Privacy Policy

PRIVACY POLICY
Last Updated: Aug 10th, 2022

This Privacy Policy describes the privacy practices of NGL Labs LLC (“NGL”, “we”, “us”, or “our”) and how we handle personal information that we collect through our application, website and any other sites or services (collectively, the “Services”).

The basics 
NGL allows users to receive anonymous messages through their social media. This is how it works:

The NGL app permits a user (“App User”) to generate an NGL link and then use the link to solicit messages from anyone with access to the link (the person sending an anonymous message is a “Message Sender”). 

When a Message Sender clicks on the NGL link, they will be taken to a URL where they can send a message directly to the App User. The App User also has the choice to post the anonymous messages and App User’s response to the App User’s social media accounts. 

NGL does not store the name or social media handles of the Message Sender, and cannot reveal this information to the App User or to others. NGL may reveal properties of the Message Sender to the App User, based on the Message Sender’s IP address or browser user agent. Additionally, NGL may share this information with law enforcement for compliance, safety, and integrity issues. 

To protect the safety of our users, we employ AI content moderation services like Hive Moderation. These services utilize deep learning and sophisticated algorithms to screen messages and filter out harmful language and bullying.

Personal information we collect
We collect information about you from a variety of sources, and the type of information we collect depends on how you interact with our Services – such as whether you visit our website, download the NGL app, or send messages to App Users through the Services.

Personal information you provide to us:

Account information,
that App Users provide when they download the NGL app and sign up to use the Services. App Users may provide their social media handle so that we can link the Services to their accounts. They may also upload a profile picture for their NGL account.

Messages that Message Senders submit to App Users through the Services. 

Feedback or correspondence, such as information you provide when you contact us with questions, feedback, product reviews, or otherwise correspond with us online.

Usage information, such as information about how you use the Services and interact with us, including information associated with any content you upload to the Services or otherwise submit to us, and information you provide when you use any interactive features of the Services. 

Other information that we may collect which is not specifically listed here, but which we will use in accordance with this Privacy Policy or as otherwise disclosed at the time of collection. 

Information we obtain from other sources. We may obtain your personal information from other third parties, such as marketing partners, publicly-available sources, lead generators and data providers. 

Automatic data collection.
 We and our service providers may automatically log information about you, your computer or mobile device, and your interaction over time with our Services, our communications and other online services, such as:

Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 4G), and general location information such as city, state or geographic area.

Online activity data, such as  pages or screens you viewed, how long you spent on a page or screen, browsing history, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access, and whether you have opened our marketing emails or clicked links within them.

We use the following tools for automatic data collection:

Cookies
, which are text files that websites store on a visitor‘s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising.

Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.

Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

How we use your personal information
We use Personal information for one or more of the following purposes:

Providing and supporting the Services. We use your personal information to operate, maintain, and provide you with the Services. In particular we will use your personal information to perform our contractual obligation under our terms of use towards you, such as to:Allow you to create an account and use the Services.Respond to your requests, provide customer support, contact you in case of any issue with your account, and send you announcements, updates, security alerts, and support and administrative messages.

Improve, monitor, personalize, and protect our Services and communications. It is in our legitimate business interests to improve and keep our Services safe for our users, which includes:Troubleshooting, testing and research and to keep the Services secure.Investigating and protecting against fraudulent, harmful, unauthorized or illegal activity.Providing customized Services and communications that may be relevant or of interest to you.

Marketing and advertising, including for:

Direct marketing. We may send you direct marketing communications as permitted by law, including, but not limited to, sending newsletters, and notifying you of special promotions, offers and events via email and other means. 

Interest-based advertising. We engage our advertising partners, including third party advertising companies and social media companies, to advertise our Services. Where applicable, if you choose to subscribe to our marketing and advertising, we process your personal information based on your consent, which you may withdraw at any time.

To enforce our agreements, to comply with legal obligations and to defend us against legal claims or disputes. We may use your personal information in our legitimate business interests to enforce and comply with our terms and policies, to ensure the integrity of our Services and to defend ourselves against legal claims or disputes. Some processing may also be necessary to comply with a legal obligation, for example to keep records of transactions, or as requested by any judicial process or governmental agency.

How we share your personal information

Service providers.
 We may share your personal information with third party companies and individuals that provide services on our behalf or help us operate our Services (such as customer support, content moderation, hosting, analytics, email delivery, marketing, identity verification, fraud detection, payment processing, and database management).

Advertising partners. We may share your personal information with third party advertising companies, including for the interest-based advertising purposes described above.

For compliance, fraud prevention and safety. We may share your personal information for the compliance, fraud prevention and safety purposes described above. 

Business transfers. We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution. In such a case, we will make reasonable efforts to require the recipient to honor this Privacy Policy.

How you share your personal information

Other social media users:
App Users may choose to post their responses to messages they receive through the Services to their social media accounts. Your social media settings will determine which other users will be able to view these responses.

Your rights and choices

Personal information requests.
We also offer you choices that affect how we handle the personal information that we control. You may request the following in relation to your personal information: 

Information about how we have collected and used your personal information. We have made this information available to you without having to request it by including it in this Privacy Policy.

Access to a copy of the personal information that we have collected about you. Where applicable, we will provide the information in a portable, machine-readable, readily usable format.

Correction of personal information that is inaccurate or out of date.

Deletion of personal information that we no longer need to provide the Services or for other lawful purposes.

Additional rights, such as to object to and request that we restrict our use of your personal information, and where applicable, you may withdraw your consent.

To make a request, please email us or write to us as provided in the “Contact us” section below. We may ask for specific information from you to help us confirm your identity. California residents can empower an “authorized agent” to submit requests on their behalf. We will require authorized agents to confirm their identity and authority, in accordance with applicable laws. You are entitled to exercise the rights described above free from discrimination.

Limits on your choices. In some instances, your choices may be limited, such as where fulfilling your request would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights. If you are not satisfied with how we address your request, you may submit a complaint by contacting us as provided in the “Contact us” section below. 

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit.  We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Children’s privacy
Our Services are not intended for use by children under 13 years of age. If we learn that we have collected personal information through the Services from a child under 13 without the consent of the child’s parent or guardian as required by law, we will delete it.  If you are a parent or guardian and you are aware that your Child has provided us with personal information, please contact us as set out in the “Contact us” section below. In certain cases, this age may be higher than 13 due to local regulatory requirements.  

International data transfers
Since we are based in the United States, you will provide your data directly to us in the United States. We may transfer your personal information to our affiliates and service providers in the United States and other jurisdictions. Please note that such jurisdictions may not provide the same protections as the data protection laws in your home country.In these instances we will ensure that relevant safeguards are in place to afford adequate protection for your personal information and we will comply with applicable data protection laws, in particular by relying on an EU Commission or UK government adequacy decision or on contractual protections for the transfer of your personal information. For more information about how we transfer personal information internationally, please contact us as set out in the “Contact us” section below.

Retention of personal information
We retain your personal information only for as long as is necessary to fulfil the purposes for which it was collected and processed, in accordance with our retention policies, and in accordance with applicable laws or until you withdraw your consent (where applicable). 
To determine the appropriate retention period for your personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we use your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. 

Security practices
We use reasonable organizational, technical and administrative measures designed to protect against unauthorized access, misuse, loss, disclosure, alteration and destruction of personal information. Unfortunately, data transmission over the Internet cannot be guaranteed as completely secure. Therefore, while we strive to protect your personal information, we cannot guarantee the security of personal information. 

Other sites, mobile applications and services 
Our Services may contain links to other websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third-party websites, mobile applications or online services, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other websites and mobile applications and online services you use. 

Changes to this Privacy Policy
We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on our Services. We may also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via e-mail (if you have an account where we have your contact information) or another manner through our Services.

Contact us
NGL is the entity responsible for the processing of your personal information, and is the data controller in respect of such processing. If you have any questions or comments about this Privacy Policy, our privacy practices, or if you would like to exercise your rights with respect to your personal information, please contact us by email at [email protected] or write to us at 253 N. La Peer Dr., Beverly Hills, CA 90211.