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Privacy Policy

We are strongly committed to letting you know how we will collect and use your personal information. The policies below are applicable to data and information collected when you use the Neutron Holdings, Inc. network of websites, including Locals.ru (including any versions optimized for viewing on a wireless or tablet device); all email newsletters published or distributed by Neutron Holdings, Inc.; all apps published by Locals LLC, including the “Locals” app. (“Service”) and all other interactive features and communications provided by Locals LLC (“App”), however accessed and/or used, that are operated by us, made available by us, or produced and maintained by us and our related companies (collectively “Locals LLC” or “we”, “us”, or “our”). We have established this privacy policy (“Privacy Policy”) to let you know the kinds of personal information we may gather during your use of this App, why we gather your information, what we use your personal information for, when we might disclose your personal information, and how you can manage your personal information.

Please be advised that the practices described in this Privacy Policy apply to information gathered online through our App, through our websites and otherwise by our customer service personnel. It does not apply to information that you may submit to organizations to which we may link or who may link to us or information that we may receive about you from other organizations.

By using our App, you are accepting the practices described in our Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use the App. We reserve the right to modify or amend the terms of our Privacy Policy from time to time without notice. Your continued use of our App following the posting of changes to these terms will mean you accept those changes. If we intend to apply the modifications or amendments to this Privacy Policy retroactively or to personal information already in our possession, we will provide you with notice of the modifications or amendments.

 

WHAT INFORMATION ABOUT ME IS COLLECTED AND STORED?

We collect two basic types of information from you in conjunction with your use of the App, personal information and non-personal information. Personal information is information that you supply to us, as described more fully below, i.e., when you use our Services, obtain a subscription, complete a survey, register on the App, upload content, participate in a community, or provide your e-mail address. Personal information is any information that can individually identify you and includes, among other things, your name, e-mail address, telephone number, postal address, credit card, billing and contact information. Non-personal information includes information that does not personally identify you, but it may include tracking and usage information about your location, demographics, use of the App and the Internet.

Personal Information

As a general matter, you can browse the App without submitting your personal information to us. However, there are a number of circumstances in which you may supply us or our agents with your personal information. The following lists the most common ways in which we may collect your personal information.

Registration for an account on the App

Use of the account through the App

Payment information submitted to Locals

Registration for an event sponsored by Locals

Profile information that You provide for Your user profile

Social media information that you authorize

Certain location data, as described below

Uploading Content to the App

Submitting an application to work at Locals

Participation in surveys, contests, or sweepstakes

Sign up to receive alerts or other information via email, text or instant message from Locals

Request for customer service, support requests or other assistance

App related communications, e.g. account verification; technical notification

Participation in communities, commenting to blog entries and participation in other forums

Submission of content or other data and information on any part of the App that permits it

Any other place on the App where you knowingly volunteer personal information

Non-Personal Information

Device information about your computer, browser, mobile device, or other device that you use to access the App. This information may include IP address, geolocation information, unique device identifiers, browser type, browser language, and other transactional information.

Device information about the Locals, including time stamps, battery status.

Other information regarding your use of the App.

Collection of Your Source IP Address/Location Information

Collection of Personal Information From or Through Social Media Sites or Using Your Social Media Login

When you interact with any Service Provider page or account on a social media platform, such as Facebook, Twitter, Google+, Tumblr, LinkedIn, YouTube, or Pinterest, we may collect the personal information that you make available to us on that page or account including your account ID or “handle.” However, we will comply with the privacy policies of the corresponding social media platform and we will only collect and store such personal information that we are permitted to collect by these social media platforms. If you publish your social media profile on our Service, we may collect personal information that you make available as part of that profile.

Collection of Information From Other Sources

We also may collect information about you that we may receive from other sources or from our offline interactions with you to, among other things, enable us to verify, update information contained in our records and to better customize the App for you. We may also collect Personal Information from credit reporting agencies to, for example, determine your creditworthiness, credit score, and credit usage, in accordance with applicable laws.

Collection of Personal and Non-Personal Information Through Surveys and Promotions

From time to time We may provide You with the opportunity to participate in sweepstakes or other promotions on our Service, which might be sponsored or conducted by a third party. If you participate, We will request certain personal information from You. Participation in these sweepstakes and promotions are completely voluntary and You therefore have a choice whether or not to disclose this personal information. The requested personal information typically includes contact information. If there is a third party sponsor involved please make sure to review that party's privacy policy.

Use of Cookies and Other Tracking Technologies

Like many websites and mobile applications, we use “cookies”, which are small text files that are stored on your computer or equipment when you visit certain online pages that record your preferences and actions. We may also use cookies to monitor traffic, improve the App and make it easier and/or relevant for your use. Like many Apps, we use cookies, web beacons and similar technologies to record your preferences, track the use of our Apps and your exposure to our advertisements. We may also use these technologies to monitor traffic, improve the Apps and make it easier and/or relevant for your use. If you delete your cookies or if you set your browser or device to decline these technologies, some features of the App may not work or may not work as designed.

We use both “session” cookies and “persistent” cookies. We do not use flash cookies, web storage, web beacons or other technology that tracks your browsing history across multiple Apps.

We use cookies for the other purposes set out below:

We use cookies to remind us who you are and to find your account information in our database when you access a Service so you do not need to log in at every visit. This helps us to provide you with service tailored to your specific needs and interests. A cookie is created when you register for a Service

We use cookies to determine the browser the visitor uses so the Apps can be designed to work properly with the most common versions of different browsers

We use cookies in conjunction with sending you e-mail newsletters

Advertisers that place ads on the App may use cookies

We use cookies in conjunction with analysis of your use of our App and generate analytics regarding our App

We use cookies to estimate our audience size. Your browser is given a unique cookie that helps us determine whether yours is a repeat visit or a first visit

We also use Google Analytics, a web analytics service provided by Google, Inc. (“Google”), on our Apps. Google Analytics uses cookies or other tracking technologies to help us analyze how users interact with and use the Apps, compile reports on the Apps’ activity, and provide other services related to Apps activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a return visitor, and any referring App. The Apps do not use Google Analytics to gather information that personally identifies you. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. To learn more about Google’s partner services and to learn how to opt out of tracking of analytics by Google click here.

We may partner with third-party advertising companies to better provide advertisements about our goods and services that may be of interest to you. These third party advertisers may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use the Apps. They may collect information about your online activities over time and across different Apps and other online services. They may use this information to provide you with interest-based advertising or other targeted content. These online advertising partners do not have access to or use your name, address, e-mail address, telephone number or other personally identifiable information from us, without your consent. They may, however, use persistent identifiers to anonymously track your Internet usage across other Apps in their networks beyond these Apps. While we restrict their further use of such information, such third parties may, with sufficient data from other sources, be able to personally identify you, unknown to us.

Third-party ad serving companies and other unaffiliated advertisers also display advertisements on our Apps. As part of their service, they may place a separate cookie on your computer or utilize other data collection and tracking technologies, to collect information such as your IP address, browser type, the server your computer is logged onto, the area code and zip code associated with your server, and whether you responded to a particular advertisement. For a listing of the third party companies we may allow to place cookies to serve ads on the Apps, click here. We do not control these third parties’ tracking technologies, how they may be used, or the information they may collect and we are not responsible for the privacy policies or the content of those third parties. Please visit the sites of those businesses at the links above to review their privacy policies. We may add or change the list of third party ad servers from time to time and we encourage you to check this section for changes.

Many of the third party advertisers that place tracking tools on our Apps are members of programs that offer you additional choices regarding the collection and use of your information. You can learn more about the options available to limit these third parties’ collection and use of your information by visiting the Apps for the Network Advertising Initiative and the Digital Advertising Alliance, as well as the webpages for Facebook’s ad preferences tool and privacy policy.

Please note that opting-out of advertising networks services does not mean that you will not receive advertising while using our Apps or on other Apps, nor will it prevent the receipt of interest-based advertising from third parties that do not participate in these programs. It will, however, exclude you from interest-based advertising conducted through participating networks, as provided by their policies and choice mechanisms.

How Do We Use Your Information?

We use the information we learn from you to help us personalize and continually improve your experience on the App. We may use your Personal and Non-Personal Information in the following ways:

General Uses

To upload your content to our App as you request

To permit you to update, edit, and manage your content on our App

To communicate with you about your account or transactions with us (including service related announcements) and send you information about features and enhancements on our App

To communicate with you about changes to our policies

To communicate with you about your comment to a blog post

To personalize content and experiences on our App, including providing you reports, recommendations and feedback based on your preferences

To disclose anonymized Personal Information to disclose statistics and analytics and other details regarding the use of our App.

To optimize or improve our products, services and operations

To automatically update the App on your device

To detect, investigate, and prevent activities that may violate our policies or be illegal

To perform statistical, demographic, and marketing analyses of users of the App

Combination of Your Personal Information

We use the information from one portion of the App on other portions of the App or elsewhere in our network of Apps, apps, and other interactive features, or in reports and analysis, all of which are owned and operated by Locals, and we may combine information gathered from multiple portions of the App into a single customer record or analysis or report. We also use and/or combine information that we collect off-line or we collect or receive from third party sources to enhance, expand, and check the accuracy of your customer records.

Who Do We Provide Your Information To?

Except as disclosed in this Privacy Policy, we do not disclose information about your Personal Information collected online to any companies not part of Locals or its parent, subsidiaries or related entities. In no event will we sell or rent your Personal Information as part of a customer list or similar transaction.