PRIVACY POLICY

OVERVIEW

This ‘Privacy Policy’ prioritize and safeguard you, our community. We believe that everyone should be able to safely experience what being IN YOUR 20 is all about. For this reason, those that fail to respect this ‘Privacy Policy’ may permanently lose access to their account and our community. Please bring an open mind to this incredible experience and leave the rest to us.

This ‘Privacy Policy’ details how we receive, save, and safeguard your information. We do not share your information with any third parties. Please read this ‘Privacy Policy’ along with our Terms of Use

When you enter the IN YOUR 20 App (The ‘App’) for the first time, we ask for the absolute minimum info from you, as we feel you are simply a person, a human being seeking to improve your own life experience while creating meaningful human connections around the world. You may choose to use our App to share information with other people within the App, including your friends or new connections.

We need to share your basic info (Profile Picture, Call Sign (User Name), and country of origin when you join the ‘Live Queue’ (List) to connect with others. This is the only information we share to facilitate creating a global sense of community.

The IN YOUR 20 App is global. Your Profile information will be sent to and safeguarded in North America regardless of the country you reside in. This ‘Privacy Policy’ details how we safely transfer and store your personal data.

WHO WE ARE

“IN YOUR 20 Inc” (Within this Policy otherwise referred to as ‘We’, ‘Us’, ‘Our’) is privately owned and based in Canada. We collect basic client information through our App and website (INYOUR20.com) to ensure a quality in-app experience. If you have any questions, please email us: info@inyour20.com

REGISTER YOUR PROFILE

Once you’ve downloaded our App, we will ask for and store the following info:

Profile Picture (Ideally a ‘Selfie’ that is shoulders up)
Call Sign (Similar to a ‘@Handle’, your unique alpha-numeric ID within our App)
Access to your phone’s camera during ‘Live Sessions’
Email address
Confirm that you are 18+ years of age (You cannot use this app if you are under 18 years of age)
Country of Current Location
Login Password

Once registered, you can review or change this information within the app. The information we collect here in intentionally minimalistic. We want to be as inclusive as possible. Only your Profile Picture, Call Sign, and Country of Current Location will be shown to others within our App.

We will not ask for or store the following info:

First or Last name
Gender identity
Date of Birth
Mobile Number
Sexual Preference
Additional Photographs
Login information from other social media accounts

CALIFORNIA RESIDENCE

For clients residing in California, some of the above data that we collect falls into the “Personal Information” category, defined by the CCPA (California Consumer Privacy Act) listed below:

Identifiers, such as name and locationPersonal information (As defined by California customer records law), such as financial information, and contact information including email and telephone number

Characteristics of protected classifications (As defined by California or federal law), such as age, gender identity, marital status, sexual orientation, race, ancestry, national origin, religion, and medical conditions
Commercial information, such as transaction information and purchase history
Biometric information
Internet or network activity information, such as browsing history and interactions with our App and website
Geolocation data, such as mobile device location
Electronic information, such as photos, videos, and audio recordings
Professional or employment-related information, such as work history and prior employer
Non-public education information
Inferences drawn from any of the above personal information used to create a profile or summary, such as an individual’s preferences and characteristics

PROFILE INFORMATION

We have structured our App’s profile information to be very simple, shifting the primary focus on the ‘Live Session’ experience within our App. We do not include a bio within our client’s profiles to restrict clients from unintentionally over-sharing personal information. When you use our ‘Connections’ feature within our App that is a messaging tool to communicate with other clients, the personal information that you share with others is provided at your own risk.

PURCHASE INFORMATION

If you decide to purchase ‘Sessions’ within our App (Which are in app credits to gain access to the live queue within our App) we will process your payment through Apple’s ‘Apple Pay’ secure payment process. Please note that if your account is blocked for any reason, any account(s) that you may have with IN YOUR 20 Inc. may also be blocked as part of our quality control process.

COUNTRY OF CURRENT LOCATION

We do not ask for or monitor your specific location. Instead, we only ask for you to specify the country that you are currently located in. This request to share your country of current location is to create a greater sense of community within our App. IN YOUR 20 is all about creating deep meaningful human connections around the world. The total opposite of dating apps that focus on prioritizing convenience to hook up with others close by.

DEVICE INFORMATION

When you use our App, we may collect information about your device including the unique device identifier, device model, and operating system.

AD LINKS

We may keep track of client interactions with links available within our APP, including ads that redirect via clicks. We will not share any of this information with third parties, it is for our use only.

SURVEYS

Please email us at info@inyour20.com if our App has left a profound impact on your life, we’d love to hear from you! We may periodically ask if you would like to provide experience-based feedback, testimonials, or join in on marketing campaigns. These surveys are optional and we will provide more information once you have agreed to participate. If you do not wish to be contacted to take part in a survey or marketing campaign, you can request this by emailing us.

CUSTOMER SUPPORT

The best way to get in contact with us is by emailing info@inyour20.com. If someone has acted inappropriately during an in app ‘Live Session’ please report them directly using the available pathways. Records will be kept of our communications with you, including any complaints of other clients, or from other clients about you.

PUSH NOTIFICATIONS AND COOKIES

We ask that you approve our request for you to allow push notifications. These are primarily used to create awareness for clients when other clients have asked to share a ‘Live Session’ with them in the present moment. It is quite important that clients are notified in a timely manor for this to happen as intended, and for our clients to have the best in app experience.

We do ask that you accept any cookies within our App or website. A cookie is a file that is placed within your device or browser that allows companies to recognise and remember you.

USING YOUR INFORMATION

Our primary intention is to ensure that your experience within our App is positive and packed with wonderful energy. To help make this a reality, we may use the information you provide to:

Offer you new or updated features
Carry out market research and analytics about how you interact and use our App and website
Settle conflicts, ensure adherence to our Terms & Conditions, and troubleshoot software related issues
Prevent fraud and protect ourselves from illegal activity
Send you special offers such as seasonal or unique to us: Gratitude based offers. If you have signed up to receive our promotions but no longer wish to receive them, feel free to withdraw from them at any time by opting out using the link provided with each offer
Protect our clients and any third parties from malicious behaviour

MODERATION

We use both automated systems and human moderators to keep an eye on our App. Such as reviewing new accounts, modified accounts, reported behaviour or issues, and messages that indicate a breach of our Terms and Conditions. If an account or message is proven to breach our Terms and Conditions, the relevant account will be subject to appropriate action (Warning, Temporary Suspension, Permanent Ban, and/or Legal Action). The affected client can contact IN YOUR 20 to contest the decision if needed.

LAWFUL DATA USAGE

Under UK and EU laws, we are required to let you know our lawful intentions for use of your data, detailed in the table below. If the legal basis is ‘Consent’, you can withdraw consent whenever desired. If the legal basis is ‘Legitimate interests’, you have a right to object to our use of your data. We detail below how you can withdraw consent or opt-out (Where applicable):

PURPOSE TO USE THE DATA	DATA	SOURCE	LAWFUL BASIS
To access the IN YOUR 20 App	Client’s call sign, email address, confirmation of age 18yr+, country of current location	Client	Legitimate Interests: Minimal information required to ensure App functionality
To send clients marketing information about our special offers, seasonal offers, events, and services	Name, email address	Client	Consent: Information required to communicate with clients, to provide the best in App client experience
To improve the app via research and analysis	Log in and usage data, such as number of live sessions completed and / or cancelled, number of requests to join the live queue, failed attempts to connect live, and client’s feedback from others	Automated within our App	Legitimate Interests: It is in our best interests to quantify how clients are interacting with our App and with each other to provide the best in App client experience
To respond to client’s inquires submitted to us (Including social media)	Client’s email address, name, social media @handle, phone number	Client	Legitimate Interests: It is in our best interests to respond to our clients in a timely manor to address their inquiries, concerns and feedback
To investigate and take required action against clients that have breached our Terms and Conditions and / or Guidelines	Client’s call sign, email address, country of current location, content of messages and photos	Client reporting issue and / or client in question	Legitimate Interests: It is in our best interests to prevent illegal, criminal or otherwise offensive behaviour, and maintain our App as a safe platform
To prevent fraudulent activity during transactions while using Apple products	Client’s Apple ID for secure in App payments	Client	Legitimate interests: We will only ever ask for clients to pay through their Apple ID to maintain secure transactions for both us and our clients
To serve advertisements in the App upon the client’s request, so that they can receive a free ‘Live Session’ instead of paying for one	Client’s call sign, email address, and country of current location	Client	Legitimate interests: As our clients have the option to pay for ‘Live Sessions’ or watch an ad to receive a ‘Free Session’, it is in our best interests to monitor this option to ensure that it functions correctly and is used as intended (Not abused)
To serve advertisements to potential clients on third party networks and measure their effectiveness	Data collected from (Perspective) client’s interactions with our website, Instagram account, Facebook page, and/or App	Client	Consent: Clients may click on the served advertisement to review the offer and must agree to be added to an email list to receive additional special offers, which they can request to be removed from at any time
To contact you in order to find out if you want to take part in marketing campaigns	Email address	Client	Legitimate interests: It is in our best interests to conduct market research to further develop our app and improve the in app experience
To enable live video interactions during an in app ‘Live Session’	Shared Video call using data (Muted audio between clients but requires in app provided shared guided audio recordings for both users to experience together)	Client	Legitimate interests: It is in our best interests to provide these functionalities as part of the paid client experience
To defend legal claims, protect legal rights and to protect people from harm	This could include any information that is relevant to the issue	Directly from a client, a client’s device, or from third parties	Legitimate interests: It is in our best interests to defend against legal claims, protect our legal rights, and to protect our clients and third parties from harm

We will not disclose your Registration Information or personal data, except in the following limited circumstances:

SITUATIONS WHERE DATA MAY BE DISCLOSED	DISCOSED DATA
LAW OR HARM: All Users should behave respectfully and kindly whilst using our App. We will cooperate with all clients, third parties, or global law enforcement agencies as needed to protect ourselves and our clients	This may include any personal client data, depending on the specifics of the request or the legal matter, including all CCPA Categories
BUSINESS TRANSITION: If we or any of our affiliates undergo a business transition such as a change of ownership (Merger, acquisition, re-organisation) or sale of all or part of its assets, or insolvency, or administration, we may be required to share client’s personal information	This may include any or all personal data that we have retained about you, including all categories listed in ‘Lawful Data Usage’ of this Privacy Policy
MODERATORS: To monitor activity within our App and approve content or review reported content	Call signs, registration details, messages, live video screenshots
ADVERTISEMENT SUPPORT PROVIDERS: We will never sell client’s personal information to third party companies	None

IN YOUR 20 Inc. does not sell your personal data. We only collect data within our app to improve our valued client’s experience.

SERVICE PROVIDERS

We utilize several trusted third parties to perform critical functions within our App and provide valued services to us. To provide our services to clients, the following suppliers are utilized:

Billing services: To allow customers to purchase paid features of our App from within the main OS
Authentication services: To allow customers to authenticate their account
Video sharing services: To allow our clients to connect with each other through live video feeds
Product improvement and marketing services: We use third parties to carry out customer surveys and market research to improve our client experience, app performance and grow our community
App development services: We utilize a trusted and valued third party app developer

We conduct due diligence on all Service Providers that we engage with to ensure that they have sufficient data protection and information security measures in effect. We also only provide them with the personal data necessary for that particular service to function correctly. Our suppliers are subject to detailed obligations under our contractual arrangements.

ADVERTISEMENT SUPPORT PROVIDERS

We work with marketing service provides to help us market and advertise our App on third party websites and applications, then measure the effectiveness of these campaigns, such as:

To exclude you from advertising campaigns that target new users if you already have an account
To concentrate our advertisements towards potential clients that have visited our website and signed up to our newsletter but did not download our App
To create an audience for our advertisements of other potential clients who match our target demographic
To include you in a target group campaign based on your country of current location

Data about your visit to our website or App and what you clicked on

Some third parties may use the data that they collect for their own purposes.

SOCIAL AWARENESS

We know that our clients are unique in the best of ways as we believe technology can indeed be used for good. Our App is specifically designed so that those that need support can easily get it, and those that wan to support can easily do so. Our App is not at all about the superficial or ‘Box checking’ ideal qualities. A true character can only be measured in the present through intentional interactions. Let’s all make each other feel wonderful through deep breathwork and conscious human connection.

When using our App, you have assumed that anything you post or submit onto our App may become publicly visible outside of our App. Be mindful of this, which is why we ask for such little profile detail, to prioritize our client’s in App security. When you do upload or share sensitive information about yourself to us, you are explicitly consenting to our processing of this information and making it public to other clients within our App.

ADULTS ONLY (18+)

Clients must be 18 years old to use our App. Sorry kids, we know IN YOUR 20 is where all the high vibe peeps hang, but you will have to wait!

We do not intentionally or knowingly market to or collect any information about children, minors or anyone under the age of 18. Please do not create a profile or submit information to us if you are under 18 years old. We will take immediate action to terminate a client’s profile if we are made aware that they are under age.

HACKING

Sadly, no website or internet transaction can ever be 100% secure. Even we cannot guarantee prevention of unauthorised access, hacking, data loss or other breaches that may occur, but do your part to keep yourself safe:

Log out of your Account on our website after use
Lock your phone before you put it down anywhere
Do not share your login password with anyone
Change your password often

YOUR RIGHTS

Privacy laws within your country of current location may provide you with the following right:

To be informed: What personal data is being used by your provider, defined by this Privacy Policy
Of access: You can request a copy of your data
Of rectification: You can request to have your information corrected if inaccurate
To erasure: You can request to have your information deleted in certain circumstances
To restrict processing: You can request that processing of your information be stopped, but the data retained
To data portability: You can request a copy of certain machine-readable data that can be transferred to another provider
To object: You can object in certain circumstances to processing of data for legitimate interests or marketing reasons
To ensure human intervention in profiling automated decision-making, if solely automated decision-making takes place with legal or significant effects to an individual

Your specific rights applicable to you may vary depending on your country. As such, not all rights may be listed here. Make yourself aware of the rights that you have under the applicable privacy laws within your country.

If you would like to exercise any of your rights listed above, please email us at info@inyour20.com. For the protection of you and all of our clients, we may request additional information from you to help us confirm your identity before we address your inquiry. Further, if you have concerns regarding how we process requests or your personal data, please contact us at the above email.

GLOBAL ACCESS

We want our clients to be able to connect within our App wherever they are in the world, especially when they feel the need to clear their mind and make a new connection. To enable us to provide this service, we operate within Apple’s global network of servers.

DELETEING / DEACTIVIATION OF YOUR ACCOUNT

When you delete your account or when it is deactivated by us, we ensure that it is no longer visible within our App. For up to 4 weeks, your account may be restored if it was deleted accidentally or deactivated wrongfully. After this timeframe, we will take action to delete your personal information from our systems in full, unless:

We must retain your information due to applicable laws (Such as tax purposes)
We must retain your information due to proof of compliance with applicable law (Such as proof of poor behaviour causing an account to be blocked, in case of inquiries or legal claims against the block)
There is an outstanding problem, claim or dispute requiring us to retain relevant information until the dispute is resolved
The information must be retained to improve client safety or fraud prevention such as preventing a client that was banned from creating another account

Take note that even if you remove all your information from your profile or delete your Account, copies of this information may still exist elsewhere outside of our App due to screenshots or other means. We have no control over this, nor do we take on or accept any liability of this. If you have given your personal information to third party applications or websites, they may retain your information to the extent permitted within their own privacy policy.

CHANGES TO THIS POLICY

If you’ve made it this far, we sincerely appreciate your time in digesting all this! We tried to keep it short but global legal details in this modern world… well, we did our best.

As we evolve, we may periodically revise this Privacy Policy. The most current version of this privacy policy will supersede all others and the latest version can always be found at inyour20.com/pages/privacy-policy. If we make a substantial change to this policy at our discretion, we may notify you via the email associated with your Account.

EFFECTIVE

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