Privacy policy.

Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at privacy@tribela.com.

Personal information you disclose to us

When you create an account, upload content, contact us directly, or otherwise use our Services, you may provide some or all of the following information:

Account and profile information. The personal information that we collect depends on how you interact with us and use the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• Names
• phone numbers
• email addresses
• usernames
• passwords
• profile images

This may also include information to verify an account such as proof of identity or age and your choices and communication preferences.

User-generated content. This includes all comments, photographs, audio recordings, videos, text and hashtags that you upload and share as part of your use of the Services and the associated metadata, such as when, where, and who the content was created by.

Messages. This includes the information you provide when you compose, send, or receive messages through the messaging functionalities available as part of the Services and information about the message, such as when it was sent, received, or read, and message participants.

Support. Information in correspondence you send to us, including when you contact us for support.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information we receive from other sources

We may receive the information described above from other sources, such as:

Google API. Our use of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

User-generated content. We may receive information about you from other users, including where you are included or mentioned in content created by other users, direct messages, in a complaint, appeal, request or feedback submitted to us, or if your contact information is provided to us.

Information we automatically collect about you

Geolocation Information. We may collect location-based information from your mobile device, either continuously or while you are using our mobile application(s), to provide certain location-based services. If you wish to change our access or permissions, you may do so in your device's settings.

Mobile Device Data. We collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). We may also collect information about the phone network associated with your mobile device, your mobile device's operating system or platform, the type of mobile device you use, your mobile device's unique device ID, and information about the features of the Services you accessed.

Cookies. We and our service providers use cookies and other similar technologies to automatically collect information, measure and analyse how you use our Services, including how you interact with content, enhance your experience, improve our Services, provide you with advertising, and measure the effectiveness of advertisements and other content.

We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage your account. We may process your information so you can create and log in to your account, as well as keep your account secure and in working order.
• To deliver Services to you. We may process your information to provide you with the requested service.
• To respond to user enquiries/offer support to users. We may process your information to respond to your enquiries and solve any potential issues you might have with the requested service.
• To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
• To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user.
• To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
• To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see 'WHAT ARE YOUR PRIVACY RIGHTS?' below.
• To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
• To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
• To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.
• To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.
• To verify identity and age of users.
• To provide content moderation and safety features. We may process your information when necessary to provide reporting, blocking and AI moderation functionalities.

We only process (ie collect, use and share your information) the information we collect about you as set out above when we believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable data protection law, like with your consent, to comply with laws, to provide you with services to enter into or fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate interests.

We use different legal bases to process your personal information, depending on the specific purpose. In some cases, the same type of information may be processed under different legal bases for different purposes. Below, we explain each legal basis and how it applies to the way we use your data.

Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.

Performance of a Contract. We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.

Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:

• To create, provide, support and maintain innovative products and features for our Services.
• Send users information about special offers and discounts on our products and services.
• Support our marketing activities.
• Diagnose problems and/or prevent fraudulent activities.
• Analyse and understand how our users use our Services so we can improve user experience to engage and retain users.

Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.

Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

We may share information in specific situations described in this section and/or with the following third parties.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents ('third parties') who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organisation apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.

The third parties we may share personal information with are as follows:

AI SERVICE PROVIDERS

OpenAI, Google Cloud AI and Amazon Web Services (AWS) AI

CLOUD COMPUTING SERVICES

Amazon Web Services (AWS)

CONTENT OPTIMISATION

Vimeo video

DJANGO

Admin panel

GETSTREAM

To provide instant messaging services

K-ID VERIFICATION

To provide age assurance services

MANDRILL / MAILCHIMP

For the purposes of sending you emails and newsletters

TWILIO SMS

SMS

We also may need to share your personal information in the following situations:

Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

Other Users. When you share personal information (for example, by posting comments, contributions, or other content to the Services) or otherwise interact with public areas of the Services, such personal information may be viewed by all users and may be publicly made available outside the Services in perpetuity. Similarly, other users will be able to view descriptions of your activity, communicate with you within our Services, and view your profile.

This may involve transferring your personal data to countries outside of your country of residence, including jurisdictions that may not offer the same level of data protection as those in your home country or region (such as the UK, EU, or other areas with comprehensive data protection laws). Whenever we transfer personal data internationally, we take steps to ensure that appropriate safeguards are in place to protect your information in accordance with applicable data protection laws. These safeguards may include contractual protections, such as standard contractual clauses, or reliance on adequacy decisions or other lawful transfer mechanisms.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required as a result of the following:

• a legal request or obligation, including obligations of Tribela or to comply with applicable law;
• a governmental investigation;
• an investigation of possible breaches our terms or policies;
• for safety and security purposes and to prevent harm to other users of our Services;
• to protect ourselves, including our rights, property or products; and/or
• if required in relation to a legal claim, complaint, litigation or regulatory proceedings.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process.

All information you provide to us is stored on secure servers. Where you have chosen a password which enables you to access your account and our Services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, no electronic transmission over the Internet or information storage technology is completely secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

Under relevant data protection laws, you have rights including:

Access — you have the right to ask us for copies of your personal information, subject to applicable law. See 'How to view and manage your account information' section below for further information about how you can exercise this right.

Rectification — You have the right to ask us to rectify personal information you think is inaccurate and can ask us to complete information you think is incomplete, subject to applicable law.

Erasure — You have the right to ask us to erase your personal information in certain circumstances and subject to applicable law.

Restriction — You have the right to ask us to restrict the processing of your personal information in certain circumstances.

Objection — You have the right to object to the processing of your personal information in certain circumstances.

Portability — You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

We will consider and act upon any request in accordance with applicable data protection laws. These rights may be limited in some circumstances by applicable law.

Complaints: If you have concerns about how we handle your personal data, we encourage you to contact us first using the details provided in this notice. We will do our best to resolve your concerns.

If your concerns remain unresolved, you have the right to lodge a complaint with your applicable data protection authority.

For UK users, you can contact the Information Commissioner's Office (ICO) at https://ico.org.uk/concerns/.

If you are located outside the UK, you may also have the right to complain to your local data protection authority. Please refer to your national regulator's website for more information.

Withdrawing your consent

If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section 'How can you contact us about this notice?' below or updating your preferences through your account.

However, please note that if you choose to withdraw your consent this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications

You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section 'How can you contact us about this notice?' below. You will then be removed from the marketing lists. However, we may still communicate with you, for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

How to view and manage your account information

If you would at any time like to review or change the information in your account or terminate your account, you can:

• Log in to your account settings and update your user account.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

In addition to managing your personal information directly through your account, subject to applicable law, you may also be able to request access to the personal information we hold about you by submitting a data subject access request or similar request. To do so, contacting us at privacy@tribela.com and we will respond in accordance with applicable data protection laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated 'Revised' date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

If you have questions or comments about this notice, you may email us at privacy@tribela.com or contact us by post at:

Tribela Ltd
Suite 128, 94 London Road
Oxford, Headington OX3 9FN
England