Privacy Policy

Last updated: September 09, 2022

Introduction

alulu Corporation (“alulu,” "we," or “us”) respects your privacy and is committed to protecting it through our compliance with this policy. For purposes of this Privacy Policy, “you” and “your” means you as the user of the Services (as defined below).

This policy describes the types of information we may collect from you or that you may provide when you download, install, register with, access, or use alulu (the “Platform”) and our related websites, services, applications, products, and content (collectively, the “Services”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

In connection with your use of the Services.
In email, text, and other electronic messages between you and the Services and/or alulu.

It does not apply to information collected by:

Us offline or through any other means, including on any other website operated by alulu or any third party; or
Any third party, including through any application or content (including advertising) that may link to or be accessible from or through the Services.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is to not use our Services. By accessing or using the Services, you agree to this Privacy Policy. This policy may change from time to time (see “Changes to Our Privacy Policy”). Your continued use of the Services after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Children Under the Age of 18

Our Services are not intended for users under 18 years of age (or the age of majority where you reside). No one under age 18 (or the age of majority where you reside) may provide any information, including any personal information, to or on the Services. We do not knowingly collect personal information from children under 18 (or the age of majority where you reside). If you are under 18 (or the age of majority where you reside), do not use or provide any information on the Services or through any of its features, register on the Services, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 18 (or the age of majority where you reside), we will delete that information. If you believe we might have any information from or about a child under 18 (or the age of majority where such child resides), please contact us at privacy@alulu.io.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our Privacy Policy on this page with a notice that the Privacy Policy has been updated on the Services home page. If we make material changes to how we treat our users' personal information, we will notify you by email to the email address specified in your account, through a notice on the Services home page, through a push notification from the mobile application, and/or with a pop-up notification when you relaunch the mobile application for the first time following the change in the Privacy Policy. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Services and this Privacy Policy to check for any changes.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Services, including information:

That identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked with, directly or indirectly, you, your household, or your device ("personal information");
That is about you but individually does not identify you; and/or
About your internet connection, the equipment and personal device(s) you use to access our Services, and usage details.

Please note, however, that personal information does not include:

Publicly available information from government records; and
Deidentified or aggregated consumer information.

In particular, our Services collects the following categories of personal information:

Identifiers – first and last name, email address, postal address, online identifier, Internet Protocol address, account name, social media account username, alias, or other similar identifiers
Protected classification characteristics under federal law – age (40 years of older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran, or military status
Internet or other similar network activity – browsing history, search history, information on a consumer’s interaction with the Services, advertisements, or third party websites
Geolocation data – physical location or movements
Inferences drawn from other personal information – profile reflecting Your personal preferences, characteristics, attitudes, intelligence, abilities, and aptitudes

We collect this information:

Directly from you when you provide it to us by creating an account or using the Services.
Automatically as you navigate through the Services. Information collected automatically may include usage details, IP addresses, and information collected through cookies and other tracking technologies. If you grant us access, we may collect information contained in the messages you send through our Platform and information from your phone book on your personal device(s). We do not collect personal information from the contents of one-to-one, private messaging that you may engage in with other users of the Platform, however, we collect information about the sender and recipient, the number of messages sent and when, and other statistical information that may be related to your personal information.
From third parties, for example, our business partners.

Where information is received from a third party, such data collection is subject to that third party’s privacy policy. The terms of our Privacy Policy do not apply on any third-party website or with respect to their information collection practices. Except as otherwise required under the relevant laws and regulations, we are not responsible for the privacy practices of these third parties and their websites. We encourage you to read their respective terms of service and privacy policies if you wish to utilize these websites so that you are informed of their practices.

Information You Provide to Us

The information we collect on or through our Services may include:

Registration information, such as age, username and password, language, and email or phone number.
Profile information, such as name, social media account information, and profile image.
User-generated content, including comments, photographs, livestreams, audio recordings, videos, and virtual item videos that you choose to create with or upload to the Platform (“User Content”). We collect User Content through pre-loading at the time of creation, import, or upload, regardless of whether you choose to save or upload that User Content, in order to recommend audio options and provide other personalized recommendations. If you apply an effect to your User Content, we may collect a version of your User Content that does not include the effect.
Content, including text, images, and video, found in your device’s clipboard, with your permission. For example, if you choose to initiate content sharing with a third-party platform or choose to paste content from the clipboard into the Services, we access this information stored in your clipboard in order to fulfill your request.
Payment information, including payment card numbers or other third-party payment information (such as PayPal) where required for the purpose of payment.
Your phone and social network contacts, with your permission. If you choose to find other users through your phone contacts, we will access and collect the names and phone numbers and match that information against existing users of the Platform. If you choose to find other users through your social network contacts, we will collect your public profile information as well as names and profiles of your social network contacts.
Your opt-in choices and communication preferences.
Information to verify an account such as proof of identity or age.
Information in correspondence you send to us.
Information you share through surveys or your participation in challenges, sweepstakes, or contests such as your gender, age, likeness, and preferences.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

Usage Details. When you access and use the Services, we may automatically collect certain details of your access to and use of the Services, including traffic data, location data, logs, and other communication data and the resources that you access and use on or through the Services.
Device Information. We may collect information about your mobile device and internet connection, including the device's unique device identifier, IP address, operating system, browser type, mobile network information, and the device's telephone number.
Stored Information and Files. The Services also may access metadata and other information associated with other files stored on your device. This may include, for example, photographs, audio and video clips, personal contacts, and address book information.
Location Information. The Platform collects real-time information about the location of your device, including location information based on your SIM card and/or IP address. With your permission, we may also collect precise location data (such as GPS).

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). See the section titled “Choices About How We Use and Disclose Your Information” for information on how you can opt out of behavioral tracking on the Services and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.

The information we collect automatically does include statistical information and personal information. The statistical information collected automatically helps us to improve our Services and to deliver a better and more personalized service, including by enabling us to:

Estimate our audience size and usage patterns.
Store information about your preferences, allowing us to customize our Services according to your individual interests.
Speed up your searches.
Recognize you when you return to our Services.

The technologies we use for this automatic data collection may include:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Services.
Web Beacons. Pages of our 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 alulu, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Information We Receive from Third Parties

We may receive the information described in this Privacy Policy from other sources, such as:

Social Media and Login Services. If you choose to link or sign up using a third-party social network or login service (such as Facebook, Twitter, Instagram, or TikTok), we may collect information from these services, including your contact lists for these services and information relating to your use of the Platform in relation to these services. If you link your alulu account to another service, we may receive information about your use of that service.
Third-Party Services. We may collect information about you from third-party services, such as advertising partners, data providers, and analytics providers.
Other Users of the Platform. Sometimes other users of the Platform may provide us information about you, including through customer service inquiries.
Other Sources. We may collect information about you from other publicly available sources.

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Services are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Services. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see the section titled “Choices About How We Use and Disclose Your Information.”

Please note that our Services, to the extent they are accessed through a website and not via our mobile application, are not configured to accept and respond to web browser Do Not Track (DNT) signals. As such, if you would like to opt-out of certain specific cookies or automatic tracking technologies, you will need to do so by exercising one of the other methods described in this Privacy Policy.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

To present our Services and its contents to you.
To provide you with information, products, or services that you request from us, including to customize the content that you see when you use the Services. For example, we may provide you with services based on the country settings you have chosen or show you content that is similar to other content that you like or interact with.
To support the social functions of the Platform, including to permit you and other users to connect with each other through the Platform and for you and other users to share, download, and otherwise interact with User Content posted through the Platform.
To send promotional materials from us or on behalf of our affiliates, trusted third parties, and marketing partners.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
To improve and develop our Platform and conduct product development.
To measure and understand the effectiveness of the advertising we serve to you and others and to deliver advertising.
To make suggestions and provide a customized ad experience.
To use User Content as part of our advertising and marketing campaigns to promote the Platform.
To understand how you use the Platform, including across your devices.
To infer additional information about you, such as your age, gender, and interests.
To help us detect abuse, fraud, and illegal activity on the Platform.
To prove your identity in order to use certain features, such as livestream or verified accounts, ensure that you are old enough to use the Platform (as required by law), or in other instances where verification may be required.
Consistent with your permissions, to provide you with location-based services, such as advertising and other personalized content.
To inform our algorithms.
To combine all the information, we collect or receive about you for any of the foregoing purposes.
To notify you about changes to our Services or any products or services we offer or provide through it.
In any other way we may describe when you provide the information.
For any other purpose with your consent.

Disclosure of Your Information

We are committed to maintaining your trust, and while alulu does not sell personal information to third parties, we want you to understand when and with whom we may share the information we collect for business purposes.

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this Privacy Policy:

To our subsidiaries and affiliates.
To other users of the Services (subject to the settings you have made with respect to posts, contributions, chats, and other communications within the Platform).
To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them. For example, we may share your personal information with payment processors and transaction fulfillment providers in order to fulfill the services you have requested.
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of alulu Corporation’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by alulu Corporation about our 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.

We may also disclose your personal information:

To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
To enforce or apply our Terms of Service and other agreements, including for billing and collection purposes.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of alulu Corporation, our customers, or others.

The categories of personal information we may disclose include:

Identifiers
Protected classification characteristics under federal law
Internet or other similar network activity
Geolocation data
Inferences drawn from other personal information

If you access third-party services, such as Facebook, Instagram, Twitter, or TikTok, to login to the Platform or to share information about your usage on the Platform with others, these third-party services may be able to collect information about you, including information about your activity on the Platform, and they may notify your connections on the third-party services about your use of the Platform, in accordance with their privacy policies. If you choose to allow a third-party service to access your account, we will share certain information about you with the third party. Depending on the permissions you grant, the third party may be able to obtain your account information and other information you choose to provide.

If you choose to engage in public activities on the Platform, you should be aware that any information you share may be read, collected, or used by other users. You should use caution in disclosing personal information while using the Platform. We are not responsible for the information you choose to submit.

Please be aware that messages sent to other users of the Platform will be accessible by those users and that we are not responsible for the manner in which those users use or disclose messages.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website. If you disable or refuse cookies, please note that some parts of the Services may then be inaccessible or not function properly.
Location Information. You can choose whether or not to allow the Platform to collect and use real-time information about your device’s location through the device’s security settings. If you block the use of location information, some parts of the Platform may become inaccessible or not function properly.
Promotional Offers from alulu. If you do not wish to have your email address used by alulu to promote our products or services, you are not required to sign-up to receive our newsletter. If you have subscribed to our newsletter, you can opt-out by using the “Unsubscribe” (or other similar) link in the footer of each newsletter email you receive or by emailing us at support@alulu.io. This opt-out does not apply to information provided to alulu as a result of a product purchase, warranty registration, product service experience or other transactions.
Targeted Advertising by alulu. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers' target-audience preferences, you can opt-out by adjusting your user advertising preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to support@alulu.io.
Disclosure of Your Information for Third-Party Advertising and Marketing. If you do not want us to share your personal information with unaffiliated or non-agent third parties for advertising and marketing purposes, you can opt-out by logging into the Platform and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to support@alulu.io.

We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.

Residents of certain states, such as California and Nevada may have additional personal information rights and choices. Please see the section titled “Your State Privacy Rights” for more information.

Accessing and Correcting Your Information

You can review and change your personal information by sending us an email at privacy@alulu.io to request access to, correct, or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Your State Privacy Rights

State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information. California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Platform that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@alulu.io.

Nevada provides its residents with a limited right to opt-out of certain personal information sales. Residents who wish to exercise this sale opt-out rights may submit a request by email to privacy@alulu.io. However, please know we do not currently sell data triggering that statute's opt-out requirements.

If you are a resident of the European Economic Area or the United Kingdom, your local laws provide you with additional rights regarding our use of your personal information. The following supplements the information contained in the other sections of this Privacy Policy and applies only with respect to personal information collected from residents of countries to which the General Data Protection Regulation (“GDPR”) or UK General Data Protection Regulation (“UK-GDPR”) apply.

Cross-Border Transfers

alulu is a corporation located in the United States. If personal information is collected on our behalf from residents of the European Economic Area or the United Kingdom, that information may be transferred to the United States, which is not subject to an adequacy decision by the European Commission or the UK Information Commissioner’s Office. If personal information is transferred to the United States, those transfers will be subject to legal transfer mechanisms that may include the European Commission’s Standard Contractual Clauses and the UK’s International Data Transfer Addendum to the European Commission’s Standard Contractual Clauses. alulu adopts additional measures to protect your personal information during cross-border transfers including encryption in transit.

Lawful Bases for Processing

Under GDPR and UK-GDPR, the lawful bases we rely on for processing your personal information are:

You have given your consent to the processing of your personal information
Processing is necessary for the performance of a contract
Processing is necessary for compliance with a legal obligation
Processing is necessary in order to protect the vital interests of you or another person
Processing is necessary for the purposes of the legitimate interests pursued by alulu (provided that our interests are not overridden by your interests or fundamental rights and freedoms)

Where you have given your consent to the processing of your personal information, you are able to revoke your consent at any time and can do so by following the instructions in the section titled “Your Data Protection Rights” below.

Your Data Protection Rights

Under GDPR and UK-GDPR, you have the right to exercise control over your personal information, including:

Right of access – you have the right to obtain a copy of the personal information that we hold about you, including other supplementary information
Right to rectification – you have the right to have inaccurate personal information corrected and to have incomplete personal information completed
Right to erasure – you have the right to have the personal information that we currently hold about you erased, subject to certain exceptions (such as if the personal information is necessary for us to comply with a legal obligation)
Right to restrict processing – you have the right to request that we restrict the processing of your personal information in certain circumstances
Right to object to processing – you have the right to object to the processing of your personal information in certain circumstances
Right to data portability – you have the right to obtain the personal information we currently hold about you in a structured, commonly used and machine readable format so that you can transmit that personal information directly to another controller or you can request that we transmit that personal information for you

You are not required to pay any charge for exercising your rights under GDPR and UK-GDPR. If you would like to exercise any of these rights, you can do so by sending us an email to privacy@alulu.io with the subject line “Data Subject Rights Request” indicating which right(s) you would like to exercise. We may need to collect some additional information from you so we may verify your identity and those identity verification efforts might come from us or from a trusted vendor on our behalf.

We will only use any personal information you provide for identity verification purposes to verify your identity and to respond to your rights request. alulu will do our best to respond to your request as soon as possible and within 30 days from when your request is received. In some circumstances, we may not be able to comply with your requests within that 30 day period and, if that is the case, we will let you know that we require an extension of time to complete the request along with the reason for that extension.

How to Complain

If you have any concerns about our use of your personal information, you can make a complaint to us using the information contained in the “Contact Information” section below. We request please contact us first so we can try to resolve your concerns. We are committed to working with you to obtain a fair resolution to any complaint or concern you may have about our use of your Personal Information.

If, however, you believe that we have not been able to assist with your request, complaint, or concern, you may have the right to lodge a complaint with the data protection authority in your country (if one exists in your country) or supervisory authority. You can find more information about your data protection authority, including their contact information, by following this link to the European Data Protection Board’s website: https://edpb.europa.eu/about-edpb/about-edpb/members_en. You may also have a right to a judicial remedy if it is determined your Personal Information is being used illegally.

If you are a UK resident, the data protection authority is the Information Commissioner’s Office (“ICO”), which can be contacted using the below information:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk

Data Security

We have implemented technical and organizational precautionary measures, in accordance with industry best practices, designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, disclosure, loss, deletion, or destruction. All information you provide to us is stored on our or our trusted service providers’ secure servers behind firewalls.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures made available or incorporated in the Services.

Data Retention

We will only keep your information, including any personal information, for as long as necessary to fulfill the purposes for which we collected it, to comply with our legal obligations, or to enforce our legal rights (or as required so others may enforce their legal rights).

Except as provided elsewhere in this Privacy Policy, alulu limits access to your personal information, regardless of if it is stored electronically or in physical form, to those persons (including employees and contractors) in our organization who have a business need for such access.

Generally, the length of time we keep your information will depend on the type of information and the purpose for which we are processing it. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we are processing it and whether we can achieve those purposes through other means, and any applicable legal requirements.

At the end of the appropriate retention period, we will either delete your information from our systems completely or anonymize it so it can be used without identifying you and so we no longer have the ability to re-associate the anonymized information with you in the future, such as by aggregating the information.

If you would like more information about our retention practices, please contact us using the information provided in the “Contact Information” section below.

Contact Information

To ask questions or comment about this Privacy Policy and our privacy practices, or to register a complaint or concern, contact us at:

alulu Corporation
ATTN: Legal Department
1775 Tysons Boulevard
Suite 4176
Tysons, VA 22102 USA
Email: privacy@alulu.io

alulu - Legal