PRIVACY POLICY

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Last Updated: December 21, 2018

Welcome to Instime, ("us", "we", “our”, "services") - marketing and promotional services.

At Instime, we collect and manage user data according to the following Privacy Policy, with the goal of incorporating our company values: transparency, accessibility, sanity, usability. This document is part of Instime’s Terms of use, and by using [www.instime.com] (the “Website”), you agree to the terms of this Privacy Policy and the Terms of use. Please read the Terms of use in their entirety. If you do not agree with the terms, do not access or use the Services, Website or any other aspect of Instime’s business.

DATA COLLECTED

Information you provide to us directly: When you sign up for or use our Services, we ask you to provide your name, email address, and password. We may collect information for tracking your Instagram accounts (your Instagram usernames); public analytics information (data about your Instagram accounts that can be found in public access); payment information from you in order to take payment for our Services. If you contact our support, we will collect the information we need to categorize your question and respond to it.

Information we collect automatically: We collect information about you automatically when you visit our Website or use our Services. For example, we collect information about how often you use the Services, pages visited, links clicked, mouse movements, and other information about how you interact with the Website and Services. We may also collect data about how you interact with messages we send to you, for example, whether you opened an email or read an in-app message. We collect information about the device you use to access our Website and Services, including your browser, operating system, and cookie information. We may collect log file information (when you use our Service, our servers automatically record certain log file. We may collect information, including your web request, Internet Protocol ("IP") address, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed, and other such information).

Information we get from third parties: We may also obtain information from our third-party partners and service providers to analyze how users use our Website and Services. We use this aggregated information to better understand and optimize our Website and Services.

We are constantly trying to improve our Services. This means that we are introducing new features of our services regularly, some of which may result in the collection of new data from you.

You are able to view, change and remove your data associated with your profile. Should you choose to delete your account, please contact us at [[email protected]], and we will follow up with such request as soon as possible. Minors and children should not use Instime. By using the Website, you represent that you have the legal capacity to enter into a binding agreement

COOKIES

Cookies and similar technologies ("Cookies") are needed for the proper functioning of this site and give you the optimum experience of the services you request, including our content and other features. Please review our Cookies Policy for more information about Cookies. We use cookies to understand site-usage and to improve the content and offerings on our Website. For example, we may use cookies to personalise your experience at our Website (e.g. to recognise you by name when you return to our site) and to save your password in password-protected areas).

USE OF THE DATA

We only use your personal information to provide you the Instime services or to communicate with you about the services or the Website.

To operate the Website and Services: We use the collected information to help us administer our Website and Services, authenticate users for security purposes, provide personalized user features and access, and process transactions between you and Instime.

To communicate with you: We communicate with you via email, or other means available on or through the Services (for example, via live chat or in-app notifications) about your use of our Websites, and services, product announcements, software updates, as well as transactional and service messages, such as welcoming you to our Services or informing you of issues with your account, for example if your social account has disconnected. You can opt out of receiving our newsletter in the footer of each email we send to you or through your Instime account settings. You cannot opt out of receiving transaction or service messages from us.

To enhance our Website and Services and develop new ones: We use the collected information to conduct research, develop new features, and enhance or improve the features, algorithms, and user experience of our Website and Services.

To support you: We use the collected data about you to respond to your requests for information or assistance.

To market to you: We may send marketing emails and special offers about Instime, from which you can unsubscribe at any time.

SHARING THE DATA

We will only disclose your personal data to:

Third party service providers who assist us in meeting business operation’s needs, including hosting, delivering, and improving our Services. We use service providers for specific services and functions, including email communication, customer support services, payment processors, and accountancy. We may also share your data with analytics and search engine providers that assist us in the improvement of our Website. These service providers may only access, process, or store personal data pursuant to our instructions and to perform their duties to us.

Regulators, government agencies, law enforcement bodies, courts or other third parties where we think it's necessary to comply with applicable laws or regulations or to exercise, establish or defend our legal rights.

Other third parties in connection with a merger, acquisition, bankruptcy, reorganization, sale of some or all of our assets or stock, public offering of securities, or steps in consideration of such activities (e.g., due diligence). In these cases, some or all of your personal information may be shared with or transferred to another entity, subject to this Privacy Policy.

Other third parties where we have your explicit consent to share your personal data.

We do not share personal information you have provided to us without your consent, unless:

– doing so is appropriate to carry out your own request;

– we believe it’s needed to enforce our Terms of use, or that is legally required;

– we believe it’s needed to detect, prevent or address fraud, security or technical issues;

– otherwise protect our property, legal rights, or that of others.

DATA STORAGE AND SECURITY

We're committed to protecting your personal data and have implemented reasonable measures to prevent unauthorized access to our servers, and to safeguard data. We have implemented such technology and security features ourselves or purchased them from specialised third parties, and we maintain strict internal guidelines to safeguard the privacy of your personal information from unauthorised access or improper use. Backups are run to prevent loss of information, and we will continue to enhance security as new technology becomes available. We encrypt our services and payment process using secure sockets layer (SSL) and/or transport layer security (TLS). Access to your account requires password verification. Please note that despite these measures, no website can guarantee data to be 100% secure.

INTERNATIONAL DATA TRANSFERS

Your data may be transferred to, and processed in, countries other than the country you live in where some of our service provider's servers are located. That country may not provide the same level of data protection as your own country. Whenever we transfer your information we will take steps which are reasonably necessary to ensure that adequate safeguards are in place to protect your personal information and to make sure it is treated securely.

DELETION

You can remove personal information we hold about you at any time by logging into your account, accessing the Settings page, and then deleting your account.

RETENTION

You can remove your personal data from Instimeat any time by deleting your account as described above. However, we may keep some of your personal information for as long as reasonably necessary for our legitimate business interests, including fraud detection and prevention and financial reporting and compliance reasons.

YOUR RIGHTS

You have certain rights in respect to your personal information, including the right to access, correct, or delete personal data we hold about you. You can:

Request access to the data that we have about you. You can export a copy of your personal data in your account settings or request it by sending an email to [[email protected]] Please note that we may request additional information from you to verify your identity before we disclose any information.

Have your personal data corrected or deleted. Some personal data can be updated by you: You can update your name and email address, as well as payment information, through your Instime account settings. You can remove your personal data from Instime by deleting your account.

Object to our continued processing of your personal data. You can ask us to stop using your personal data, including when we use your personal data to send you marketing emails. You can opt out of receiving marketing communications at any time by clicking the “unsubscribe” link found within our emails and through your account settings.

If you have any questions or concerns regarding privacy when using Instime, please send us a detailed message to [[email protected]]. If you're based in the EEA and think that we haven't complied with data protection laws, you have a right to lodge a complaint with your local supervisory authority.

UPDATES

We post any changes we make to our Privacy Policy on this page. The date the Privacy Policy was last updated is identified at the top of this page. You are responsible for periodically visiting the Instime Privacy Policy to check for any changes.

GDPR PRIVACY NOTICE

If you are located in the European Union (“EU”), United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.

For this GDPR Privacy Notice, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data, such as collection, use, storage and disclosure. Instime Media Production Ltd(“Instime”) will be the controller of your Personal Data processed in connection with the Services. For more information about your data rights and processing activities where we are the controller, please contact us at [[email protected]]. For more information about your data rights and processing activities where we are the processor, please contact the controller party in the first instance.

Where applicable, this GDPR Privacy Notice is intended to supplement, and not replace, our existing privacy policy. If there are any conflicts between this GDPR Privacy Notice and our Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this notice or whether any of the following applies to you, please contact us at [[email protected]].

How We Process Personal Data:

We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below. In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such Personal Data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection. From time to time, we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

What Personal Data Do We Collect From You and How Do We Use Your Personal Data?

We collect Personal Data about you when you provide such Personal Data directly to us, when third parties such as our business partners or service providers provide us with Personal Data about you, or when Personal Data about you is automatically collected in connection with your use of our Services.

Information we collect directly from you:

We receive certain Personal Data directly from you when you provide us with such Personal Data, including without limitation the following:

– First name

– Last name

– Email address

– Country

We collect and process these categories of Personal Data as a matter of contractual necessity so that we can provide the Services to you in accordance with our Terms of use. When we process Personal Data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such Personal Data.

We may also collect user content from you when you provide it to us. For example, the Services allow you to provide us with comments, posts, and user writing samples that you submit, and you may choose to provide Personal Data (such as your name) in such content. By sharing this user content in a public forum, you are choosing to disclose any Personal Data included in such content, and we do not have control over your decision. We process user content, including any Personal Data included in any such user content, on the basis of our legitimate business interest in providing you with the Services.

We also use the Personal Data we collect directly from you to operate, improve, understand and personalize our Services based on our legitimate business interest in operating our Services in a way that benefits us and our users. For example, we use the Personal Data to:

– Create and manage user profiles

– Communicate with you about the Services

– Contact you about Service announcements, updates or offers

– Provide support and assistance for the Services

– Personalize website content and communications based on your preferences

– Meet contract or legal obligations

– Respond to user inquiries

– Fulfill user requests

– Comply with our legal or contractual obligations

– Resolve disputes

– Protect against or deter fraudulent, illegal or harmful actions

– Enforce our Terms of use

Information we receive from third party sources: Some third parties provide us with Personal Data about you, such as the following:

– Account information for third party services: If you interact with a third party service when using our Services, such as if you use a third party service to log-in to our Services (e.g., Facebook Connect), or if you share content from our Services through such third party service, the applicable third party service will send us certain Personal Data (specifically your first name, ID, token and profile picture URL) if the third party service and your account settings allow such sharing. Specifically, this Personal Data permits us to create and manage user profiles and sync your progress when you connect to Facebook through the Services. The Personal Data we receive will depend on the policies and your account settings with the applicable third party service. We process this Personal Data based on our legitimate business interest of personalizing and optimizing the Services to improve user experience.

– Information from our advertising partners: We receive information about you from some of our service providers (e.g., Instagram) who assist us with marketing or promotional services related to how you interact with our website, applications, services, advertisements or communications. We process this Personal Data based on our legitimate business interest in providing direct marketing about our services.

Information we automatically collect when you use our Services: Some Personal Data is automatically collected when you use our Services, such as the following:

– IP address

– Device identifiers

– Web browser information

– Page view statistics

– Browsing history

– Usage information

– Cookies and other tracking technologies (e.g. web beacons, pixel tags, SDKs, etc.)

– Location information (e.g. IP address, zip code)

– Log data (e.g. access times, hardware and software information)

We process this Personal Data based on the following legitimate business interests:

– Network security

– Personalization of web content

– Evaluation of quality of writing to consider engagement

– Web analytics

– Provision of rewards

– Administrative matters

In collecting the Personal Data we sometimes use “cookies” and other tracking technologies (e.g., web beacons and pixel tags). Cookies allow us to recognize your browser or device and “remember” your browser during subsequent visits for purposes of functionality, preferences, and website performance, and they also tell us how and when pages and features in our Services are visited and by how many people.

Most browsers automatically accept cookies but have an option for blocking or deleting cookies, which will prevent your browser from accepting new cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new cookie in a variety of ways. You can usually access these options through the “Settings” or similar menu in your browser. For more information about cookies, including how to see what cookies have been set and how to manage and delete cookies, please review our Cookies policy. Please note that if you block or delete cookies, some portions of the Services may not work properly.

Other uses of Personal Data: In addition to the uses set forth above, we may also process the Personal Data we collect on the basis of the following legitimate business interests.

– Operation and improvement of our business, products and services

– Marketing of our services

– Provision of customer support

– Protection from fraud or security threats

– Compliance with legal obligations

– Completion of corporate transactions

How and With Whom Do We Share Your Data?

We share Personal Data third party service providers and agents who work on our behalf and provide us with services related to the purposes described in this Privacy Policy or our Terms of use. These parties include:

– Analytics service providers

– Staff augmentation and contract personnel

– Hosting service providers

We also share Personal Data when necessary to complete a transaction initiated or authorized by you or provide you with service you have requested. We also share Personal Data when we believe it is necessary to:

– Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies

– Protect us, our business or our users, for example to enforce our terms of service, prevent spam or other unwanted communications and investigate or protect against fraud

– Maintain the security of our services

We also share Personal Data with third parties when you give us consent to do so.

Furthermore, if we choose to buy or sell assets, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party, and we would share Personal Data with the party that is acquiring our assets based on our legitimate business interest of being able to provide you with continued services. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Information as set forth in this policy.

How Long Do We Retain Your Personal Data?

We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide the Services to you and improve the Services for all users generally. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. Afterwards, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.

What Security Measures Do We Use?

We seek to protect Personal Data using appropriate technical and organizational measures based on the type of Personal Data and applicable processing activity.

Personal Data of Children:

We do not knowingly collect or solicit Personal Data from anyone in the EU, United Kingdom, Lichtenstein, Norway, or Iceland under the age of 16. If you are under 16, please do not attempt to register for the Services or send any Personal Data about yourself to us. If we learn that we have collected Personal Data from a child under age 16, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us Personal Data, please contact us at [[email protected]].

What Rights Do You Have Regarding Your Personal Data?

You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email [[email protected]]. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need to you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.

Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. You can also access certain of your Personal Data by emailing us at [[email protected]].

Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement Personal Data by emailing us at [[email protected]].

Erasure: You can request that we erase some or all of your Personal Data from our systems.

Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.

Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.

Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.

Restriction of Processing: You can ask us to restrict further processing of your Personal Data.

Right to File Complaint: You have the right to lodge a complaint about our practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.

What if You Have Questions Regarding your Personal Data?

If you have any questions about this GDPR Privacy Notice or our data practices generally, please contact us using the following information:

Instime,

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Attn: Data Protection Officer

Email: [[email protected]]