Brown Bear Brown Bear Inc. Privacy Policy
Last Update: March 25, 2021
Effective as of: March 25, 2021
Please read our Privacy Policy with respect to our collection, use and disclosure of personal information we collect from visitors through our websites at brownbearbrownbear.com and speaknativeapp.com (the "Sites"), the use of our software applications (the "Apps") and the use of our services (the "Services"). By using the Sites, the Apps, the Services or submitting information to Brown Bear Brown Bear Inc. ("Brown Bear") via a form or using support services, you acknowledge that you accept the practices and policies outlined in this Privacy Policy.
This Privacy Policy addresses:
Information Collection and Use
Updating Personally Identifiable Information
Users Outside of the United States of America
Privacy Policy Updates
Brown Bear may need to update this Privacy Policy from time to time. If so, Brown Bear will post our updated Privacy Policy on the Sites, on the Apps and on the Services, along with notice that the Privacy Policy has been changed so you are always aware of what personally identifiable information we may collect and how we may use this information. Brown Bear may also send registered users that have provided us with their email address an email notification notifying such users of any changes to the Privacy Policy. Brown Bear encourages you to review this Privacy Policy regularly for any changes. Your continued use of the Sites, the Apps or the Services and/or continued provision of personally identifiable information to us will be subject to the terms of the then-current Privacy Policy.
Information Collection and Use
Brown Bear enables people to interact with each other via text messages, voice messages, video messages and/or real time conversations in the form of voice call or video chat. You can generally visit the Sites without having to submit any personally identifiable information about yourself to us. To interact with other people via the Sites or the Apps, you are required to become a "User" by registering an account with your email address and providing login credentials, such as a password. You may also be required to provide introductory information about yourself (the Personal Profile). Your Personal Profile should contain a name and an introductory video. It may also contain any other relevant information you choose to provide in text or other forms. Personal Profiles may contain personally identifiable information. A User may voluntarily submit and share with other Users one or more messages in text, audio or video form, which may contain personally identifiable information. A User may voluntarily submit and share with other Users one or more documents, which may contain personally identifiable information. A User may voluntarily submit and share with other Users one or more uniform resource locators (URLs), which may point to online resources that contain personally identifiable information. We will also collect a unique device identifier ("UDID"), a push notification identifier, IP address, device manufacturer name, device model, operation system type/version and other information about your device and network.
If you contact us with questions or to request information, we will collect the personally identifiable information that you voluntarily transmit with your communications to us. We also may collect personally identifiable information about you that you elect to upload to the Sites, the Apps or the Services.
We may use your personally identifiable information to register you to use the Sites, the Apps and the Services, contact you to deliver certain services or information you have requested, verify your authority to use the Services, the Apps and the Sites, to detect fraud, improve the content and general administration of the Sites, the Apps and the Services.
If you use the Apps or the Services, you may communicate information to other potential or current Users through the Apps or the Services, such as making self-introductions, sharing video posts, having audio or video conversations, leaving messages in the form of text, audio or video, sharing content through URLs, sharing documents, sharing notes or your screen, uploading presentations, streaming audio or streaming videos. Brown Bear does not monitor personally identifiable information that you include in such communications, such as video files, photos, audio files, documents, presentations, audio streams and video streams, but Brown Bear may have access to such communications through your use of the Apps or the Services. We will only use such information as set forth above.
Brown Bear provides services based on speech recognition technology (the "SR Services") to help Users improve their speaking skills. If you use the SR Services, Brown Bear may collect your voice samples and speech recognition results. Brown Bear does not monitor personally identifiable information that you include in your voice samples or speech recognition results, but Brown Bear may have access to such information. We will only use such information as set forth above.
Children's Privacy
You must be 18 years of age in order to use the Sites, the Apps and the Services. Brown Bear does not target the Apps or the Services or the Sites to children under 18. Brown Bear does not knowingly collect personally identifiable information from children under the age of 18.
Cookies
We may use small text files called cookies to improve overall experience on the Sites. A cookie is a piece of data stored on the User's hard drive containing information about the User. Cookies generally do not permit us to personally identify you. We generally use persistent cookies to save your preferences and for support for the internal operations of the Sites, the Apps and the Services. Brown Bear does not respond to browser do not track signals.
Third parties such as providers of external services like web traffic analysis services may also track Users over time and over the Sites and third party websites and such third parties may also place cookies, via the Sites. These cookies are likely to be analytical, performance cookies or targeting cookies.
Brown Bear contracts with various third party analytics vendors, including, without limitation, Google and Zendesk. You can find out more about Google's website analytics tool here: https://analytics.google.com/analytics/web/. You can find out more about Zendesk's website analytics tool here: https://www.zendesk.com/explore/. These analytics providers use cookies to collect feedback regarding the Apps and the Services or to collect information about how visitors use a website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don't collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how a website works. You can find out more about how Google Analytics protects your data here: https://policies.google.com/privacy. You can find out more about how Zendesk protects your data here: https://www.zendesk.com/company/customers-partners/privacy-policy/ and https://www.zendesk.com/company/customers-partners/cookie-policy/.
Through the third party analytic providers, as discussed above, and directly through the Sites and the Apps, we may track information that will be maintained, used and disclosed in aggregate form only and which will not contain your personally identifiable information. For example, we may collect, without limitation, the total number of visitors to the Sites and the Apps, the number of visitors to each page of the Sites, browser type, External Web Sites (defined below) linked to, operating system and IP addresses. We may analyze this data for trends and statistics in the aggregate, and we may use such aggregate information to administer the Sites, and gather broad demographic information for aggregate use.
Disclosure
We may provide your personally identifiable information and the data generated by cookies and the aggregate information to the vendors and service agencies that we may engage to assist us in providing the Services to you for their use solely to provide us with such assistance. For example, we use third party payment processors to process your payments, we use third party vendors to provide voice call and video chat services, the backend servers used by the Sites and Apps are hosted by a third party hosting provider and we use a third party to conduct fraud detection services on the Sites and/or the Apps and/or the Services. Such third parties' use of your personally identifiable information is subject to the third party's applicable privacy policy terms.
We will also disclose your personally identifiable information (a) if we are required to do so by law, regulation or other government authority or otherwise in cooperation with an ongoing investigation of a governmental authority, (b) to enforce the Brown Bear Terms of Service or user agreements or to protect our rights or (c) to protect the safety of users of the Sites, the Apps and the Services. We will not sell your personally identifiable information to any company or organization, but we may transfer your personally identifiable information to a successor entity upon a merger, consolidation or other corporate reorganization in which Brown Bear participates or to a purchaser or acquirer of all or substantially all of Brown Bear's assets to which the Sites and/or the Apps and/or the Services relates.
Links to Third Party Sites
The Sites and the Apps may provide links to other Web sites or resources over which Brown Bear does not have control ("External Web Sites"). Such links do not constitute an endorsement by Brown Bear of those External Web Sites. You acknowledge that Brown Bear is providing these links to you only as a convenience, and further agree that Brown Bear is not responsible for the content of such External Web Sites. Your use of External Web Sites is subject to the Terms of Service and privacy policies located on the linked to External Web Sites.
We may employ procedural and technological measures that are generally consistent with industry practice. Such measures are reasonably designed to help protect your personally identifiable information from loss, unauthorized access, disclosure, alteration or destruction. Depending on the specific Services being used, Brown Bear may use encryption, secure socket layer and password protection to help prevent unauthorized access to your personally identifiable information.
Updating Personally Identifiable Information
Brown Bear provides you with the ability to review and update the registration information that you provide to us by contacting us at privacy@brownbearbrownbear.com.
Questions
If you have any questions regarding this Privacy Policy please contact us via email at privacy@brownbearbrownbear.com.
Users Outside of the United States
Our computer systems and third party hosting provider systems are currently based in the United States, so your personal data will be processed by us in the U.S. where data protection and privacy regulations may not offer the same level of protection as in other parts of the world, such as the European Union. In particular, you are advised that the United States of America uses a sectoral model of privacy protection that relies on a mix of legislation, governmental regulation, and self-regulation. Article 26 of the European Union's Data Protection Directive (Directive 95/46/EC, 1995 O.J. (L 281) 31) allows for transfer of personal data from the European Union to a third country if the individual has unambiguously given his or her consent to the transfer of personal information, regardless of the third country's level of protection.
By using the Sites and/or the Apps and/or the Services you expressly consent and agree to this Privacy Policy and to the transfer to and processing of your personal data in the United States of America as described in this Privacy Policy.
In our discretion, we also may agree to enter into Model Contracts for the transfer of personal data to third countries or a data transfer agreement or we may adopt other means under applicable law for ensuring adequate safeguards.