Privacy Policy

About us and this policy

We, Enumma, Inc., a Delaware corporation, control the collection of information about you in relation to the service.

This policy gives you a comprehensive view of our information practices. It also explains what privacy protection rights you may have under applicable law and how you may exercise those rights if you have them.

Please note that some of the terms we use, including “information,” “the service,” “sell” and “share,” have specific meanings we have set out in the Glossary below or, by reference in that Glossary, specific meanings we have set out in the "About these terms of service" section of our Terms of Service.

This policy was originally written in English. We may translate it into other languages. If there’s a conflict between a translated version and the English version, the English version will control.

Categories of information we may collect

Identifiers

We may collect information that identifies you or the means by which you access the service, including the information we set out in the table below.

Protected characteristics

We may ask you to confirm that you’re an adult with full legal capacity.

Professional information

We may collect information related to your profession or professional activity, including the information we set out in the table below.

Relationships information

We may collect information, such as the email addresses of people in one or more of your contact lists, to help you find users you may know on the service, or to let you invite people you may know to join the service.

Commercial information

We may collect records of products or services you have purchased or used or have considered purchasing or using to help us personalize your experience on the service, including the content and ads we serve to you.

Inferences about you

We may collect inferences about your interests and preferences to help us personalize your experience on the service, including the search results, content and ads we serve to you.

Audio and visual information

We may collect audio and visual information that you create on the service or that you submit, post, import, upload, transmit, broadcast, send or in any other way publish to or through the service, including:

• Profile pictures, posters and banners that you upload to the service.
• Open-ended information that you associate with a profile such as a short bio, an “about” description or a status message.
• Music tracks that you add to your music catalog on the service so that users can use them in their content.
• Video, including audio, that you stream to service or broadcast to external platforms through the service.
• Video recordings, including audio, that you create on, or upload to, the service, or that you spread to external platforms through the service.
• Posts that you submit to the service or spread to other platforms through the service, including text, images, graphics, video and audio that you include in those posts.
• Comments and public chat messages that you submit to the service or to other platforms through the service, including text, images, graphics, video and audio that you include in those comments or public chat messages.
• Private chat messages that you submit to the service or to other platforms through the service, including text, images, graphics, video and audio that you include in those messages.
• Recordings of your voice when you use your voice to interact with the app or when you communicate with our support team.
• Descriptors and metadata related to all of the above.

We also collect messages and other information that you send or provide to us when you communicate or interact with us, such as when you connect with us on social media, contact our support team, attend our events, participate in research, or fill out our surveys.

Activity information

We may collect information that describes or relates to your activity on the service, including:

• Information about how you connect and interact with the service such as the country, time zone and date and time of your requests to the service, the last webpage visited through your browser before contacting the service, when, how frequently and for how long you use the service, how you navigate through the service, what parts of the service you spend time on, who you follow, who follows you, who you communicate with, what you search for, what content and ads you engage with, when, how and for how long you do so, and your reactions to content and ads.
• Information about your device’s status and performance and the service’s status and performance while you use the service such as battery level, Internet connection strength and bandwidth, accessories, settings, launch time, hang rate, energy use, system activity, error logs, crash reports and other technical diagnostics and troubleshooting data.

Approximate location

We may collect your approximate location to confirm that you’re eligible to use the service and to personalize your experience on the service, including the search results, content and ads we serve you.

External account login information

We may collect the information necessary to access external accounts when you grant us permission to do so.

Is information in any category sensitive?

External account login information is considered sensitive under the law of some of the places where we operate. You may grant us access to an external account so that you can, among other things:

• Create a user account using your external account credentials.
• Log in to the service using your external account credentials.
• Authenticate yourself and verify information about you.
• Import data and media from the external account to the service.
• Assign and remit royalties to the Enumma ecosystem.
• Broadcast or spread your content to an external platform.
• Earn rewards based on your content’s performance on an external platform.

The audio and visual information, including text, that you include in a private chat message to a user other than us is also considered sensitive under the law of some of the places where we operate. We use that information only to:

• Enable you to send the private chat message to the user.
• Ensure the private chat messaging feature works as intended.
• Maintain, develop, evaluate and improve the private chat messaging feature.
• Keep the service safe and secure.
• Enforce our terms and policies, including investigation of potential violations.
• Reasonably cooperate with governmental authorities.
• Comply with a court order or other legal requirement.
• Comply with applicable laws and regulations.

Except as set out in this section above, we limit the information we collect to nonsensitive information.

Sources of the information

Typically, we collect information about you directly from you. That’s the case not only when you deliver the information to us, such as when you fill out a form on the service or publish content to or through the service, but also when we draw the information from your device or from your activity on the service.

In some cases, we’ll draw information about you by making calls to an application programming interface on your device. In other cases, we’ll do that by extracting data from local storage or application data caches on your device, or through the use of cookies, web beacons, browser web storage or other similar technologies.

You may be able to set your browser to accept all cookies, to reject all cookies, or to notify you whenever a cookie is offered so that you can decide each time whether to accept it. However, rejecting some cookies may cause the service to not work for you as intended by us. For more details on cookies, please visit All About Cookies.

While we typically collect information directly from you, we may also collect information about you from:

• External accounts you grant us access to or link to the service.
• Other users when they give us information about you, such as confirmation that they have you in their contact lists, or when we draw information or make inferences about you based on their interactions with you.
• Companies or other organizations when you interact with them on or through the service, or when they incorporate some part of the service, such as our embedded player, into their own offering or website.
• Other services’ application programming interfaces, directly or through aggregators or other redistributors, with your permission where required by their own terms.
• Ad networks, advertisers and others that supply us with information that helps us select and prioritize the ads we serve to you based on your interests and preferences or on inferences about your interests and preferences.

In particular, when you broadcast or spread your content to an external platform, we periodically obtain metrics from the external platform to gauge your content’s performance on the external platform. We may retain and display these metrics to you and others to account for how we allocate rewards and may continue to do so if you revoke our access to the external platform or ask us to delete the information we have collected form the external platform.

If you have a user account, we typically tie the information we collect about you to your user account. If we can’t tie the information we collect about you to a user account, either because you don’t have one or you’re not signed in to it and we can’t identify you as its owner, we may tie that information to a deterministic or probabilistic identifier associated with your device or to some other similar identifier.

For how long we intend to keep the information

Baseline retention rules

We intent to keep external account login information until you revoke access the account it relates to. We intent to keep information in each of the other categories for the following length of time, plus an additional holding period:

Additional holding period

We may keep the information for longer if we need it to:

• Complete the transactions for which we collected the information.
• Provide the service as requested by you or as reasonably anticipated by you.
• Fulfill our agreements with you and others under our terms and policies.
• Protect your legal interests or those of the general public.
• Identify and repair errors that impair the service’s existing functionality.
• Enable internal uses aligned with your reasonable expectations.
• Exercise our right of free speech or protect another’s right of free speech.
• Exercise a legal claim or defend against a legal claim.
• Exercise any other right we may have under the law.
• Keep the service safe and secure.
• Enforce our terms and policies, including investigation of potential violations.
• Reasonably cooperate with governmental authorities.
• Comply with a court order or other legal requirement.
• Comply with any applicable law or regulation.

Purposes for which we may use the information

We may use the information we collect about you to:

• Confirm that you’re eligible to use the service.
• Identify you even when you don’t use the service through a user account.
• Power your user account and profile accounts.
• Protect your legal interests or those of the general public.
• Enable features that only work if we verify information about you.
• Make the service work for you and others as expected.
• Help users and others find you and your content.
• Facilitate connections and interactions between you and other users.
• Integrate or connect the service with other services.
• Make the service fair and transparent for all users.
• Personalize your experience and make suggestions to you.
• Serve you ads that we think might interest you.
• Help advertisers understand and improve the performance of their ads.
• Evaluate and manage a business relationship with you.
• Communicate with you in relation to the service.
• Process and address any claim you may have.
• Maintain, develop, evaluate and improve the service, including models and algorithms.
• Keep our service safe and secure.
• Enforce our terms and policies, including investigation of potential violations.
• Reasonably cooperate with governmental authorities.
• Comply with a court order or any other legal requirement.
• Comply with applicable laws and regulations.

Our ability to use of the information about you for all of the purposes we listed above is an essential element of the bargain between the two of us because, without it, we wouldn’t be able to deliver the service in a form and manner that’s acceptable to us given the service’s value proposition, its design, and the standards on which our brand and reputation rest.

We use various technologies to process the information we collect about you for these purposes. For example, we use automated systems to prioritize content and ads on your feed. In particular, our eligibility and verification decision-making processes may be partially or fully automated.

We don’t sell or share any of the information

We don’t “sell” or “share” any of the information we collect about you as we define those terms in the Glossary below.

However, here are a few things you should know:

• Your profiles on the service are public, so everything you make part of your profiles is available for everyone to see. The only exception is your email address, which is private by default, but you can make public if you want.
• When you publish content or react to content on the service, we make your content or reaction available to all users and allow users and others to share or publish previews of your content or reaction across the web.
• When you broadcast or spread your content to an external platform, we transmit your content to the external platform and the external platform uses and makes your content available to others according to its own rules and practices.
• Because the service rewards users based on the timing and performance of their content relative to the timing and performance of other users’ content, we can make your content’s engagement metrics available to all users, even after your delete your content.
• When you use the service to intentionally interact with an external service, we transfer or disclose information to the external service as instructed by you or as called for by the interaction.
• If you share access to a user account or profile account with other users, the other users will have access to information associated with that account, including private chat messages.
• If you file a copyright or neighboring right infringement claim, we’ll disclose information in relation to your claim to the affected user as set out in our Infringement Claims Policy.
• If you file a content reinstatement request in response to a copyright or neighboring right infringement claim, we’ll send a copy of that request to the claimant as set out in our Infringement Claims Policy.
• We may grant our service providers access to the information we collect about you and have them process that information on our behalf for business purposes. We may also disclose the information we collect about you to a potential or transitioning service provider for due diligence or transition purposes.
• If we transfer all or part of our business, we may transfer the information we collect about you to our successor in interest. We may also disclose the information we collect about you to a potential or transitioning successor in interest for due diligence or transition purposes.
• We may disclose information about you to others, including governmental authorities, to keep the service safe and secure, exercise or enforce our rights, or comply with a court order, any other legal requirement or any applicable law or regulation.

Also, please be careful when you use our private chat messaging and sharing features. We don’t control, are not responsible and have no liability for what others do with the information you send to them. Consider whether you can trust them with information you want to keep private.

Processing of information by our service providers

We may grant our service providers access to the information we collect about you and have them process that information on our behalf for business purposes. We may also disclose the information we collect about you to a potential or transitioning service provider for due diligence or transition purposes. Our service providers may be based in or outside the United States of America, or in or outside your jurisdiction. Privacy protection laws vary among countries, with some providing more protection than others.

Transferring information to our successors

If we transfer all or part of our business, we may transfer the information we collect about you to our successor in interest. We may also disclose the information we collect about you to a potential or transitioning successor in interest for due diligence or transition purposes. Our successors in interests may be based in or outside the United States of America, or in or outside your jurisdiction. Privacy protection laws vary among countries, with some providing more protection than others.

Managing your information on the service

You can always delete any of your profile accounts or delete your user account directly on the service. However, after you delete any of your profile accounts or your user account, we may keep information associated with that account for an additional holding period as described in the "For how long we intend to keep the information" section above. Also, you may be able to configure your browser to block cookies and your device may have controls that determine what information we collect in some instances. For example, your device may require your permission before we can access your camera, microphone or contacts.

Our information security procedures

We implement and adhere to the information security procedures required by applicable law. As part of those procedures, we encrypt your user account password and guard and control access to our servers in the Unites States of America and elsewhere. We also use appropriate mechanisms and safeguards when we transmit information about you, including when we do so across jurisdictions. However, no online transmission is ever fully secure or error free. In particular, email sent to or from us may not be secure. Because of this, you should take special care in deciding what information you send to us or ask us to send to you through any online channel, including email.

Your privacy protection rights

Applicable law that determines your rights

Your privacy protection rights depend on which law governs our collection and processing of information about you, which in turn may depend on your place of residence.

Explanation of the different rights you may have

Depending on which law governs our collection and processing of information about you, you may have some or all of the privacy protection rights we set out of below.

Right to know

You may have the right to know:

• The categories of information we have collected about you.
• The categories of sources from which we have collected information about you.
• The purposes for which we have collected information about you.
• The categories of information about you that we have disclosed for business purposes, and for each category of information, the categories of parties to whom we have disclosed information in that category.
• The specific pieces of information we have collected about you.

Right to correct

You may have the right to correct inaccurate information we maintain about you.

Right to delete

You may have the right to delete information we have collected about you, with a number of exceptions set out in applicable law.

Depending on the law that applies, we may choose to keep information that you ask us to delete to, among other things:

• Complete the transactions for which we collected the information.
• Provide the service as requested by you or as reasonably anticipated by you.
• Fulfill our agreements with you and others under our terms and policies.
• Protect your legal interests or those of the general public.
• Identify and repair errors that impair the service’s existing functionality.
• Enable internal uses aligned with your reasonable expectations.
• Exercise our right of free speech or protect another’s right of free speech.
• Exercise a legal claim or defend against a legal claim.
• Exercise any other right we may have under the law.
• Keep our service safe and secure.
• Enforce our terms and policies, including investigation of potential violations.
• Reasonably cooperate with governmental authorities.
• Comply with a court order or any other legal requirement.
• Comply with any applicable law or regulation.

In addition, if permitted under applicable law, instead of deleting the information about you we may choose to keep in deidentified form.

How you can exercise your rights

You can exercise any of your privacy protection rights by sending a request to privacy@enumma.com. You can do so directly or through your authorized agent. However, to be able to fulfill your request we’ll need to verify that you’re the person about whom we have collected the information that is the subject of your request, and if you’re sending your request through your authorized agent, that you gave your authorized agent permission to submit your request on your behalf. Also, your request will need to meet a number of requirements that we detail in the following sections.

How we verify that you are who you say you are

If you have a user account with us

If you have a user account with us, the process by which we verify that you are who you say you are is pretty straightforward.

We’ll ask you to:

• Authenticate yourself with your user account credentials.
• Verify the email address associated with your user account if you haven’t already done so.

We may also ask you to reauthenticate yourself before sending you any specific pieces of information about you or before finally correcting or deleting any information about you.

If you don’t have a user account with us

If you don’t have an account with us, things can get a bit more complicated.

The level of certainty with which we’ll need to verify you depends on the type of request you’re making:

To verify you with a “reasonably high degree of certainty” we’ll ask you to:

• Provide us with three data points matching three data points that we maintain and that in our estimation are reliable for the purpose of verifying you. 
• Send us a physically or electronically signed letter in which you declare under penalty of perjury that you’re the person about whom we have collected the information that is the subject of your request.

To verify you with a “reasonable degree of certainty” we’ll ask you to provide us with two data points matching two data points that we maintain and that in our estimation are reliable for the purpose of verifying you.

How we verify that your authorized agent has your permission

If you send your request through your authorized agent, to verify that your authorized agent has your permission to submit your request on your behalf we may:

• Ask you to confirm, through your user account, that you gave your authorized agent permission to submit your request.
• Ask your authorized agent to provide us with formal proof that your authorized agent has permission to submit your request on your behalf.

Heightened verification measures in case of suspicious activity

If we have reason to suspect any fraudulent or malicious activity, we may take heightened verification measures and defer from complying with your request until we can determine that you’re the person about whom we have collected the information that is the subject of your request and, if applicable, that you gave your authorized representative permission to send the request on your behalf.

Requirements that each type of request must meet

Request to know

In your request to know you must let us know:

• Your email address if we don’t already have one associated with your user account.
• Your country and state of residence so that we can determine what law applies to you.
• What sets of information are the ones you would like to know among the sets of information you have a right to ask for.

However, you should know that applicable law may:

• Exempt us from fulfilling your request if you’ve exceeded the maximum number of requests to know that we’re required to accept for processing within a given period of time.
• Exempt us from searching for information that we only keep for legal purposes in a form that makes searching for that information unreasonably difficult.
• Prohibit us from disclosing information that we use to keep the service secure.
• Provide other reasons for denying all or part of your request.

Request to correct

In your request to correct you must let us know:

• Your email address if we don’t already have one associated with your user account.
• Your country and state of residence so that we can determine what law applies to you.
• What is the information we maintain about you that is inaccurate.
• Any direction as to how we should correct that information.

You must also make a good effort to provide us with all documentation necessary to support a more-likely-than-not conclusion that the information we maintain is inaccurate and that the information you want to replace it with is accurate. We may require that you provide us with documentation to that effect if necessary to rebut a contrary conclusion from our own documentation.

That said, you should know that applicable law may:

• Limit the efforts we must expend to establish a basis for fulfilling your request.
• Provide reasons for denying your request or for deleting your information instead of correcting it.

Request to delete

In your request to correct you must let us know:

• Your email address if we don’t already have one associated with your user account.
• Your country and state of residence so that we can determine what law applies to you.
• The information that you want us to delete.

However, you should know that applicable law may provide reasons for denying all or part of your request that are additional to the exceptions to the right to delete.

What you can expect after you send your request

After we receive your request, we may ask you or your authorized agent for additional information. We’ll process your request in accordance with applicable law and deliver our final response together with any approved information to the email associated with your user account, or if you don’t have a user account, to the email that you specify in your request. If we deny your request, depending on where you live, you may have the right to appeal our denial.

Your right to no retaliation

Please know that we may not discriminate against you because you have exercised any of your privacy protection rights.

Our information practices report

The following report describes our information practices:

This report is qualified as follows:

• During the calendar year in which the first version of this policy becomes effective, each reference to the “reporting period” will be understood to allude to our policy as to what our information practices are to be until the end of that calendar year.
• During each of the following calendar years, if we do not update this report in January of that calendar year, this report will be understood to remain updated as of the end of the preceding calendar year and the “reporting period” will be understood to mean that preceding calendar year.

External platforms

As set out in our Terms of Service, the service may include a feature that allows you to connect a profile account to an external platform and to broadcast or spread your content from the service to the external platform. The collection and processing of your information by the external platform is governed by the external platform’s own privacy policy and not by this policy.

Other external services

As set out in our Terms of Service, the service may also include integrations with external services other than for the purposes described in the “External platforms” section above. The collection and processing of your information by an external service is governed by the external service’s own privacy policy and not by this policy.

Outbound links and references

As set out in our Terms of Service, the service may contain outbound links or references to websites or offerings we don’t own or control. Those websites and offerings are governed by their own privacy policies and not by this policy.

Changes to this privacy policy

We may make changes to this policy as set out in the “Changes to our terms and policies” section of our Terms of Service. However, we need not send you an email to let you know of any updates to our information practices report that relate only to collection and processing of information already contemplated by this policy. You can always review the latest version of this policy, including updates to our information practices report, on the “Terms & Policies” section of our website.

How to contact us

If you want to make a request to know, correct or delete information under this policy, you must email your request to privacy@enumma.com.

The best way to ask questions about this policy or our information practices is to email your questions to privacy@enumma.com. If you must, you can instead mail your questions to:

If you have a dispute concerning this policy, you must follow the dispute resolution process set out in our Terms of Service. If you bring a claim against us, you may only serve process to us through our Delaware registered agent as set out in the “Service of process” section of our Terms of Service. These dispute resolution and service of process provisions apply only to the extent permitted under applicable law. They don’t affect any right you may have to bring a complaint before a privacy protection authority if you cannot contractually agree to alter or give up that right.

Dispute resolution