Expper Privacy Policy

Expper Technologies, Inc., a Delaware corporation, respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you access or use Robin or the Services and tell you about your privacy rights and how the law protects you. Any terms not defined here shall have the definition provided in the Terms of Use, available at www.expper.tech/privacy.

1. IMPORTANT INFORMATION AND WHO WE ARE


PURPOSE OF THIS PRIVACY POLICY

This privacy policy aims to give you information on how Expper collects and processes your personal data through your access or use Robin or the Services.

While the Robinand the Services may relate to children, we do not collect data relating to children without your knowledge or except as provided by this privacy policy.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

CONTROLLER & CONTACT DETAILS

Expper Technologies, Inc., a Delaware corporation, is the controller and responsible for your personal data. We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy.

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Full name of legal entity: Expper Technologies, Inc.
Name of DPO: Karen Khachikyan
Email address: [email protected]
Postal address: 2035 Sunset Lake Rd., Suite B-2, Newark, Delaware 19702

If you are subject to the GDPR and/or UK Data Protection Act 2018, you may also contact your local data protection authority within the European Economic Area for unresolved complaints (for example, the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk)). We would, however, appreciate the chance to deal with your concerns before you approach your local data protection authority so please contact us in the first instance.

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

We may update our privacy policy from time to time. If we make material changes to how we treat your personal data, we will post the new privacy policy on this page, and we may also send a courtesy email to you to the email address we have on file for you, if any. The date the privacy policy was last revised is identified at the top of the page. You are responsible for periodically visiting this privacy policy to check for any changes, and your continued access and use of Robin and the Services after such change signifies your acceptance thereof.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

THIRD-PARTY LINKS

Robin and the Services may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.

2. THE DATA WE COLLECT ABOUT YOU


PURPOSE OF THIS PRIVACY POLICY

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). References herein to your personal data or personal data shall mean, as relevant, the personal data of Client Users, including children. We may collect, use, store and transfer different kinds of personal data about you and your Client Users, including children,that we have grouped together as follows:

Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth and gender. Contact Data includes billing address, delivery address, email address, and telephone numbers. Sensory Data includes data and Content that Robin gathers through its interaction with you and Client Users, including children. Financial Data includes bank account and payment card details. Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us. Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website. Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses. Usage Data includes information about how you use our Site, Robin, products, and the Services. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
For the avoidance of doubt, Robin may collect only the following types of personal data from Client Users: Identity Data, Sensory Data, and Usage Data.

We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Sensory Data to calculate the percentage of users asking a specific question or how they respond to a joke shared by Robin. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

AGE LIMITS

We acknowledge that children Client Users may interact with Robin and share personal data about themselves, such as their first name, last name, date of birth, gender, preferences, and other personal data. Certain personal data could be essential to the proper provision of Robin Services, and in order to collect and use such personal data in accordance with our privacy policy, we request the freely given, specific, informed, and unambiguous consent of the children, their parent, legal guardian, or other person who is the holder of parental responsibility over the child. As provided in our Terms, Client is responsible for obtaining such consent from its Client Users, including children, and the instance that Client has provided access to and use of Robin to Client Users shall mean that Client has obtained such consent.

In the case of our other Services, we do not knowingly collect or solicit personal data from or direct or target interest-based advertising to anyone under the age of 13 or knowingly allow such persons to use or access the Services and/or the Site. If you are under 13, please do not send any data about yourself to us, including your name, address, or email address. No one under the age of 13 may provide any personal data. If we learn that we have collected personal data about a child under age 13, we will delete that data as quickly as possible. If you believe that we might have any data from or about a child under the age of 13, please contact us.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with Robin and the Services). In this case, we may have to cancel a Service you have with us but we will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including: Directly from you when you provide it to us; Automatically when you use Robin and/or the Services; and Data we collect from our partners.

Information You Provide to Us
You or your Client Users, including children, may give us your or their Identity Data, Contact Data, Sensory Data, or Usage Data by filling in forms, corresponding with us, using Robin or the Services, or otherwise. You and your Client Users, including children, will share with us Content.The Sensory Data or Robin Content is not recorded or stored on our servers.

Automatic Information Collection and Tracking
When you register with, access, and use Robin and/or the Services, it may use technology to automatically collect:

Usage Data. When you access and use Robin and/or the Services, we may automatically collect certain details of your access to and use of Robin and the Services, including traffic data, usage data, location data, logs, and other communication data, Content, and the resources that you access and use on or through Robin and the Services; Technical Data. We may collect information about your Device and internet connection, including the Device’s unique device identifier, IP address, operating system, browser type, mobile network information, device (including operating system) language Location Information. Robin and the Services may collect real-time information about the location of Robin or your Device. For your Device, you can disable this function in the settings of your Device, but some parts of the Services may then not function properly.

You acknowledge and accept that Robin and the Services have certain content, features, functionality and/or services that are based on geolocation, location tracking, and geofencing which may also be collecting information on your use and access of Robin and the Services, including information on your surroundings and background. If you do not want us to collect this information, do not register with, use or access Robin and/or the Services. We also may use these technologies to collect information about your activities over time and across third-party websites, apps, or other online services (behavioral tracking).

Information Collection and Tracking Technologies
The technologies we use for automatic information collection may include: (i) cookies (or mobile cookies): a cookie is a small file placed on your Device. Like most online services, we and our partners use cookies and similar technologies to provide and personalize Robin and the Services, analyze use, and prevent fraud. You can disable cookies in your settings, but some parts of the Services may then not function properly; and (ii) web beacons: parts of the Services and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related Services statistics (for example, recording the popularity of certain Services and/or Site content, features, functionality, and services, and verifying system and server integrity).

Data We Collect From Our Partners
We also collect the following data from our partners: demographic data (such as to determine the coarse location of your IP address); data to fight fraud (such as refund abuse or click fraud); data from platforms that the Services run on (such as to verify payment); and data for analytics purposes, so we can provide you with better services.

Third-Party Information Collection
When you use or access Robin and the Services or its/their content, certain third parties may use automatic information collection technologies to collect information about you or your Device, or you may otherwise be accessing and using third-party platforms, software, and applications. These third parties may include, without limitation: media platforms and services; analytics companies; your Device manufacturer; your vendor.We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about a third party’s processing of your information, you should contact the responsible provider directly. You acknowledge and agree that your access and use of such third party tools may be subject to their respective terms of use and privacy policies.

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances: where we need to perform the contract we are about to enter into or have entered into with you; where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; where we need to comply with a legal obligation.We process your personal data for the following purposes:

To make Robin and the Services.
To perform the contract, we process data necessary to:
Create accounts and allow you to use Robin and the Services, access its contents, features, functionality, and services, and to access or use the Site; Operate our Services; Verify and confirm payments; At our discretion, provide and deliver products, services, and any other information you reasonably request; Send you Robin- or Services-related communications, such as when updates are available, and of changes to any products or services we offer or provide through Robin or the Services; Fulfill any other purpose for which you provide the information; Give you notices about your account; and Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.

To keep Robin and the Services safe and fair.
For more information on our prohibited uses policy, see our Terms of Use. In order to keep Robin and the Services and its social features safe and fair, to fight fraud and ensure acceptable use otherwise, we have a legitimate interest to process necessary data to:
Analyze and monitor use of Robin and the Services and their social features; Moderate chats, forums, and other social interaction platforms either automatically or manually; Take action against fraudulent or misbehaving users.

To analyze, profile, and segment.
In all of the above cases and purposes, we may analyze, profile, and segment all collected data, including for the purpose of estimating our audience size and usage patterns.

With your consent.
With your consent, which is implied herein, we may process your data for additional purposes, such as personalized tips to improve your experience.

MARKETING & PROMOTIONAL OFFERS FROM US

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may use your Identity, Contact, Sensory, Technical, Usage, and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).You will receive marketing communications from us if you have requested information from us or purchased goods or services from or through us and you have not opted out of receiving that marketing.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may disclose aggregated information about our users, and information that does not identify any individual or device, without restriction.Except as explicitly provided hereunder, we do not sell your personal data. In addition, we may disclose personal information that we collect or you provide:

To our subsidiaries and affiliates; To contractors, vendors, and other third parties we use to support our business and/or with which we integrate or link to deliver you Robin and the Services and/or with which you use Robin and the Services, and who may access your data and operate under their own respective terms of use and privacy policies. We encourage you to check their respective terms of use and privacy policies to learn more about their data processing practices; To a buyer, investor, or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all ofExpper’s assets or stock, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Expper about Robin and the Services users is among the assets transferred; To fulfill the purpose for which you provide it; For any other purpose disclosed by us when you provide the information; With your consent; To comply with any court order, law, or legal process, including to respond to any government or regulatory request, including in order to combat fraud and illegal activity; To enforce our rights arising from any contracts entered into between you and us; and If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Expper, our customers, users, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

6. INTERNATIONAL TRANSFERS

The Services may be accessed globally (despite the geographic restrictions provided in the Terms) and your data can therefore be transferred to anywhere in the world. Because different countries may have different data protection laws than the United States (or your own country, if you are using the Services outside of the United States, despite the geographic restrictions provided in the Terms), we take steps to ensure adequate safeguards are in place to protect your data as explained in this privacy policy. Adequate safeguards that our partners may use include standard contractual clauses approved by EU Commission and the Privacy Shield certification in case of transfers in and to the United States.

7. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Unfortunately, however, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through Robin and the Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.

8. DATA RETENTION


HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We retain your data for as long as your account is active or you are otherwise accessing and using Robin and the Services or as needed to provide you with Robin or the Services. We will, for example, periodically de-identify unused accounts, and we regularly review and de-identify unnecessary data. Note that if you ask us to remove your personal data, we will retain your data as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to exercise any of the rights set out above, please contact us the DPO at the contact information provided above.

No Fee Usually Required. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What We May Need From You. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time Limit To Respond. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please let us know.

Your Legal Rights. You have the right to:

Opt-out of marketing emails and other direct marketing. Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: If you want us to establish the data’s accuracy. Where our use of the data is unlawful but you do not want us to erase it. Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims. You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. You can withdraw your consent, for example, by turning off GPS location sharing in your Device settings.