Effective date: September 19, 2022
Oooh (“Oooh,” “we,” “our,” or “us”) has developed a social platform to provide a more enriching, safer, and fun place for all audiences, including children, teens, and adults, to spend their time online. Oooh is committed to protecting the privacy of all users (both children and adults) of the Oooh mobile application and associated services (together, referred to as the “Platform”).
A note on information collected from children. As set forth in the U.S. Children’s Online Privacy Protection Act (“COPPA”), we will only collect personal information (as defined by COPPA) from children with appropriate parental consent, or as otherwise permitted by COPPA (if there is an exception to consent, for example). Before a parent provides consent (or if they do not consent), a child can use Oooh with limited functionality, but they will not be able to submit personal information (such as registration information or videos), share content with other users, or use Oooh’s social features. Without such consent, we only collect minimal device or browser information to support the operations of the Platform for such limited functionality. If we become aware that we have inadvertently collected personal information from a child in a manner inconsistent with COPPA’s requirements, we will seek to obtain parental consent, and if such consent is not obtained, we will delete such information. If you are a parent concerned that your child is using the Platform without your consent, please contact us as set forth in “Contact Us” below.
The Information We Collect and How We Use It
Oooh is a social content platform that allows users to watch, participate in, and create interactive videos with other users and creators. Below we have summarized how and when we collect information to provide these features and how we use it. These activities will in part depend on what type of user you are (i.e., general user (including children and their parents) or a creator). Please note that if you choose not to share certain information with us, some features may not function as intended or at all. This section discusses our information practices with respect to each type of user.
1. Information We Collect from All Users, Including Children and their Parents and Creators
We collect the following types of information from users of the Platform, and use it in the following ways:
Age and Contact Information.
To participate in the Platform, we require all participants to disclose their age. We will also collect an email address and phone number to provide further instructions related to using the Platform and to send Platform updates. If a user indicates that he/she is a child, we will ask that user to provide a parent or guardian’s email address so that we can seek consent from the parent before the child participates on the Platform. If we do not receive parental consent within a reasonable time, we will delete the parent’s contact information and any other personal information submitted by the child. If the parent consents, we will keep the parent’s email address on file in case we need to contact the parent in the future.
User and Profile Information.
With your permission through the Platform, we will access phone numbers from your device contacts (and store them in a hashed form) so we can notify you when a contact joins the Platform and so you can invite contacts to join. This access can be turned off through device settings at any time.
Financial and commercial information.
Credit card numbers or other third-party payment information are collected by our third-party payment processors or the applicable app store where you make a purchase to process payments and fulfill your transactions with us. We collect and use records of your transactions with us to fulfill your orders.
Video and Other Audio-Visual Content.
Users have the ability to create video and other audio-visual content that may contain their image, likeness, or voice. Such content can be viewed by any creators to which you submit that content, and also to other users if that content has gone through moderation and either (i) has been selected by a creator (by incorporating or featuring such content) or (ii) you have earned an achievement (such as by topping a leaderboard or completing a skill). If you are a creator (including if you earn sufficient experience points to be able to host your own content as discussed further below), other users can view the content you post, including your submissions to other creators. In addition, if you share content with creators, they can choose to include that content in their creations, which they may share via their home feed. Users are responsible for the video and audio content that they choose to post on the Platform. If your video or audio content contains the image or voice of another person, please be sure you have their permission before posting.
We may also collect information about the images and video that are a part of your content, such as objects and/or body or face landmark locations (“Positional Data”) within an image or video that appear in your ooohs when you decide to join an oooh. We collect Positional Data to allow users to add special effects to their content, to facilitate interactivity (e.g., AR-like video gameplay), for content moderation, and for other similar content enhancement purposes. THIS INFORMATION IS NEVER USED TO IDENTIFY YOU, OR ANY SPECIFIC FACES OR BODIES.
In most cases any Positional Data is not stored by our servers and is only computed and rendered locally on your device before being discarded from your device. Some of our ooohs use this Positional Data to see how it changes in order to create a score, which is all done locally on a user's device (never transmitted or stored by us) and then this data is discarded.
For example, in an oooh called “Try Not to Laugh” the app on your device will look at a small set of face landmark points, to determine if your mouth moved up while you were recording that oooh (if it does your score drops, and at the end all we record and store is your score for that oooh).
In other ooohs, we may create and store a scoring template of changes in Positional Data so that one user's recorded oooh can be scored relative to another user. To do this, we observe where feature landmarks (e.g., the outline of a ball (object data), your mouth (face landmark data), a shoulder (body landmark data)) are located and how they change during the course of that oooh.
For example, in an oooh called “Dance Battle” a user makes a video of themselves doing a dance (they are the 'host' of this oooh), and while recording this oooh our technology observes the locations of the host’s shoulders or elbows throughout the dance. A player who then chooses to join that oooh records themselves trying to recreate that dance as closely as possible. Our technology compares this player’s Positional Data (e.g., where their shoulders are in the video) vs. the host's on the player’s device to create a score. That player's specific Positional Data is never stored or transmitted by us and is discarded after the score is generated.
In the limited cases where Positional Data a user creates is stored on our servers (or stored locally on a user’s device) it is always able to be deleted by that user by deleting the oooh where the Positional Data is bound. We never separate or copy any Positional Data a user might create from the oooh that it was created in and it is bound to, nor do we share Positional Data with any 3rd parties.
In some cases we may also use this data as an ’anti-cheat’ or verification to check that a user was actually on camera during the recording of that oooh, to help foster a more trusting environment and validate that real users’ participation and skill were responsible (and therefore not 'bots' or some other mechanism for cheating) for the actions taken in the oooh.
Activity and Usage Data.
Survey responses & feedback.
From time to time, we may request or you may provide feedback, including via surveys, regarding the Platform and its features. We will use this information solely for purposes of enhancing and improving the Platform.
If you submit a question to us seeking customer support or making a general inquiry, we may collect your name and email and any other information you provide. We will use this information to respond to your request and to monitor our customer service responses.
2. Information We Collect from Creators
We collect and use all of the same information from and about creators as we collect from users of the Platform as discussed above, as well as the following, additional information, which we use to determine your eligibility to be an Oooh creator, to establish creator profiles, for analytics, and to provide and promote the Platform:
We will collect basic contact information from you, including your first name, last name, e-mail address, mailing address, and country.
Financial and commercial information.
We collect credit or payment card numbers (through our third-party payment processor) or other third-party payment information (such as PayPal) to process payments or provide payments to you.
Social Media Information.
Depending on how we originally connect with you about becoming a creator, we may also ask you to provide your various social media handles from third-party platforms, your total number of online followers, your opinion on why you should be chosen as a creator, and other information about you and your creations.
If you are chosen as a creator, we will provide you with your own link to use on social media or in email to attract followers to the Oooh Platform. These links will include certain tracking technologies (such as web beacons) that allow us to track how many users come to our Platform via your links.
In addition to the purposes outlined above, we may use user data to enforce our Terms and policies, to detect fraud, to protect the Platform and its users, and to comply with applicable law,
3. Aggregate/De-Identified data
We may aggregate and/or de-identify any information collected through the Platform from all types of users so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”). We may use Aggregate/De-Identified Information for any purpose, including without limitation for research and marketing purposes, and we may also share such information with any third parties, including with our partners.
How We Disclose Information
We may share or disclose information collected from creators and users (including children) in the following circumstances:
- With our service providers in order for them to perform services on our behalf (such as Platform moderators who assist us in keeping the Platform safe)
- With our current and future investors and advisors, who are assisting us in further developing our Platform
- As permitted or required by law, including in response to a court order or a subpoena
- To protect the safety of a child, to prevent a crime, or to facilitate a public safety investigation
- To take precautions against liability
- To protect the security or integrity of our Platform
- If we are involved in a merger, acquisition, or sale of assets, user and creator information may be among the information shared, and we will comply with applicable legal notice and consent requirements if we ever share information in this way
Also, please note that because Oooh is an interactive, social Platform, any content you post, games you play, or leaderboard information can be seen by other users and creators. Such content may be shareable both on and off the Platform. For example, if you upload content in response to a creator, the creator may re-post that content. It will then be viewable by other users, including the creator’s followers. Creator-selected and moderated content will also be viewable in your profile, as will content that has earned an achievement (such as topping a leaderboard or completing a skill). If you earn sufficient experience points (as determined by us in our sole discretion), you will be permitted to host content and receive content from other users. Such content will be viewable in accordance with the settings of your account.
Accordingly, please think carefully about what you post on the Platform and how you use the Platform.
Parental Choices and Controls
Parents or guardians may contact firstname.lastname@example.org to request review of or request deletion of their child’s personal information and/or refuse to permit us to further collect or use personal information from their child. Please note that a request to delete your child’s information may terminate their account, as such information are necessary for operating the Platform. Moreover, if you request deletion of your child’s content, it may impact or require removal of certain creator’s content if they have incorporated your child’s content.
Important Information for California Residents
If you are a California resident, California law may require us to provide you with additional information regarding how we collect, use, and share your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)).
1. Categories of Personal Information We Collect and How We Use and Share Them
- Personal identifiers (such as name, user email address, phone number, and parent email address)
- Device identifiers (such as IP address)
- Internet or other network or device activity (such as usage information)
- Geolocation information (e.g., your approximate location based on IP address and the country you provide)
- Physical characteristics or description (including your image or voice)
- Visual and audio materials (from videos you post)
- Other information that you provide (including your social media handles and favorite apps)
We use and share the categories of personal information we collect from and about you consistent with the various business purposes we discuss throughout this Policy. See the “The Information We Collect and How We Use It” and “How We Disclose Information” sections above for more information. Please note that the CCPA sets forth certain obligations for businesses that “sell” personal information to third parties. We do not engage in such activity.
2. Your California Privacy Rights
CCPA Rights Disclosure. If you are a California resident, the CCPA allows you to make certain requests about your personal information (e.g., requests for more information, access, or deletion). The CCPA further provides you with the right to not be discriminated against (as provided for in applicable law) for exercising your rights. Please note that certain information may be exempt from such requests under California law. For example, we need to retain certain information in order to provide the Platform to you. We also will take reasonable steps to verify your identity before responding to a request. If you would like further information regarding your legal rights under California law or would like to exercise any of them, please contact us at email@example.com
3. California Shine the Light Disclosure
If you are a resident of California, you can request a list of all the third parties to which we have disclosed certain personal information (as defined by CA law) during the preceding year for those third parties’ direct marketing purposes. However, we do not share personal information (as defined by such law) with third parties for their direct marketing purposes.
How We Protect Your Information
We use a variety of administrative, technical, and physical safeguards to protect your information against accidental or unlawful destruction or loss, alteration, or unauthorized access. However, no method of transmission over the Internet, and no means of electronic or physical storage, is absolutely secure.