator engages in that collection. At this time, we do not track our Users’ personal information over time and across third-party online services. This law also requires operators of online services to disclose whether third parties may collect personal information about their users’ online activities over time and across different online services when the users use the operator’s service. We do not knowingly permit third parties to collect personal information about an individual User’s online activities over time and across different online services when using the App.
9. YOUR RIGHTS
Privacy laws applicable in your country may give you the following rights:
- Right of access: you can request a copy of your information.
- Right of rectification: if the information held is inaccurate, you have the right to have it corrected.
- Right to erasure: you have the right to have your information deleted in certain circumstances.
- Right to restrict processing: in limited circumstances, you have the right to request that processing is stopped but the information retained.
- Right to data portability: you can request a copy of certain information in a machine-readable form that can be transferred to another provider.
- Right to object: in certain circumstances (including where information is processed on the basis of legitimate interests or for the purposes of marketing) you may object to that processing.
If you want to exercise any of your rights listed above please email us at email@example.com. You can also send us mail at the following address: ALOE, LLC Attn: Legal Department, P.O. Box 550963 575 Pharr Road, NE Atlanta, GA 30355-6000. For your protection and the protection of all of our Users, we may need to request specific information from you to help us confirm your identity before we can answer the above requests.
If you have a concern about how we have processed your request or your personal information, you should contact us in the first instance via the contact details listed above.
10. DATA PROCESSING IN THE UNITED STATES
Aloe is headquartered in the United States and may use service providers that operate in other countries. Your personal information may therefore be processed in the United States or transferred to other locations where privacy laws may not be as protective as those in your state, province, or country.
11. DATA RETENTION AND DELETION
We keep your personal information only as long as we need it for the legal basis relied upon (as set out in Section 2 above) and as permitted or required by applicable law.
You may permanently delete your Account at any time, though deletion is irreversible. When you delete your account, we’ll deactivate it, remove your profile and hubs from Aloe and delete your account data. Please note that there may be legal reasons for us to keep your data, such as if we receive a law enforcement request asking us to preserve data. We may also retain certain information in our backup systems for a limited period of time, or as required by law.
Warning: Even after you remove information from your profile or delete your account, copies of that information may still be viewable and/or accessed to the extent such information has been previously shared with others, or copied or stored by others. We cannot control this, nor do we accept any liability for this. If you have given third-party applications or websites access to your personal information, they may retain such information to the extent permitted under their terms of services or privacy policies.
12. CHANGES TO THIS POLICY