SQUADS PRIVACY POLICY

Effective date: February 15, 2022

Unnamed Startup, Co. (“Squads,” “we,” “our,” and/or “us”) values the privacy of individuals who use our website, app, and related online services (collectively, our “Services” or “Platform”). This privacy policy (the “Privacy Policy”) explains how we collect, use, and share information from users of our Services (“Users”, “you”, and/or “your”), and how to exercise your rights. It applies to Users who buy coins in squads (“Fans”), as well as the individuals creating and sharing content (“Creators”). Beyond the Privacy Policy, your use of our Services is also subject to our Terms of Service (https://www.squads.life/terms-of-service).

 

INFORMATION WE COLLECT

We may collect a variety of information from or about you or your devices from various sources, as described below.

If you do not provide your information when requested, you may not be able to use our Services if that information is necessary to provide you with our Services or if we are legally required to collect it.

 

Information You Provide to Us

Registration and Profile Information. When you sign up for an account, we ask for information about you, like a phone number. Later we will also ask for additional information about you, such as your username, real name, age, profile picture, physical address, and email address. This information may be shared with Creators when you apply for experiences, as set forth in “How We Share The Information We Collect” below.

 

Creator Accounts and Content. If you are a Creator, we may collect information that you submit to us in connection with your squad. This information may include your name, phone number, and your social media identifiers, such as your Instagram URL, YouTube URL, and/or TikTok URL. We also collect this information if you sign up to be a Creator via our waiting list.

 

Communications. If you contact us directly, we may receive additional information about you. For example, if you contact us for customer support, we may receive your name, email address, phone number, the contents of the message and any attachments you send to us, and any other information you choose to provide. When we send you emails, we may track whether you open them to learn how to deliver a better customer experience and improve our Services.

Careers. If you decide that you wish to apply for a job with us, you may submit your contact information and your resume online. We will collect the information you choose to provide on your resume, such as your education and employment experience. You may also apply through LinkedIn. If you do so, we will collect the information you make available to us on LinkedIn.

Payment Information. If you make a purchase through our Services, your payment-related information, such as credit card, public blockchain data, or other financial information, is collected by our third party payment processor on our behalf.  To make purchases or transfer funds via bank transfer, we will require additional information, such as your bank account number.

 

Crypto Wallet Information. We may offer the ability to make purchases of non-fungible tokens (“NFTs”), which can be used to receive certain rewards or benefits on our platform. To enable this feature, we may collect your crypto wallet address, the NFTs you bid on or purchase, and the amounts you pay for each NFT. We may also collect other information in order to facilitate the transaction, verify your identity, and comply with our regulatory obligations (sometimes referred to as “Know Your Customer” checks). Such information may include, without limitation: date of birth, your passport or national ID card, a bank card statement, or other information linking you to an address.

 

Squad Interactions and Other Interactive Features. We and others who use our Services may collect personal information that you submit or make available through our interactive features (e.g., messaging and chat features, commenting functionalities, forums, blogs, and social media pages). You may have the ability to engage with other Fans during Creator chats or other types of content. If you choose to send messages, videos, or other content on Squads, we may collect that information, for example to ensure you get the rewards you’ve earned and otherwise to ensure compliance with our Terms of Service. Any information you provide using the public sharing features of the Services will be considered “public,” unless otherwise required by applicable law, and is not subject to the privacy protections referenced herein. Please exercise caution before revealing any information that may identify you in the real world to other users.

 

Experiences.  We will collect information from you as needed to facilitate the delivery of exclusive content and experiences for Fans and Creators. For example, we may arrange meetups between Creators and their fans, which may require us to collect your name, passport information, and other information to book travel on your behalf.

 

Information We Collect When You Use Our Services

Video, Message and Audio Recordings. When you post content on our platform, the content may be recorded and publicly posted to our Platform and other services.

Location Information. When you use our Services, we may infer your general location information, for example, by using your internet protocol (IP) address. With your permission, we may also ask for your precise geolocation from your mobile device, such as in order to facilitate in-person meetups between Fans and Creators.

Device Information. We receive information about the device and software you use to access our Services, such as your IP address, web browser type, operating system version, phone carrier and manufacturer, application installations, device identifiers, mobile advertising identifiers, and push notification tokens.

Usage Information. To help us understand how you use our Services and to help us improve, we automatically receive information about your interactions with our Services, such as the pages or other content you view, the searches you conduct, Creators you follow, purchases you make, your comments, any content you post, and the dates and times of your visits.

Your Contacts. If you permit us to access the address book on your device or give us permission to import your contacts from an email account associated with your account, we may access and store names and contact information from your address book to facilitate invitations and social interactions that you initiate through our Services, and for other purposes described in this privacy policy or at the time of consent or collection. We also collect information about your contacts if you invite them to use our Services or share information or content with them from our Services.

Information from Cookies and Similar Technologies. We, as well as third parties that provide content, analytics, or other functionality on our Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through your use of our Services.

 

  • Cookies. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.

 

  • Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in our Services that collects information about engagement on our Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

 

Our uses of these Technologies fall into the following general categories:

 

  • Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity, improve security, or allow you to make use of our functionality;

 

  • Performance-Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services (see Analytics Partners below);

 

  • Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences; and

 

  • Advertising- or Targeting-Related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third-party websites.

 

See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies.

 

Information We Receive from Third Parties

Information from third party services. If you choose to link our Services to a third party account, such as a social media account, we may receive information about you, including your profile information, follower information, and your use of the third party account. If you wish to limit the information available to us, you should visit the privacy settings of your third party accounts to learn about your options.

 

In accordance with the applicable law, we or our service providers may obtain information about you from public databases, credit bureaus, and ID verification service providers for the purpose of verifying your identity. Such information may include your name, address, publicly available information, credit history, status on any sanctions’ lists maintained by public authorities, and other relevant data. We obtain such information to comply with our legal obligations, such as anti-money laundering laws. In some cases, we may process additional data about you to assess risk and ensure our Services are not used fraudulently or for other illicit activities.

 

Other third parties. We may receive additional information about you, such as demographic data, from third parties such as data or marketing partners and combine it with other information we have about you.

HOW WE USE THE INFORMATION WE COLLECT

We may use the information we collect:

  • To provide, maintain, improve, and enhance our Services;

  • To personalize your experience on our Services such as by providing tailored content and recommendations. Note: our processing of your personal information will not result in a decision based solely on automated processing that significantly affects you unless such a decision is necessary as part of a contract we have with you, we have your consent, or we are permitted by law to engage in such automated decision making. If you have questions about our automated decision making, you may contact us as set forth below;

  • To understand and analyze how you use our Services and develop new products, services, features, and functionality;

  • To communicate with you, provide you with updates and other information relating to our Services, provide information that you request, respond to comments and questions, and otherwise provide customer support;

  • To generate aggregated or de-identified reports;

 

  • To generate anonymized, aggregate data containing only de-identified, non-personal information that we may use to improve or maintain the Services;

 

  • To send you text messages and push notifications;

  • To facilitate transactions and payments;

  • To find and prevent fraud, and respond to trust and safety issues that may arise;

  • For digital currency services, we are required to collect, use, and store your personal information such as verifying your identity in order to comply with applicable anti-money laundering laws;

 

  • To tailor and provide you with advertisements, some of which may include email campaigns, custom audiences advertising, and re-targeting;

 

  • For compliance purposes, including enforcing our Terms of Service or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency; and

  • For other purposes for which we provide specific notice at the time the information is collected.

HOW WE SHARE THE INFORMATION WE COLLECT

We do not share or otherwise disclose information we collect from or about you except as described below or otherwise disclosed to you at the time of the collection.

Vendors and Service Providers. We may share any information we receive with vendors and service providers retained in connection with the provision of our Services.

User Information and Creator Chats. Squad chats are social communication tools during which you may be able to participate by chatting with Creators and other participants via video or chat functionality. If you participate during a chat, other squad members will see your profile and profile picture, your video, and any messages you send. Squads or Creators may publicly post recorded sessions, including your participation in them, on our Services or third party services. You should not share content or otherwise participate in a session if you would not be comfortable having that content publicly viewable.

User Profile and Collections. User profiles on Squads are publicly viewable. If you have chosen to provide a username, profile picture, or wallet address, that will be viewable by other users. If you have linked your social media accounts to our Services, the links and follower counts will be publicly displayed to other users. Additionally, other users may be able to view your connections and which Creator’s squads you have chosen to join.

 

Creator Experiences. We may share your information with Creators, so that they can deliver content, coordinate meetings, organize drops, and provide other experiences to you and other Fans.

Marketing. With your consent, we may share your email address and any other contact information you choose to provide with Creators, who may use that information to market their own products or services to you.

Analytics Partners. We use analytics services such as Amplitude to collect and process certain analytics data. These services may also collect information about your use of other websites, apps, and online resources. You can learn more about Amplitude’s practices by visiting https://amplitude.com/privacy.

Social Media Platforms. Our Services may contain social media buttons, such as Instagram, TikTok, and YouTube. which might include widgets such as the “share this” button or other interactive mini programs). These features may collect your IP address and which page you are visiting on our Services and may set a cookie to enable the feature to function properly. Your interactions with these platforms are governed by the privacy policy of the company providing it.

 

As Required by Law and Similar Disclosures. We may access, preserve, and disclose your information if we believe doing so is required or appropriate to: (a) comply with law enforcement requests and legal process, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, or safety. For the avoidance of doubt, the disclosure of your information may occur if you post any objectionable content on or through the Services.

Merger, Sale, or Other Asset Transfers. We may transfer your information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets, as permitted by law and/or contract.

Consent. We may also disclose your information with your permission.

YOUR RIGHTS AND CHOICES

Marketing Communications. You can unsubscribe from our promotional emails and texts via the link provided in the texts and emails. Even if you opt out of receiving promotional messages from us, you will continue to receive administrative messages from us.

 

“Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

 

Cookies. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS and others.

 

Please note you must separately opt out in each browser and on each device.

 

Your Privacy Rights. In accordance with applicable law, you may have the right to:

 

  • Access Personal Information about you, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information in a structured, commonly used, and machine readable format; and (iii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company in a structured, commonly used, and machine readable format (the “right of data portability”);

 

  • Request Correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information;

 

  • Request Deletion of your personal information;

 

  • Request Restriction of or Object to our processing of your personal information; and

 

  • Withdraw your Consent to our processing of your personal information. Please note that your withdrawal will only take effect for future processing and will not affect the lawfulness of processing before the withdrawal.

 

If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.

THIRD PARTIES

Our Services may contain links to other websites, products, or services that we do not own or operate. We are not responsible for the privacy practices of these third parties. Please be aware that this Privacy Policy does not apply to your activities on these third party services or any information you disclose to these third parties. We encourage you to read their privacy policies before providing any information to them.

SECURITY

We make reasonable efforts to protect your information by using safeguards designed to improve the security of the information we maintain. However, as no electronic transmission or storage of information can be entirely secure, we can make no guarantees as to the security or privacy of your information.

CHILDREN’S PRIVACY

 

We do not knowingly collect, maintain, or use personal information from children under 13 years of age, and no part of our Services are directed to children. If you learn that a child has provided us with personal information in violation of this Privacy Policy, then you may alert us at support@squads.life.

 

If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account.

 

INTERNATIONAL TRANSFERS OF DATA

Our Services are hosted in the United States and intended for visitors located within the United States. If you choose to use the Services from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the United States for storage and processing. Also, we may transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Services.  We endeavor to safeguard your information consistent with the requirements of applicable laws.​

 

RETENTION OF PERSONAL INFORMATION

 

We store the personal information we collect as described in this Privacy Policy for as long as you use our Services, or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws. 

 

SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS

 

This Supplemental Notice for California Residents only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information Squads has collected about them, and whether Squads disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months. California residents can find this information below:

 

Category of Personal Information Collected by Squads

Category of Third Parties Information is Disclosed to for a Business Purpose

Identifiers.

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.

  • Data analytics providers

  • Service providers

  • Creators

  • Other Users/Public (e.g., your public profile)

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

A name, signature, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, bank account number, credit card number, debit card number, or any other financial information. Personal Information does not include publicly available information that is lawfully made available to the general public from federal, state, or local government records. Note: Some personal information included in this category may overlap with other categories.

  • Data analytics providers

  • Service providers (e.g., third-party identity verification systems)

Protected classification characteristics under California or federal law

Age (40 years or older), race, color, national origin, citizenship, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

  • Service providers (e.g., third-party identity verification systems)

Commercial information

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

  • Data analytics providers

  • Service providers

 

Internet or other electronic network activity

Browsing history, search history, information on a consumer's interaction with an internet website, application, or advertisement.

  • Data analytics providers

  • Service providers

 

Geolocation data

Physical location or movements.

  • Data analytics providers

  • Service providers

  • Creators

 

Sensory data

Audio, electronic, visual, or similar information.

  • Data analytics providers

  • Service providers

  • Creators

  • Other Users

 

Inferences drawn from other personal information to create a profile about a consumer

Profile reflecting a consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

  • Data analytics providers

  • Service providers

 

 

The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth in “Information We Collect” and “How We Use The Information We Collect” above, respectively.

 

“Sales” of Personal Information under the CCPA. For purposes of the CCPA, we do not “sell” personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age.

 

Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.

 

Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

 

Verification. To protect your privacy, we will take the following steps to verify your identity before fulfilling your request. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include asking you to answer questions regarding your account and use of our Services.

 

If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.

 

California Shine the Light. The California “Shine the Light” law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties.

 

Right for minors to remove posted content. Where required by law, California residents under the age of 18 may request to have their posted content or information removed from the publicly-viewable portions of the Services by contacting us directly as set forth in Contact Us below.

 

SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS

 

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Information to third parties who intend to license or sell that Personal Information. You can exercise this right by contacting us at support@squads.life with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not sell your Personal Information as sales are defined in Nevada

 

ACCESSING/UPDATING YOUR INFORMATION

You can update your account and profile information through your profile settings.

CHANGES TO THIS PRIVACY POLICY

We will post any adjustments to the Privacy Policy on this page, and the revised version will be effective when it is posted. If we materially change the ways in which we use or share personal information previously collected from you through the Services, we will notify you through the Services, by email, or other forms of communication.

CONTACT US

If you have any questions, comments, or concerns about our processing activities, please email us at support@squads.life or write to us at Unnamed Startup, Co., 119 Fuller Street Brookline, MA 02446.