1. Information We Collect
Where applicable, we indicate whether and why you must provide us with your Personal Information, as well as the consequences of failing to do so. If you do not provide Personal Information when requested, you may not be able to benefit from our Service if that information is necessary to provide you with them or if we are legally required to collect it.
2. Personal Information You Provide Us
Registration: If you wish to have access to certain features on Earn App, including earning points (“Earn Points”), you may be required to become a registered user, and to submit the following types of Personal Information to Mode Mobile:
Facial Recognition: To the extent that you provide us your express consent to do so by opting into the feature, we may collect a facial scan in order to verify your identity for the primary purpose of expediting Earn App Points redemptions. Under applicable laws, the facial scan may be considered “biometric data.”
We retain and use this biometric data as follows:
Other Optional Information: We may ask you for additional information about yourself, such as age, country or city, tastes and preferences, and other survey questions. This information is optional to provide, and you may be rewarded for providing it with Earn App Points.
Communications: If you contact us directly, we may receive additional information about you. For example, when you contact our Customer Support Team, we may receive your name, email address, phone number, the contents, date and time of a message or attachments that you may send to us, and other information you choose to provide.
Business Partners: If you work for one of our business partners or vendors, we will collect your contact details to manage the business relationship.
Job Application: If you apply for a job with us, we will collect your application information, including your resume and the contact details of your referees, as well as any other information you chose to provide to us in the context of your application.
3. Personal Information Obtained From Third Parties
Friend Referrals. We may provide you with an opportunity to invite your friends, family and acquaintances (“Friends”) to use the Apps. If you elect to use our referral service for informing a Friend about Earn App, you will be asked to allow Mode Mobile to access your contacts; you will be prompted to select contacts to whom you wish Mode Mobile to contact with information about Earn App; and then you will be prompted to consent to Mode Mobile contacting your Friends. Using our referral service permits us to automatically send the Friend one or more emails or other communications, on your behalf, inviting them to visit or register for Earn App (which invite may include additional subsequent reminders and communications). You warrant and represent that you have your Friend’s consent to provide us with his or her information for this purpose, and that you will not give us referral information for any person not permitted to use Mode Mobile, including, without limitation a child under the age of , a person whose account has previously been suspended or deactivated, or a person residing or located in a territory where use of Mode Mobile is not authorized.
4. Personal Information We Collect Automatically From Your Use of the Services
Further, if you are a resident of the EU, advertisements shown to you may be supplied via the Ogury Choice Management Platform (“Ogury CMP”), which is compatible with version 2.0 of the IAB Europe Transparency and Consent Framework (“TCFV2”). Accordingly, your prior consent will be collected via Ogury CMP, which supports TCFV2.
If, however, you do not accept cookies, you may experience some inconvenience in your use of the Services.
5. How We Use Your Personal Information
Internal and Service-Related Usage. We use Personal Information for internal and Service-related purposes, including to operate, provide and maintain the Services. For example, we use information we obtain from third parties and collect automatically to do the Earn App Point reward calculation.
Analytics and Improving the Service. We and our service providers use Personal Information that we collect on the Services, such as your location and your activities on the Services, to monitor and analyze usage of the Services and to improve and enhance the Services.
Communications. We may contact you (i) for customer-service or technical-support purposes, or (ii) to send you (a) information about topics or content that we think may interest you, or (b) updates about the latest developments or features on the Services. We also may send push notifications to your device and periodic communications to the email address you provide to us in the event that you subscribe to receive such notifications and communications.
Advertising. We and our advertising partners may use your Personal Information, including your location and your activities on the Service to facilitate the delivery of advertisements.
Tailored Content. We may use your Personal Information to provide you with personalized services, content, offers and recommendations. For example, we may analyze your listening history to recommend similar content that we think would be of particular interest to you, send you tailored recommendations based on your location or send you personalized marketing communications based on Personal Information we have collected about you.
Aggregate Data. We may de-identify and aggregate information collected through the Services for statistical analysis and other lawful purposes.
Business Partners. We may use your personal information to manage our business relationships, including:
Job Applications. We process your Personal Information to evaluate your job application.
Legal. We may use your Personal Information to enforce our Terms of Service modemobile.com/terms, to defend our legal rights, to comply with our legal obligations and internal policies.
If you are located in the European Economic Area, we only process your Personal Information based on a valid legal ground, including when:
6. How We Share Your Personal Information
We disclose Personal Information that we collect about you in the context of the Services to third parties in the following circumstances:
We may use and disclose aggregate information that does not identify or otherwise relate to an individual for any purpose.
7. Third Party Services and Links
We maintain administrative, technical and physical safeguards that are intended to appropriately protect Personal Information against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the Personal Information in our possession.
9. Data Retention
We take measures to delete your Personal Information or keep it in a form that does not allow you to be identified when this information is no longer necessary for the purposes for which we process it, unless we are required by law to keep this information for a longer period. When determining the retention period, we take into account various criteria, such as the type of products and services requested by or provided to you, your ability to claim Earn App Points you have earned via our services, the nature and length of our relationship with you, possible re-enrollment with our products or services, the impact on the services we provide to you if we delete some information from or about you, mandatory retention periods provided by law and the statute of limitations.
10. Your Rights and Choices
Marketing Communications. If you decide at any time that you no longer wish to receive marketing communications from us, please follow the unsubscribe instructions provided in any of the communications. You may also opt out from receiving commercial email from us by sending your request to us by email at email@example.com. Please be aware that, even after you opt out from receiving commercial messages from us, you may continue to receive administrative messages from us regarding the Services.
European Privacy Rights. Depending on your country and, in particular, if you are located in the European Economic Area or Switzerland, you may have the following additional rights:
11. Use of Services By Children
The Services are not directed to individuals under the age of thirteen (13), and we request that they not provide personal information through the Services. We do not knowingly collect, maintain or use Personal Information (as that term is used herein and as defined in the Federal Trade Commission’s Children’s Online Privacy Protection Act Rule) from children under the age of thirteen (13). If you are located in the European Economic Area or Switzerland, we do not knowingly collect, maintain or use Personal Information from children under the mandated minimum age set by each country within the European Economic Area. If a parent or guardian becomes aware that his or her child has provided us with Personal Information, he or she should contact us at firstname.lastname@example.org, and we will take steps to immediately delete that information.
12. International Cross-Border Data Transfer
13. California Privacy Rights
If you are a California resident you may request a notice from us describing what categories of personal information (if any) we have shared with third parties, including our corporate affiliates, for their direct marketing purposes during the preceding calendar year. You may request such notice once a year and free of charge. To request a notice, please contact Mode Mobile as provided in the “Contact Us” section of this Policy and indicate in the email subject line “California Shine The Light Request” so that we can process your request. Please include your mailing address, state of residence and email address with your request.
Those rights may be limited in some circumstances by local law requirements. You may exercise these rights by contacting us as specified below.
As of January 1, 2020, California residents also have the following rights provided to them under the California Consumer Privacy Act of 2018, Civil Code §1798.100 et seq. (CCPA): (1) Right to Know About Personal Information Collected. California residents have the right to request that a business disclose to them the Personal Information it collects, uses, discloses, and sells, subject to certain exceptions and limitations. (2) Right to Request Deletion of Personal Information. California residents also have the right to request the deletion of their Personal Information collected or maintained by Mode Mobile, subject to certain exceptions and limitations. (3) Right to Opt-Out of the Sale of Personal Information. California residents have the right to opt-out of the sale of their Personal Information. Under the CCPA, the “sale” of Personal Information broadly includes any communication of Personal Information to any business that is deemed to be a “third party” (as defined in the CCPA) for monetary or other valuable consideration, subject to certain exceptions and limitations. (4) Authorized Agent. California residents may use an authorized agent to exercise certain privacy-related requests and rights on their behalf. The authorized agent’s exercise or request on your behalf sent by mail shall include a power of attorney or a notarized statement properly signed by you appointing such authorized agent for such purpose. If your authorized agent submits the exercise or request online via the link below, a copy of the power of attorney or the original notarized statement shall be mailed to the following address: Mode Mobile, LLC, One East Erie, Suite 525, Chicago, IL 60611; Attention: Privacy, within five (5) days after submitting such online request, or we may in our discretion otherwise verify the agent’s authority to our reasonable satisfaction. (5) Notice of Financial Incentive. California residents have the right to receive notice of financial incentives provided to them by a business. (6) Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights. California residents have a right not to receive discriminatory treatment by a business in the event that the California resident exercises one or more of their privacy rights conferred by the CCPA. (7) How to Submit Your Request. Mode Mobile offers California consumers (or their authorized agent) two (2) ways to submit requests concerning their California privacy rights under the CCPA: (i) by emailing us at email@example.com (Attn: California Privacy Requests); or (b) by mailing your request to the following address: Mode Mobile, LLC, One East Erie, Suite 525, Chicago, IL 60611 (Attn: California Privacy Requests). Mode Mobile will review all properly-submitted requests and respond in a timely manner in accordance with the CCPA and applicable regulations thereunder. As part of this process, and to prevent unauthorized use of your Personal Information, you may be asked to verify your identity so that we can match you to a person in our systems. The verification methods we use may include requests to disclose your first name, last name, email address, location information, security question, Service activity and other information; such verification may be conducted by a third-party on our behalf. (8) Publication of CCPA Statistical Data. Starting January 1, 2021, and updated each year thereafter (if and as required by the CCPA), Mode Mobile will publish a summary of statistical data pertaining to the following categories of California-resident consumer privacy requests: (1) “Requests to Know”, (2) “Requests to Delete”, and (3) “Requests to Opt-Out of Sale.” The statistical data Mode Mobile will publish will include: (A) the number of requests Mode Mobile received in each category of California-resident consumer privacy request, (B) the number of such requests that Mode Mobile complied with in (in whole or in part), (C) the number of such requests which Mode Mobile denied, and (D) the median number of days within which such requests were responded to.
15. Contact Us
Privacy Team (Attn: Justin M. Hines)
Mode Mobile, LLC.
One East Erie, Suite 525
Chicago, IL, 60611
United States of America
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