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    Dubsmash App & Website Privacy Policy

    This is the Privacy Policy (‘Policy’) for this App and Website which is run and provided by Mobile Motion GmbH, Majakowskiring 55 c/o Wekel Strasser & Kollegen, 13156 Berlin, Germany (we, us us and our). We will only use the personal data gathered as set out in this Policy. Below you will find information on how we use your personal data, for which purposes your personal data is used, with whom it is shared and what control and information rights you may have.

    2. Definitions
    • Personal Data: means any information relating to a natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, or an online identifier.
    • Processing: means any operation which is performed on personal data, such as collection, recording, organisation, structuring, storage, adaptation or any kind of disclosure or other use.
    3. Registration for our Services

    In order to use Dubsmash’s services you have to set up an account. With regard to the registration of an account and its subsequent use, we process:

    • Name, phone number or email address, account information like your profile picture or video, username and password, date of birth and age, user and device information like preferences, time zone, dubbed video files, recorded or imported sound files, location data (opt-in), information about your usage of the service, for example what buttons you click on, and about the device you use to access the service, for example, the device’s unique device identifier, operating system, device language, device region, device time zone, device keyboard settings, push notification token and mobile network Information

    The purposes of these processing activities are provision of our service, troubleshooting, in particular to improve the service’s performance and security.

    For this, the legal basis is Article 6 sec. 1 sent. 1 lit. b and lit. f GDPR.

    Your personal data is retained for as long as your user account is used. After deletion of your account, your personal data will be erased after 24 month. Statutory storage obligations or the need for legal actions that may arise from misconduct within the services or payment problems can lead to a longer retention of your personal data. In this case, we will inform you accordingly.

    4. Information about Facebook Connect

    You may also use your Facebook account to set up an account for Dubsmash. Facebook Connect allows you to sign up and then log in very easily and quickly on Dubsmash by synchronizing the information of your Facebook account and the information required by Dubsmash when creating your profile.

    If you click on the button and log in to Facebook, Facebook and the App service are linked. Facebook then transmits your public profile and your friends list to Dubsmash. For more information on this data transmission, please see the Facebook Privacy Policy.

    5. Evaluation of App Use

    We use our own technology that allows us to improve the service’s performance. This technology works by registering certain events in our database. These events may include start and duration of user sessions with the application, clicks on different buttons within the application, as well as user input like search terms.

    6. Automated decision making

    We do not use your personal data for automated decision making which produces legal effects concerning you or similarly significantly affects you.

    7. Third party content and social media plug-ins
    1. Social media plug-ins
      We use the following social media plug-ins: Facebook, Twitter, Youtube. This allows you to communicate with such service and like or comment on our App. The social media plug-in enables a direct communication between your end user device and the servers of the social media provider, allowing the social media provider to communicate with you and collect information about you browsing our App. This processing is based on Article 6 sec. 1 sent. 1 lit. f GDPR and represents our legitimate interest to improve your App experience and to optimize our services. Transfer of personal data takes places whether you have an account with the provider or not. Please note that we neither have the control of the extent of personal data that is collected by the respective plug-in provider nor do we know the processing’s purpose or the period your personal data will be retained. Further information about the processing of your personal data in the provider’s course of operation is provided via their respective privacy policy. Moreover, you will be provided with further information with regard to your rights and setting concerning privacy.

      • Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA https://de-de.facebook.com/policy.php
      • Twitter Inc., 795 Folsom St., Suite 600, San Francisco, CA 94107, USA https://twitter.com/privacy
      • Youtube LLC, 901 Cherry Avenue, San Bruno, CA 94066, USA
    2. Links to third parties
      This App may contain links to third party websites and/or apps. We are not responsible for the content and the data collection on respective third party websites or apps; please check the privacy policy of respective websites for information of respective websites’ data processing activities.

    8. Sharing your Information

    Your personal data may be disclosed to following third parties. Legal basis for the transfer of your personal data is Article 6 sec. 1 sent. 1 lit. b and f GDPR. We share your information t

    We may disclose your personal data to contractors who assist us in providing the services we offer through the App. Such a transfer will be based on data processing agreements. Therefore, our contractors will only use your personal data to the extent necessary to perform their functions and will be contractually bound to process your personal data only on our behalf and in compliance with our requests.

    Legal basis for the transfer is Art. 28 GDPR and the respective data processing agreement.
    In the event that we undergo re-organisation or are sold to a third party, any personal data we hold about you may be transferred to that re-organised entity or third party in compliance with applicable law.

    We may disclose your personal data if legally entitled or required to do so (for example if required by law or by a court order).

    9. Cross Border Transfers

    Within the scope of our information sharing activities set out above, your personal data may be transferred to other countries (including countries outside the EEA) which may have different data protection standards than your country of residence. Please note that data processed in a foreign country may be subject to foreign laws and accessible to foreign governments, courts, law enforcement, and regulatory agencies. However, we will endeavour to take reasonable measures to keep up an adequate level of data protection also when sharing your personal data with such countries.

    9. Security

    We have reasonable state of the art security measures in place to protect against the loss, misuse and alteration of personal data under our control. For example, our security and privacy policies are periodically reviewed and enhanced as necessary and only authorised personnel have access to personal data. Whilst we cannot ensure or guarantee that loss, misuse or alteration of information will never occur, we use all reasonable efforts to prevent it.

    You should bear in mind that transfer of information over the internet is never entirely secure. We cannot guarantee the security of information you submit via our App whilst it is in transit over the internet and any such submission is at your own risk.

    10. Data Retention

    We strive to keep our processing activities with respect to your personal data as limited as possible. In the absence of specific retention periods set out in this policy, your personal data will be retained only for as long as we need it to fulfil the purpose for which we have collected it and, if applicable, as long as required by statutory retention requirements.

    11. Your rights

    Under the legislation applicable to you, you may be entitled to exercise some or all of the following rights:

    1. require (i) information whether your personal data is retained and (ii) access to and/or duplicates of your personal data retained, including the purposes of the processing, the categories of personal data concerned, and the data recipients as well as potential retention periods;
    2. request rectification, removal or restriction of your personal data, e.g. because (i) it is incomplete or inaccurate, (ii) it is no longer needed for the purposes for which it was collected, or (iii) the consent on which the processing was based has been withdrawn;
    3. refuse to provide and – without impact to data processing activities that have taken place before such withdrawal – withdraw your consent to processing of your personal data at any time;
    4. object, out grounds relating to your particular situation, that your personal data shall be subject to a processing. In this case, please provide us with information about your particular situation. After the assessment of the facts presented by you we will either stop processing your personal data or present you our compelling legitimate grounds for an ongoing processing; and/or
    5. take legal actions in relation to any potential breach of your rights regarding the processing of your Personal data, as well as to lodge complaints before the competent data protection regulators.
    6. require (i) to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and (ii) to transmit those data to another controller without hindrance from our side; where technically feasible you shall have the right to have the personal data transmitted directly from us to another controller;

    You may (i) exercise the rights referred to above or (ii) pose any questions or (iii) make any complaints regarding our data processing by contacting us under the contact details set out below.

    12. Contacting us

    Please submit any questions, concerns or comments you have about this privacy policy or any requests concerning your personal data by email to privacy@dubsmash.com or write to us to Mobile Motion GmbH, Majakowskiring 55 c/o Wekel Strasser & Kollegen, 13156 Berlin, Germany.

    The Information you provide when contacting us will be processed to handle your request and will be erased when your request was completed. Alternatively, we will restrict the processing of the respective Information in accordance with statutory retention requirements.

    13. Amendments to this Policy

    We reserve the right to change this Policy from time to time by updating our App. Please visit the App regularly and check our respectively current privacy policy. This policy was last updated on 25.05.2018.

    © 2018 Dubsmash, Inc. All rights reserved.