PRIVACY POLICY

Last updated: March 27, 2023

Privacy Policy

Youpi Inc. and its affiliates (“Youpi,” “we,” “our,” and/or “us”) value the privacy of individuals who use our websites (including https://joinrealm.ai), services, and applications that link to this Privacy Policy, (including Bubble Camera, Huddle, MetaDance, Realm, Vibey and respective versions on iOS and Android) (collectively, the “Services”).  This Privacy Policy (the “Privacy Policy”) explains how we collect, use, and disclose Personal Information from users of the Services (“Users”).  As used in this Privacy Policy, “Personal Information” means any information relating to an identified or identifiable individual.  By using the Services, you agree to the collection, use, and disclosure of your Personal Information as described in this Privacy Policy.  Beyond this Privacy Policy, your use of the Services is also subject to our Terms of Service.

INFORMATION WE COLLECT
We may collect a variety of Personal Information from or about you or your devices from various sources, as described below.

A. Information You Provide to Us
Registration.  When you register for an account to use the Services, we ask you for your Personal Information, including your username, name, phone number, age, gender, and any images you choose to upload for your profile.  If you register using your third-party account credentials (such as your Apple account), we collect your Personal Information from the applicable third party as discussed in “Platform Sign-On” under Section C below.
Communications.  If you contact us directly, we may receive additional Personal Information about you.  For example, when you contact us for support, we will receive your username, phone number, email address, device type and any other information you choose to provide to us.
Use of the Services.  We collect the content, communications, and other Personal Information you provide when you use the Services, including any content you create or share on the Services, your messages, or communications with other Users, videos, and photos you upload to the Services, annotations you used to create your videos, and any other information you provide to us.  For example, when you make a post on the Services, we collect the contents of your post and any other information you provide in connection with your post.
Pictures Uploaded to the Services.  We collect the photos that you upload to the Services for purposes communicated to you at the time of collection.  For example, the Realm application collects facial images of Users (“Facial Images”) to train and retrain the Stable Diffusion model and create a personalized model that generates artwork for Users based on textual descriptions (“Facial Model”).  When uploading images to the Services, Users are required to upload only images of themselves.
Facial Image Information and Facial Models.  We do not use your personalized Facial Models trained using Facial Images to identify you personally.  Nevertheless, depending on your location, applicable laws might define this data as a biometric identifier or biometric information.  We will obtain your express consent for the collection, use, and sharing of such information, and you may withdraw your consent at any time by contacting us as described in the “Contact Us” section below.  For more information on how we process your Facial Images and Facial Model, please visit our Facial Data Privacy Notice.
Careers.  If you decide to apply for a job with us, you may submit your contact Personal Information and your resume online.  We will collect the Personal Information you choose to provide us as part of your job application, such as your contact information, current employment information, and other information you choose to submit with your application and on your resume.  If you apply for a job with us through a third-party platform (such as Glassdoor or LinkedIn), we will collect the information you make available to us through such third-party platform.

B. Information We Collect When You Use the Services
Location Information.  When you use the Services, we may infer your general location information.  For example, your IP address may indicate your general geographic region.
Device Information.  We receive information about the device and software you use to access the Services, such as your internet protocol (IP) address, web browser type, operating system version, and device identifiers.
Video and Audio Information.  We receive information from the videos that you uploaded to the Services.  We may also request access to your camera and microphone to facilitate your use of the Services such as uploading videos to your private library to save and edit such videos or to generate personalized artwork.
Usage Information.  To help us understand how you use the Services and to help us improve them, we may automatically receive information about your interactions with the Services, such as the types of features you use, the objects with which you interact, the lengths of your sessions, etc.
Analytics Partners.  We use analytics services such as Amplitude Analytics, Kochava, Facebook Analytics, and Google Analytics for Firebase to collect and process certain analytics data.  These services may also collect information about your use of other websites, apps, and online resources.  You can learn about Google’s practices by going to https://www.google.com/policies/privacy/partners/ and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

C. Information We Receive from Third Parties
Platform Sign-On.  When you register for the Services using a third-party account such as your Apple account, we receive your Personal Information, including your username, name, and email address.  If you wish to limit the Personal Information available to us, you should visit the privacy settings of your third-party accounts to learn about your options.
Third Parties.  We may receive additional personal information about you from third parties and combine it with other information we have about you.  If you choose to submit information to social media websites operated by us, such as Instagram or Twitter, we may receive Personal Information about you, including your profile information and your use of the third-party account.  If you wish to limit the Personal Information available to us from third-party services, you should visit the privacy settings of your third-party accounts to learn about your options.

HOW WE USE THE INFORMATION WE COLLECT
We use the Personal Information we collect:
- To provide, maintain, debug, improve, and enhance the Services;
- To understand and analyze how you use the Services, and develop new products, services, features, and functionalities;
- To recommend content and other Users to you;To understand and analyze usage patterns;To process your job application;
- To send you SMS messages and push notifications;
- To communicate with you, provide you with updates and other information relating to the Services, provide information that you request, respond to comments and questions, and otherwise provide customer support;
- To find and prevent fraud, and respond to trust and safety issues that may arise; For compliance purposes, including enforcing our Terms of Service, Facial Data Privacy Notice, or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency; andFor other purposes for which we provide specific notice at the time the Personal Information is collected.

LEGAL BASES FOR PROCESSING EUROPEAN INFORMATION
If you are located in the European Economic Area (“EEA”) or the United Kingdom (“UK”), we only process your Personal Information when we have a valid “legal basis”, including as set forth below.
Consent.  We may process your Personal Information where you have consented to certain processing of your Personal Information.  For example, we may process your Personal Information to send you marketing communications where you have consented to such use.
Contractual Necessity.  We may process your Personal Information where required to provide you with the Services.  For example, we may need to process your Personal Information to respond to your inquiries or requests.
Compliance with a Legal Obligation.  We may process your Personal Information where we have a legal obligation to do so.  For example, we may process your Personal Information to comply with tax, labor and accounting obligations.
Legitimate Interests.  We may process your Personal Information where we or a third party have a legitimate interest in processing your Personal Information.  Specifically, we have a legitimate interest in using your Personal Information for product development and internal analytics purposes, and otherwise to improve the safety, security, and performance of the Services.  We only rely on our or a third party’s legitimate interests to process your Personal Information when these interests are not overridden by your rights and interests.

HOW WE SHARE THE INFORMATION WE COLLECT
We do not share or otherwise disclose information we collect from you except as described below or otherwise disclosed to you at the time of the collection.
Affiliates.  We may share any information we receive with our affiliates for any of the purposes described in this Privacy Policy.
Vendors and Service Providers.  We may share any information we receive with vendors and service providers retained in connection with the provision of the Services.
User Information and Content Sharing.  The Services are social services in which you can view and share content with other Users.  Your username, profile image, gender and other profile information will be viewable and searchable by other Users.  The content you share on the Services will be displayed on the Services and viewable by other Users.  Users with whom you share content or information through the Services may be able to share such content and information with others.  We are not responsible for the other Users’ use of available information, so you should carefully consider whether and what to share and how you identify yourself on the Services.
User Communication.  The Services include features that allow you to interact with other Users, such as by commenting on their content or sending direct messages.  To facilitate these interactions, we will share the contents of your comments and messages with the relevant Users.
Sharing Models with Users.  The Services include a feature that allows you to permit other Users to use your personal Facial Model.  By default, your personal Facial Model will not be shared with any other Users, and you will need to enable this feature separately.  Users interested in accessing another User’s personal Facial Model may submit a request to the creator of the Facial Model.  The creator of the Facial Model has full control over whether to accept or reject such requests.  We do not share your raw personal Facial Model with other Users.
Marketing.  We do not rent, sell, or share Personal Information about you with nonaffiliated companies for their direct marketing purposes unless we have your permission.
Social Media.  When you share your content with third-party social media companies such as Snapchat or TikTok, we may share your Personal Information with those third-party companies.  See the “Third Parties” section below for more information.
Analytics Partners.  We use analytics services such as Amplitude Analytics, Kochava, Facebook Analytics, and Google Analytics for Firebase to collect and process certain analytics data.  These services may also collect information about your use of other websites, apps, and online resources.  You can learn about Google’s practices by going to https://www.google.com/policies/privacy/partners/ and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
As Required by Law and Similar Disclosures.  We may access, preserve, and disclose your Personal Information if we believe doing so is required or appropriate to: (i) comply with law enforcement requests and legal process, such as a court order or subpoena; (ii) respond to your requests; or (iii) protect your, our, or others’ rights, property, or safety.
Merger, Sale, or Other Asset Transfers.  We may disclose and transfer your Personal Information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company, or we sell, liquidate, or transfer all or a portion of our business or assets.
Consent.  We may also disclose your Personal Information with your permission.

YOUR CHOICES
Marketing Communications.  You can unsubscribe from our promotional emails or SMS messages via the unsubscribe link provided in the emails or following the opt-out instructions in the SMS messages.  Even if you opt out of receiving promotional messages from us, you will continue to receive administrative messages from us.
Do Not Track.  There is no accepted standard on how to respond to Do Not Track signals, and we do not respond to such signals.
Personal Facial Model.  If you have previously opted into sharing your personal Facial Model with other Users, you may revoke their access at any time.  This can be done by adjusting your settings within the platform.
If you choose not to provide us with the Personal Information we collect, some features of the Services may not work as intended.
Your European Privacy Rights.  If you are located in the EEA or the UK, you have additional rights described below.
You may request access to the Personal Information we maintain about you, update and correct inaccuracies in your Personal Information, restrict or object to the processing of your Personal Information, have your Personal Information anonymized or deleted, as appropriate, or exercise your right to data portability to easily transfer your Personal Information to another company. In addition, you also have the right to lodge a complaint with a supervisory authority, including in your country of residence, place of work or where an incident took place.
You may withdraw any consent you previously provided to us regarding the processing of your Personal Information at any time and free of charge.  We will apply your preferences going forward and this will not affect the lawfulness of the processing before you withdrew your consent.
You may exercise these rights by contacting us using the contact details at the end of this Privacy Policy.  Before fulfilling your request, we may ask you to provide reasonable information to verify your identity.  Please note that there are exceptions and limitations to each of these rights, and that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain Personal Information for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.

THIRD PARTIES
The Services may contain links to other websites, products, or services that we do not own or operate (“Third-Party Services”).  We are not responsible for the privacy practices of these Third-Party Services.  Please be aware that this Privacy Policy does not apply to your activities on these Third-Party Services or any information you disclose to these Third-Party Services.  We encourage you to read the privacy policies of these Third-Party Services before you provide them with your Personal Information.

RETENTION
We take measures to delete your Personal Information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it unless we are required by law to keep this information for a longer period.  When we process Personal Information for our own purposes, we determine the retention period taking into account various criteria, such as the type of services provided to you, the nature and length of our relationship with you, possible re-enrollment with the Services, the impact on the Services we provide to you if we delete some information from or about you, and mandatory retention periods provided by law and the statute of limitations.
The Facial Images collected by the Realm application are deleted permanently after the Facial Model is trained and retrained.  We also offer in-app features that allow Users to explicitly delete their Facial Models or their account.

SECURITY
We make reasonable efforts to protect your Personal Information by using physical and electronic safeguards designed to improve the security of the Personal Information we maintain.  However, as no electronic transmission or storage of information can be entirely secure, we can make no guarantees as to the security or privacy of your Personal Information.

INTERNATIONAL VISITORS
The Services are hosted in the United States (“U.S.”) and intended for visitors located within the U.S.  If you choose to use the Services from the EEA, the UK or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your Personal Information outside of those regions to the U.S. for storage and processing.  We may transfer your Personal Information from the EEA or the UK to the U.S. and other third countries based on European Commission-approved Standard Contractual Clauses, or otherwise in accordance with applicable data protection laws.  Also, we may transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Services.  By providing any information, including Personal Information, on or to the Services, you consent to such transfer, storage, and processing.

CHILDREN’S PRIVACY
We do not knowingly collect, maintain, or use Personal Information from children under 16 years of age (“Minors”), and no parts of the Services are directed to Minors.  If you learn that a Minor has provided us with Personal Information in violation of this Privacy Policy, please alert us at privacy@joinrealm.ai.

CHANGES TO THIS PRIVACY POLICY
We will post any adjustments to the Privacy Policy on this page, and the revised version will be effective when it is posted.  If we materially change the ways in which we use or share Personal Information previously collected from you through the Services, we will attempt to notify you through the Services, by email, or by other means.

CONTACT US
If you have any questions, comments, or concerns about our processing activities, please email us at privacy@joinrealm.ai or write to us at:
Youpi Inc112 Alley WayMountain View, CA 94040