Welcome to Sense Social (the “Platform”). We are committed to protecting and respecting your privacy and this policy sets out the basis on which we process any personal data we collect from you, or that you provide to us. Where we refer to “Sense Social”, “we” or “us” in this Privacy Policy, we mean Hub Sense Limited, a UK company.

SUMMARY

What information do we collect about you?

We collect and process information you give us when you create an account and use the Platform. This includes technical and behavioural information about your use of the Platform. 

How will we use the information about you?

We use your information to provide the Platform to you and to improve and administer it. In order to provide an effective and dynamic Platform, and where we have determined it is in our legitimate interests, we use your information to improve and develop the Platform, prevent crime and ensure users’ safety. Where we have your consent, we will also use your personal data to serve you targeted advertising and promote the Platform. 

Who do we share your information with?

We share your data with third party service providers who help us to deliver the Platform including cloud storage providers. We also share your information with business partners, other companies in the same group as Sense Social, content moderation services, measurement providers, advertisers and analytics providers. We may share your information with law enforcement agencies, public authorities or with other third parties only where we are legally required to do so or if such use is reasonably necessary (for instance, to ensure your or someone else’s safety). 

Your Rights

You have the following rights: you can ask us to delete your data; to change or correct your data; to provide a copy of your data and to stop using some or all of your data. To make these requests, email privacy@hubsense.co.uk, and we will review your request in accordance with applicable laws.

How long do we keep hold of your information?

We retain your information for as long as it is necessary to provide you with the service so that we can fulfil our contractual obligations and exercise our rights in relation to the information involved. Where we do not need your information in order to provide the service to you, we retain it only as long as we have a legitimate business purpose in keeping such data or where we are subject to a legal obligation to retain the data. We will also retain your data if necessary for legal claims. 

How will we notify you of any changes to this Privacy Policy?

We will notify all users of any material changes to this policy through a notice on our Platform or by other means. We update the “Last Updated” date at the top of this policy, which reflects the effective date of the policy. By accessing or using the Platform, you acknowledge that you have read this policy and that you understand your rights in relation to your personal data and how we will collect, use and process it. 

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1. The types of personal data we use

We collect and use the following information about you:

Your Profile Information

You give us information when you register on the Platform, including your name, date of birth, email address and/or telephone number, information you disclose in your user profile and your photograph.

User Content and Behavioural Information

We process the content you generate and view on the Platform, including preferences you set (such as categories of interest), photographs, and activities you make (“User Content”). We collect information through surveys, challenges and competitions in which you participate. We also collect information regarding your use of the Platform, e.g. how you engage with the Platform, including how often you use the Platform and how you interact with content we show you, the ads you view, activities you view and problems encountered, the content you like, the words you search and the users you follow. 

We infer your interests, gender and age for the purpose of personalising content. We also infer the interests of our users to better optimise advertising across our Platform. If you have consented, we will use this information for the purpose of serving personalised advertising. 

We review User Content for content moderation purposes to enforce our community guidelines, comply with legal obligations, and prevent and respond to abuse, fraud, illegal activity and other potentially harmful content on the Platform. 

Messages

Where local laws allow us to, we collect and process your messages, which includes scanning and analysing the information in those messages through the Platform’s messaging functionality. That information includes the content of the message and information about when the message has been sent, received and/or read, as well as the participants in the communication.

We do this to prevent and block spam, prevent and detect crime, safeguard children (where this is in the substantial public interest) or to protect the interests of our users and other people. 

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

Information from Third Parties

You may choose to share certain data with us from third parties or, through your use of the Platform, we may collect such third party data automatically.  

Business Partners

If you choose to register your social media account details (e.g. Facebook, Twitter, Instagram, Google) to the Platform, you will provide us or allow your social network to provide us with your username and public profile. We will likewise share certain information with the relevant social network such as your app ID and access token. 

Advertisers and Measurement Partners

Where you have consented to personalised advertising, we will match your information e.g. your mobile advertising ID, where it is provided to us by advertisers and other partners, with your Sense Social profile to serve you ads. We may also serve you ads based on the information we infer from the data these partners provide. 

We use information provided by our measurement partners, to understand how you’ve interacted with our ad partners’ websites and better assess the effectiveness of the advertising on our Platform. 

Technical Information we collect about you

We collect certain information from you when you use the Platform. Such information includes your IP address, instance IDs (which allow us to determine which devices to deliver messages to), mobile carrier, time zone settings, identifier for advertising purposes and the version of the app you are using. We will also collect information regarding the device you are using to access the Platform such as the model of your device, the device system, network type, device ID, your screen resolution and operating system, audio settings and connected audio devices. Where you log-in from multiple devices, we will be able to use your profile information to identify your activity across devices.

Location

When you use the Platform on a mobile device, we will collect information about your location in order to customise your experience. We infer your approximate location based on your IP address. In certain jurisdictions, we may also collect Global Positioning System data.

Information about your friends

You can choose whether to find other users of the Platform and invite your contacts to join you on the Platform. We will use the contact information you have for that person, such as from within your telephone’s contact list or Facebook friends list, and give you the option to send them either an SMS, email or third party message (such as Whatsapp, Facebook Messenger or Twitter) inviting them to view your TikTok profile.  

We use your personal data to find matches based on your contact information and your address book. However, your contact information and your address book is private and will not be disclosed. We use a technical system to find matches without sending your own information or your address book to us in plain text. 

If you want to find other users through your Facebook contacts, you can grant us access to your Facebook contact list. We will then collect your public Facebook information as well as names and profiles of your Facebook contacts. We will match this to registered users and show you any matches so you can follow them. 

Information you provide to us 

We collect information you provide us in response to a survey. If you respond to a Sense Social survey, your individual responses will be used for the purpose of the survey and will be shared with other organisations, as explained to you when you participate in a survey. We may also use aggregate data from these surveys in the same way.

We also collect information you provide to us in correspondence.  

2. Cookies

Cookies and similar technologies (e.g. pixels and ad tags) (collectively, “Cookies”) are small files which, when placed on your device, enable us to collect certain information, including personal data, from you in order to provide certain features and functionality. We and our service providers and business partners use Cookies to collect data and recognise you and your device(s) on the Platform and elsewhere across your different devices. We do this to better understand the effectiveness of the advertising on the Platform and to enhance your user experience.  

3. How we use your personal data

We will use the information we collect about you based on the legal grounds described below.

In accordance with, and to perform our contract with you, we will use your information to:

• provide the Platform and associated services;

• notify you about changes to our service;

• provide you with user support;

• enforce our terms, conditions and policies;

• administer the Platform including troubleshooting;

• personalise the content you receive and provide you with tailored content that will be of interest to you;

• enable you to share User Content and interact with other users;

• enable our messenger service to function if you choose to use it and are 18 or above;

• communicate with you.

In order to comply with our legal obligations and as necessary to perform tasks in the public interest or to protect the vital interests of our users and other people, we use your data to help us prevent and respond to abuse, fraud, illegal activity and other potentially harmful content on the Platform.

In accordance with our legitimate interests to provide an effective and dynamic Platform, we may use your information to:

• ensure your safety and security, including reviewing User Content, messages and associated metadata for breaches of our Terms of Service;

• ensure content is presented in the most effective manner for you and your device;

• understand how people use the Platform so that we can improve, promote and develop it;  

• promote popular topics, hashtags and campaigns on the Platform;

• carry out data analysis and test the Platform to ensure its stability and security;

• verify your identity, for example, to enable you to have a ‘verified account’, and your age, for example, to ensure you are old enough to use certain features;

• provide non-personalised advertising, which keeps many of our services free; 
• infer your interests for optimising our advertising offerings, which, where you’ve consented to personalised advertising, may be based on the information our advertising partners provide to us;
• measure the effectiveness of the advertising you see on our Platform;
• inform our algorithms so we can deliver the most relevant content to you and to prevent crime and misuse of the Platform;

• carry out surveys regarding our services, products and features; 

• allow you to participate in interactive features of the Platform; and
• enable you to socialise on the Platform. For example, we may allow other users to identify you through their phone contacts.

Where we process your information to fulfill our legitimate interests, we conduct a balancing test to check that using personal data is really necessary for us to achieve our business purpose. When we carry out this balancing test we also take into account the privacy rights of our users and put in place appropriate safeguards to protect their personal data.

4. How we share your personal data

We share your data with the following selected third parties:

Business Partners

• If you choose to register to use the Platform using your social network account details (e.g. Facebook, Twitter, Instagram, Google), you provide us or allow your social network to provide us with your username and public profile. We will likewise share certain information with the relevant social network such as your app ID, access token and the referring URL.

• Where you opt to share content on social media platforms, the activity, name and any text associated with the post will be shared on that platform or, in the case of sharing via instant messaging platforms such as Whatsapp, a link to the content will be shared.

Service Providers

• We provide information and content to service providers who support our business, such as cloud service providers and providers of content moderation services to ensure that the Platform is a safe and enjoyable place.

Analytics and measurement providers

• We use analytics and measurement providers to help us improve the Platform including by assisting us with content measurement and following your activity on our Platform across your devices. 
• Our third party analytics and measurement providers also help us measure advertising on our Platform and help our advertisers determine whether their advert has been shown on our Platform and how it performed. We share your mobile advertising ID and other device data with measurement companies so that they can link your activity on the Platform with your activity on our advertisers’ websites.

Advertisers

• We only share aggregated user information with advertisers. Aggregated information is information that is grouped together and is not specific to an individual user. This is done to help measure the effectiveness of an advertising campaign by showing advertisers how many users of the Platform have viewed or clicked on an advertisement. 

Our Corporate Group

• We may share your information with other members, subsidiaries, or affiliates of our corporate group where it is necessary to provide the Platform in accordance with the Terms of Service. 
• We share information to improve and optimise the Platform, including to prevent illegal use and to support users.

Law Enforcement / Legal Obligation

• We may share your information with law enforcement agencies, public authorities or other third parties if we consider that we are legally required to do so or if such use is reasonably necessary to:
• comply with a legal process or request;

• enforce our Terms of Service and other agreements, policies, and standards, including investigation of any potential violation;

• detect, prevent or otherwise address abuse, fraud, illegal activity or security or technical issues; or

• protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).

Public Profiles

• If your profile is public, your content will be visible to anyone on the Platform and may also be accessed or shared by your friends and followers as well as third parties such as search engines, content aggregators and news sites. You can change who can see an activity each time you upload an activity. If your profile is public, other users can use your content to produce and upload further content, for example, by creating an activity similar to your own.

Sale or Merger

• We disclose your information to third parties:
• in the event that we sell or buy any business or assets (for example, as a result of liquidation, bankruptcy or otherwise). In such transactions, we will disclose your data to the prospective seller or buyer of such business or assets; or

• if we sell, buy, merge, are acquired by, or partner with other companies or businesses, or sell some or all of our assets. In such transactions, user information may be among the transferred assets.

5. Where we store your personal data

The personal data that we collect from you will be transferred to, and stored at, a destination inside the UK. For more information, please contact us at privacy@hubsense.co.uk.

6. Your Rights

We offer you settings to control and manage the personal data we have about you. 

You have the following rights:

• Access Your Data: You can ask us, free of charge, to confirm we process your personal data and for a copy of your personal data.

• Delete Your Data: You can ask us to delete all or some of your personal data. 

• Change or Correct Data: You can ask us to change or fix your data. You can also make changes using the in-app controls and settings.  

• Portability: You can ask for a copy of personal data you provided in a machine readable form.

• Object or Restrict Use of Data and Withdraw Consent: You can ask us to stop using some or all of your data, e.g. if we have no legal right to keep using it. You can ask us to stop processing your personal data for direct marketing purposes; withdraw your consent or ask us to stop making any automatic individual decisions, including profiling. If you object to such processing, we ask you to share the reason for your objection in order for us to examine the processing of your personal data and to balance our legitimate interest in processing and your objection to this processing.

Before we can respond to a request to exercise one or more of the rights listed above, you may be required to verify your identity or your account details.

For information about how to make these requests, you can contact us using the contact information below, and we will review your request while considering applicable laws. Hub Sense Limited will be responsible for responding to your request within the relevant periods provided by law. 

7. The security of your personal data

We take steps to ensure that your information is treated securely and in accordance with this policy. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, for example, by encryption, we cannot guarantee the security of your information transmitted via the Platform, which means any transmission is at your own risk. 

We have appropriate technical and organisational measures to ensure a level of security appropriate to the risk that may be posed to you and other users. We maintain these technical and organisational measures and will amend them from time to time to improve the overall security of our systems.

We will, from time to time, include links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any information to these websites. 

8. How long we keep your personal data

We retain your information for as long as it is necessary to provide you with the service so that we can fulfil our contractual obligations and exercise our rights in relation to the information involved. Where we do not need your information in order to provide the service to you, we retain it only for so long as we have a legitimate business purpose in keeping such data. 

If you ask us to delete your account it will first be placed into a deactivated state for 30 days (to allow you to request it to be reinstated), followed by the deletion of the account. We will also delete personal data that relates to the in-app messaging function within 30 days of you cancelling your user account. Please note that messages sent to other users of our service are stored on their devices and cannot be deleted by us. 

In each case, there are also occasions where we may need to keep your data for longer in accordance with our legal obligations or where it is necessary for legal claims.

9. Information relating to children

Sense Social is not directed at children under the age of 18. If you believe that we have personal data about or collected from a child under the relevant age, please contact us at privacy@hubsense.co.uk.

10. Changes

We will notify you of any material changes to this policy through a notice provided via the Platform or by other means. The “Last Updated” date at the top of this policy reflects the effective date of such policy changes. 

11. Who we are and how to contact us

Hub Sense Limited provide the Platform and associated services, and together process personal data in the manner described in this policy and in our Terms of Service. 

If you have questions or complaints regarding this policy, or if you wish to contact Hub Senes Data Protection Officer, you can do so by emailing privacy@hubsense.co.uk.

If contacting us does not resolve your complaint you have the right to complain to your local data protection supervisory authority.