Orbu: Data Policy

Data Policy This policy describes the information we process to support products and features offered by Places App, Inc, dba Honeycommb (Products).

I. What kinds of information do we collect? Things you and others do and provide.

• Information and content you provide. We collect the content, communications, and other information you provide when you sign up for an account, create or share content, message or communicate with others. This can include information in or about the content you provide (like metadata), such as the date a file was created, file dimensions, file types. Our systems automatically process content and communications you and others provide to analyze context and what’s in them for the purposes of improving user experience.

• Networks and connections. We collect information about the people, accounts, hashtags, and groups you are connected to and how you interact with them across our Products, such as people you communicate with the most or groups you are part of.

• Things others do and information they provide about you. We receive and analyze content, communications and information that other people provide when they use our Products. This can include information about you, such as when others send a message to you.

Device Information. As describe below, we collect information from and about the computers, phones, and other web-connected devices you use that integrate with our Products, and we combine this information across different devices you use.

Information we obtain from these devices include:

• Device attributes: information such as the operating system, hardware and software versions, device carrier, and display sizes.

• Device operations: information about operations and behaviors performed on the device, such as whether a window is foregrounded or backgrounded, or mouse movements.

• Identifiers: unique identifiers, device IDs, and other identifiers such as associated provider account identifiers.

• Data from device settings: information you allow us to receive through device settings you turn on, such as access to your GPS location, camera, or photos.

• Network and connections: information such as the name of your mobile operator or ISP, language, time zone, and IP address.

• Cookie data: data from cookies stored on your device, including cookie IDs and settings.

Information from partners. Advertisers and publishers can send us information through APIs to our platform. These partners provide information about your activities outside of our Products including information about your devices and websites you visit - whether or not you have an account or are logged into the platform.

Partners receive your data when you visit or use their services or through third parties they work with. We require each of these partners to have lawful rights to collect, use and share your data before providing any data to us.

II. How do we use this information? We use the information we have (subject to choices you make) as described below and to provide and support the Products and related services. Here’s how:

Provide, personalize and improve our Products. We use the information we have to deliver our Products, including to personalize features and content and make suggestions for you. To create personalized Products that are unique and relevant to you, we use your connections, preferences, interests and activities based on the data we collect and learn from you and others; how you use and interact with our Products, and the people, places, or things you’re connected to and interested in on and off our Products.

• Location-related information: We use location-related information-such as your current location, where you live, the places you like to go-to provide- to personalize and improve our Products, including ads, for you and others. Location-related information can be based on things like precise device location (if you’ve allowed us to collect it), IP addresses, and information from you and others’ use of our Products.

• Product research and development: We use information we have to develop, test and improve our Products.

• Ads and other sponsored content: We use the information we have about you-including information about your interests, actions and connections-to select and personalize ads, offers and other sponsored content that we show you.

Provide measurement, analytics, and other business services. We use the information we have to help advertisers and other partners measure effectiveness and distribution of their ads and services.

Promote safety, integrity and security. We use the information we have to verify accounts, and activity, combat harmful conduct, detect and prevent spam and other bad experiences, maintain the integrity of our Products, and promote safety and security on and off of our Products.

Communicate with you. We use the information we have to send you marketing communications, communicate with you about our Products, and let you know about our policies and terms. We also use your information to respond to you when you contact us.

III. How is this information shared? Your information is shared with others in the following ways:

Sharing on our Products

• People and accounts you share and communicate with. When you share and communicate using our Products, you are sharing with the audience that you select. For example, when you post generally, you are sharing to all members of the community. Similarly, when you post to a group, the post is shared with the members of the group as well as the community, dependent on the group’s settings. Your network can also see actions you have taken on our Products, including engagement with ads, sponsored posts, other posts, and other users.

Public information can be seen by anyone, on or off our Products, including if they don’t have an account. This includes your username, any information you’ve share with a public audience. Public information can also be seen, accessed, reshared, or downloaded through third-party services such as search engines, and APIs.

• Content others share or reshare about you. You should consider who you choose to share with, because people who can see your activity on our Products can choose to share it with others on and off our Products, including people and businesses outside the audience you shared with. Also, when you comment on someone else’s post, your comment is visible to anyone who can see the other person’s content.

  • New Owner. If the ownership or control of all or part of our Products or their assets changes, we may transfer your information to the new owner.

Sharing with Third-Party Partners We work with third-party partners who help us provide and improve our Products. We don’t sell any of your information to anyone, and we never will. We also impose strict restrictions on how our partners can use and disclose the data we provide.

• Partners who use our analytics services. We provide aggregated statistics and insights that help people and businesses understand how people are engaging with posts, videos, and other content on and off our Products.

• Advertisers. We provide advertisers with reports about the kinds of people seeing their ads and how their ads are performing. We don’t share information that personally identifies you (information such as your name or email address).

• Measurement Partners. We share information about you with companies that aggregate it to provide analytics and measurement reports to our partners.

• Vendors and service providers. We provide information and content to vendors and service providers who support our business, such as by providing technical infrastructure services, analyzing how our Products are used, providing customer service, facilitating payments or conducting surveys.

• Law enforcement or legal requests. We share information with law enforcement or in response to legal requests.

IV. How can I manage information about me? We provide you with the ability to access, rectify, port and erase your data.

We store data until it is no longer necessary to provide our services or until your account is deleted - whichever comes first. This is a case-by-base determination that depends on things like the nature of the data, why it is collected and processed, and relevant legal or operational retention needs.

When you delete your account, we delete things you have posted, such as your photos or posts, and you won’t be able to recover that information later. Information that others have shared about you isn’t part of your account and won’t be deleted.

V. How do we respond to legal requests or prevent harm? We access, preserve and share your information with regulators, law enforcement or others:

• In response to a legal request (like a search warrant, court order or subpoena) if we have a good faith belief that the law requires us to do so. This may include to legal requests from jurisdictions outside of the United States when we have a good faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards.

• When we have a good faith belief it is necessary to: detect, prevent and address fraud, unauthorized use of our Products, violations of our terms or policies, or other harmful or illegal activity; to protect ourselves (including our rights, property, or Products), you or others, including as part of investigations or regulatory inquiries, or to prevent death or imminent bodily harm. For example, if relevant, we provide information to and receive information from third-party partners about the reliability of your account to prevent fraud, abuse and other harmful activities on and off our Products.

Information we receive about you can be accessed and preserved for an extended period when it is the subject of a legal request or obligation, governmental investigation, or investigations of possible violations of our terms or policies, or otherwise to prevent harm. We also retain information from accounts disabled for terms violations for at least a year to prevent abuse or other term violations

VI. How will we notify you of changes to this policy? We will notify you before we make changes to this policy and give you the opportunity to review the revised policy before you choose to continue using our Products.