Privacy Policy for [App Name]
Effective Date: [YYYY-MM-DD]
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Scope
This Privacy Policy describes how [Company Name] (“we”, “us”, “our”) collects, uses, discloses, and protects personal information when you use the [App Name] mobile social application and related services. It applies to users globally, with region-specific disclosures for the European Economic Area (EEA), the United Kingdom (UK), and applicable U.S. state privacy laws (including California).
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Controller and Contact
- Data Controller: [Company Legal Name], [Address], [Country]
- Email: [privacy@company.com]
- Data Protection Officer (if applicable): [DPO Name], [DPO contact email]
- EU/UK Representative (if applicable under GDPR Art. 27): [Rep Name/Entity], [Address], [Email]
- Personal Information We Collect
We collect the following categories of personal information:
- Account and Profile Data: name, username, password, email address, phone number, profile photo, bio, settings.
- User-Generated Content: posts, photos, videos, comments, captions, hashtags, and metadata (timestamps, geotags if enabled).
- Social Graph and Interactions: follows, likes, shares, mentions, friend requests, and in-app activity signals.
- Messaging: messages and attachments you send via the app. Note: messages are processed to deliver and maintain service features; do not assume end-to-end encryption unless stated in product documentation.
- Device and Network Data: IP address, device identifiers (e.g., IDFA/AAID), device type, OS and version, app version, language, time zone, crash logs, diagnostics.
- Location Data: approximate location (e.g., IP-based). Precise location only if you grant permission in the app.
- Contacts: address book data only if you opt in for friend discovery; processed to match or suggest connections. Where feasible, we hash or minimize contact data and do not retain full address book contents.
- Cookies/SDKs and Online Identifiers: mobile SDK events, ad identifiers, session tokens, and similar technologies for authentication, analytics, and advertising.
- Payment and Purchases: transaction metadata (e.g., product, time, amount) received from app stores; we do not collect full payment card details.
- Support and Feedback: communications with support, problem reports, ratings, and survey responses.
- Sensitive Personal Information: we avoid collecting sensitive data (e.g., precise geolocation, health, race/ethnicity, biometric data) unless necessary for a feature you enable and with appropriate notice and consent.
Sources of Data:
- Directly from you (account setup, content submission).
- Automatically via the app and device.
- From third parties (e.g., authentication providers if you sign in with [Apple/Google/Facebook], app stores, analytics vendors, ad partners, or other users who share your contact information for friend discovery).
- Purposes and Legal Bases (GDPR)
We process personal information for the following purposes and under the identified legal bases:
- Provide and Operate the Service: account creation, authentication, content hosting, social features, messaging. Legal basis: performance of a contract (Art. 6(1)(b)).
- Safety, Integrity, and Moderation: detect spam/abuse, prevent fraud, secure accounts, enforce community guidelines. Legal basis: legitimate interests (Art. 6(1)(f)) and compliance with legal obligations (Art. 6(1)(c)).
- Analytics and Service Improvement: measure usage, diagnose issues, improve features. Legal basis: legitimate interests (Art. 6(1)(f)); where required for non-essential cookies/SDKs, consent (Art. 6(1)(a)).
- Personalization: recommend content, suggest connections. Legal basis: legitimate interests (Art. 6(1)(f)); consent where required.
- Marketing and Communications: send service-related notices; send marketing messages if you opt in. Legal basis: legitimate interests for service notices; consent for marketing (Art. 6(1)(a)).
- Targeted Advertising: show ads based on your activity and preferences. Legal basis: consent in the EEA/UK (Art. 6(1)(a)); opt-out rights in applicable U.S. states.
- Friend Discovery and Contacts Sync: match your contacts to other users. Legal basis: consent (Art. 6(1)(a)).
- Push Notifications: deliver alerts and updates. Legal basis: consent (Art. 6(1)(a)).
- Legal and Compliance: respond to lawful requests, handle claims, maintain records. Legal basis: legal obligation (Art. 6(1)(c)).
You may withdraw consent at any time via in-app settings or by contacting us.
- Disclosure of Personal Information
We disclose personal information to:
- Service Providers (Processors): hosting, storage, analytics, crash reporting, push notifications, customer support, security/fraud prevention, advertising technology vendors. These providers are bound by contract to process data only on our instructions.
- Other Users and the Public: content you post may be visible to other users or the public according to your settings.
- Advertising and Measurement Partners: identifiers and Internet/electronic network activity for ad delivery and measurement. In California, this may constitute “sharing” for cross-context behavioral advertising under the CCPA as amended by the CPRA.
- Authentication and Social Login Providers: if you choose to sign in via a third-party account.
- Authorities and Legal Requests: when required by law or to protect rights, safety, and security.
- Business Transfers: in connection with mergers, acquisitions, or asset sales, subject to applicable laws.
We do not sell personal information for monetary consideration. We may “share” personal information (e.g., identifiers, online activity) with ad partners for cross-context behavioral advertising; you may opt out as described below.
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International Data Transfers
If we transfer personal information outside your country (including transfers from the EEA/UK to other jurisdictions), we use lawful transfer mechanisms such as the European Commission’s Standard Contractual Clauses (and UK International Data Transfer Addendum as applicable). Details are available upon request.
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Data Retention
We retain personal information for as long as needed to provide the service, comply with legal obligations, resolve disputes, and enforce agreements.
- Account Data: retained for the life of the account; deleted or anonymized within a reasonable period after account closure.
- Content: retained until you delete it or your account is closed; residual backups may persist for a limited time.
- Logs and Diagnostics: typically retained 12–24 months unless required longer for security or legal reasons.
- Advertising and Analytics Data: retained per partner policies and legal requirements; in the EEA, retention for advertising identifiers is typically limited (e.g., 13 months) where required by law.
We will anonymize or aggregate data where feasible.
- Security
We implement administrative, technical, and physical safeguards appropriate to the risk, including:
- Encryption in transit and at rest where applicable.
- Access controls, least-privilege, and authentication.
- Network and application security monitoring, logging, and vulnerability management.
- Vendor due diligence and data processing agreements.
No method of transmission or storage is completely secure; we cannot guarantee absolute security.
- Your Rights
EEA/UK (GDPR/UK GDPR):
United States State Privacy Laws (e.g., CA, VA, CO, CT, UT):
- Rights: know/access, correct, delete, portability; opt out of sale, sharing, or targeted advertising; limit use/disclosure of sensitive personal information (California); non-discrimination.
- Opt-Out of Targeted Advertising and Sharing: use the in-app “Do Not Sell/Share or Target” control or our web form [URL]. We honor browser-based Global Privacy Control (GPC) signals where applicable.
- Authorized Agents (CA): may submit requests with appropriate authorization and identity verification.
- Sensitive Personal Information (CA): if collected, you may limit its use to necessary purposes; see in-app settings.
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Children’s Privacy
The service is not directed to children under 13 (or under the age threshold in your jurisdiction). We do not knowingly collect personal information from children. If you believe a child has provided personal information, contact us to request deletion.
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Automated Decision-Making
We do not use automated decision-making that produces legal or similarly significant effects. We may use automated systems to moderate content and detect spam/abuse; you can contact support to appeal moderation decisions.
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Cookies, SDKs, and Tracking Technologies
We use mobile SDKs and similar technologies to:
- Authenticate users and maintain sessions.
- Measure usage and performance.
- Personalize content.
- Deliver and measure advertisements.
Controls:
- In-app settings for consent and preferences (EEA/UK).
- Device settings to reset/limit advertising identifiers (IDFA/AAID).
- Opt-out of targeted advertising via in-app control or [URL].
Some features may not function without certain technologies.
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Third-Party Links and Features
Third-party services (e.g., links, embedded content, social login) are governed by their own privacy policies. Review those policies before use.
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Changes to This Policy
We will update this Policy as needed. We will notify you of material changes via in-app notice or email and indicate the effective date. Continued use of the service after changes indicates your acceptance.
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How to Contact Us
- Email: [privacy@company.com]
- Mailing Address: [Company Legal Name], [Address], [Country]
- Online Rights Request Form: [URL]
- EU/UK Representative and DPO: [emails as above]
- Region-Specific Disclosures
- EEA/UK: Our legal bases, DPO, and transfer mechanisms are described above. You have the right to obtain a copy of applicable transfer safeguards (subject to redactions for confidentiality).
- California: We provide the following categories collected in the past 12 months—identifiers, internet/electronic network activity, geolocation (if enabled), commercial information (transactions), inferences (for personalization), and content. We disclose these to service providers and, for advertising, to partners consistent with “sharing” under CPRA. We do not sell personal information for monetary consideration.
- Other U.S. States: We provide opt-out rights for targeted advertising and, where applicable, sale. Appeal mechanisms for denied rights requests are available at [URL].
- Additional Notes
- Data Minimization: We collect only what is necessary for the stated purposes.
- Privacy by Design: We implement appropriate technical and organizational measures and conduct privacy impact assessments where required.
- Records of Processing: Maintained in accordance with GDPR Article 30 where applicable.
Appendix: Summary of Opt-Out and Consent Controls
- Consent management (EEA/UK): in-app privacy settings.
- Targeted advertising opt-out: in-app toggle and [URL].
- GPC: honored for web contexts and supported app integrations where feasible.
- Contact syncing: enable/disable in app.
- Precise location: enable/disable device permission.
- Push notifications: manage via device and in-app settings.
Placeholders in brackets should be completed before publication (e.g., controller identity, contact details, effective date, URLs).