Belong Privacy Policy

Last updated: July 12, 2021


This Privacy Policy applies to your access/use of the Belong mobile application (hereinafter “App” or the “Service”). The App is owned and operated by Impact Incubation LLC, a company formed and operating in accordance with the laws of the State of Nevada and federal laws of the United States of America (hereinafter “the Company,” “we,” “us,” or “our”).


This Privacy Policy describes how we collect, use, share and secure your personal data when you make use of the App and your rights as a data subject. We will not use or share your personal data with anyone except as described hereunder. By installing the App and signing up for a user account, you agree to the collection and use of your personal data in accordance with this Privacy Policy.


1.Who is covered by this Privacy Policy?

This Privacy Policy covers individuals who sign-up for a user account and those who subscribe to our mailing list.


2.Definitions

Unless expressly specified hereunder, all the words used in this Privacy Policy shall have the same meaning as defined in our Terms and Conditions:


  1. ‘Data Controller,’ ‘Personal Data’ and ‘Processing’ shall have the same meaning as defined in Article 4 of the EU General Data Protection Regulation 2016/679 (EU GDPR);


  1. ‘Data Subject’ means a natural person whose personal data is processed by the Company or its processors. 


3.What information do we collect, and how do we use it?

There is some personal data that you voluntarily provide us when you sign-up for a user account on the App, when you subscribe to our mailing list, when you send us enquiries and support requests, etc., and there is some personal data that we are able to collect automatically from your use of the Service. Regardless of whether we receive your personal data directly from you or automatically, we will only process it if we have a legal basis to do so, such as your express consent, the performance of a contract, or legitimate interest.


You may decline to submit any personal data that you do not wish to provide us with. However, you understand that your refusal to provide any information required for the provision of the Service may result in us not being able to provide the Service to you. 


We process the following personal data for our users:

3.1.User Account Data

When you register a user account on the App, you must provide us with your mobile phone number and full name. You also have the option to provide your profile photo and email id if you wish to do so, but this information is not mandatory.  


How do we use this data?

We use your user account data:


  • To verify your phone number;

  • To create your user account; and

  • To enable you to use the Services as intended.


Legal basis

The legal basis we rely upon for processing this data is Article 6(1)(b) of the EU GDPR, which provides that data may be processed if such processing is required for the performance of a contract.


Data Retention

We will keep your user account data until your user account is terminated. We will remove your user account data from our database within six months from the date of your account termination. Please note that we may be allowed to keep your user account data for a longer duration on other lawful grounds. 


3.2.User Content Data

Your User Content Data includes all your user content on the App, such as the events you create, the photographs you upload, your full name, email address and the content of any inquiries/support requests you send to the Company.


Your User Content data also includes any personal information we receive from you about your contacts when you authorize us to access your phone book, such as your contacts’ name, phone number, photo, email address, or manually add a contact to the App.


How do we use your User Content Data?

We use your User Content Data for purposes, including but not limited to:

  • Delivering, maintaining and improving the Service to our users;

  • Enabling our users to easily add their contacts from their phone;

  • Responding to users support requests/enquiries and resolving any issues;

  • Detecting and preventing any unauthorized activities, including spam.


Legal basis

The legal basis we rely upon for processing this data is Article 6(1)(f) of the EU GDPR, which provides that data may be processed if the controller has a legitimate interest and data processing does not override the data subject's rights.


Data Retention Duration

We will retain all your User Content Data for the entire duration your user account is active on the App. If your user account is terminated, we will remove all your User Content Data within 6 months of your user account termination.


If you do not have a user account, we retain your personal data associated with your inquiry for a maximum period of three months from the date of last communication. We will safely remove all personal data linked to your inquiry from our records after three months unless we have another legal basis for processing this data.


3.3.Marketing Data  

When you subscribe to receive direct marketing communication from us, such as our newsletter, you provide us with your full name and your email address.


How do we use your data?

We will use your data to send you direct marketing material.


Legal basis

The legal basis we rely upon for processing this data is Article 6(1)(a) of the EU GDPR, which provides that data may be processed if the data subject freely grants his/her consent for such processing.


Data Retention Duration

Your marketing data is only retained as long as you are subscribed to receive such communication. You can opt-out of receiving marketing communication from us by clicking the unsubscribe button in our marketing email. If you wish, you can also send your request to opt-out by emailing us at general@impactincubation.com using the same email that you used to subscribe to the newsletter, and we will immediately remove you from our mailing list.


3.4.Log data

We may automatically collect some data from you when you make use of the App, such as:

  • Your phone logs (date and time when you connected with your contact);

  • Your facetime logs (date and time when you connected with your contact);

  • Your message logs (date and time when you connected with your contact); and

  • Email logs (date and time when you connected with your contact)


How do we use this data?

We use this data to:

  • Send you reminders to connect with your contacts according to your relationship goals; and

  • Maintain and improve our Service.


Legal basis

We rely upon Article 6(1)(b) of EU GDPR as the legal basis for the processing of this personal data. Article 6(1)(b) provides that data processing of data during the performance of a contract is lawful.


Data Retention Duration

Your log data is only retained for as long as your user account is active on the App. We will terminate your log data within 6 months of your user account termination.


3.5.Analytics Data

Google Analytics for Firebase

We make use of Google Analytics for Firebase, which uses data to provide us with analytics information such as the session duration, operating systems, device models etc. To learn more about Google’s use of this analytics data, please visit Google’s Partner Policy, Privacy and Security in Firebase and Google’s Privacy Policy.


Crashlytics

When you access and use our App, Crashlytics automatically collects certain information from your usage, including but not limited to the device state information, unique device identifiers, device hardware and operating system information, and information relating to how our app functions. Please note that Crashlytics may aggregate and anonymize the data to improve their service. Aggregated and anonymized data cannot be linked back to an individual user. To learn more about Firebase Crashlytics’ privacy policy, please visit https://firebase.google.com/products/crashlytics?utm_source=crashlytics_marketing&utm_medium=redirect&utm_campaign=crashlytics_redirect


Legal basis

The legal basis we rely upon for processing this Analytics Data is Article 6(1)(f) of the EU GDPR, which provides that data may be processed if the controller has a legitimate interest and data processing does not override the data subject's rights.


4.Sharing your personal data

We will not sell or rent your personal data to any third party. Your personal data may be shared with third parties in the following circumstances:


  • With other users you invite to your event

The App enables you to invite other users to an event planned by you. Please note that by default all the content linked to your event, such as event details, participants, and photographs, will be shared with all users who are invited to that event through the App. If you do not wish to make all event-related content visible to all invitees, you should change your default privacy settings to your preferred visibility setting.


  • Our third-party service providers

Our third-party service providers may have access to your personal data to the extent necessary to deliver the Services on our behalf. 


  • Commercial transactions

If we undergo a merger, acquisition, or any other commercial transaction such as the sale of our business, our users’ personal data will be disclosed to the other entity as part of initial due diligence and will be transferred to the new entity if we conclude the commercial transaction.


  • Valid requests for information

We may be obliged to share your personal data with any local or international law enforcement authorities, governmental bodies or in the event, we are ordered or subpoenaed by a court of law to do so.


  • Legal action

If we are ever involved in any legal action arising from our Agreement with you, we may disclose your personal data to the extent required to assert our rights or defend any claims against us.


  • Email distribution tools

We may make use of third-party email distribution tools to send marketing emails to our subscribers. If you opt-in to receive our newsletter, your name and email address will be stored on these email distribution tools.


5.Data Subject Rights

As a data subject, your rights relating to your personal data that we hold are as follows:


  • Right to access your personal data

As a data subject, you may request what personal data we have for you.


  • Right to rectification

As a data subject, you may request rectification of any incorrect or incomplete information we hold about you.


  • Right to withdraw consent

If you subscribe to receive our newsletter by opting in, you can withdraw your consent by clicking the “unsubscribe” button in our marketing email.


  • Right to erasure of personal data

In limited circumstances, you may exercise your right to request the erasure of your personal data, such as where your personal data is being processed unlawfully or where your personal data is retained for a longer period than specified in our data retention policies.


  • Right to lodge a complaint

If you are in the European Economic Area (EEA), you may also exercise the right to lodge a complaint against any infringement of your privacy rights by contacting your local data protection authority.


6.California Residents

Impact Incubation LLC does not sell your personal data to any third parties. If you are a California resident, California Civil Code Section 1798.83 grants you the right to request information regarding the disclosure of your personal information by the Company to third parties for direct marketing purposes. If you wish to make a request, please contact us at the contact details provided at the bottom of this Privacy Policy. We will make our best effort to respond to you within 14 business days.


As a California resident, you may request access to the specific personal data that we have collected about you in the preceding year. You also have the right to request information about our privacy practices, how we collected your personal data, parties with whom we share your personal data. You may make specific requests to exercise the aforementioned rights by sending a support request.


7.Security of your data

We care about the security of data, and we use industry best practices to ensure that your data is protected from all unauthorized access, use, modification, destruction and accidental loss. However, the technical realities of our present world mean that despite our best efforts, no mode of digital storage and transmission of data over the internet is completely secure. Therefore we cannot offer you any guarantees as to the security of the data that we store.


8.Transfer of your data

We are operating from the United States, and we will process your data within the United States as well as other parts of the world. If you are located in a European Economic Area (including the United Kingdom or Switzerland), we will transfer your data outside of the EEA, UK, and Switzerland to the United States as well as other third countries where the data protection laws are not as strict as those in the country of your residence.


Whenever we transfer your data to the United States or any country outside of the EEA, which does not offer adequate protection to your personal data, we will take all the steps necessary to protect your data as provided by the European Commission.


9.Third-Party Links

Our App may contain links that will redirect you to third-party websites. Such third-party websites are not owned or operated by us. These third-party websites are governed by their own legal Terms and Conditions and Privacy Policy. We advise our users to review all third-party Terms and Privacy Policy before making use of such websites. You understand that the presence of any third party links on our App does not constitute an endorsement of such a third party, and we cannot be held responsible for such a third party’s actions.


10.Changes

We may amend this Privacy Policy from time to time. If we make any material changes to this Privacy Policy, we will notify you by email (if you have consented to receive communication from us) or by updating the last modified date on the top of the page where this Privacy Policy appears. It is solely your responsibility to periodically review this Privacy Policy to familiarise yourself with any changes.


11.Protection of Children’s Privacy

We do not target our website to anyone under the age of thirteen (13) years ("Children"). If you are the parent or legal guardian of a child who you believe has provided us with his/her personally identifiable information, please contact us, and we will immediately investigate the matter and take appropriate steps.


12.Data Controller

The Company is the data controller for the personal data that we collect from you through the App. If you have any questions relating to our privacy practices, this Privacy Policy, or if you wish to exercise your data rights, please contact us at:


e-mail:             general@impactincubation.com


Address:          361 Borgato Ct, Las Vegas NV 89145