Privacy Policy

PRIVACY POLICY effective as of 4.5.18

This privacy policy (the “Privacy Policy”) applies to Question Roulette, a mobile application (the “App”), owned and operated by MCH Communications, Inc. (“MCH,” “we,” “us,” or “our”). We have created this Privacy Policy to tell you what information the App collects, how we use that information, and who we will share that information with, if at all. This Privacy Policy does not address the privacy practices of any third parties that we do not own, control, or are affiliated with. Capitalized terms not defined in this Privacy Policy will have the meaning set forth in our Terms of Use. By downloading, visiting and/or using our App, you are agreeing to the terms of this Privacy. We encourage you to read the Privacy Policy, and to use the information it contains to help you make informed decisions. If you do not agree with the terms in this Privacy Policy, you may not use the App.

1. INFORMATION WE COLLECT OR RECEIVE. In the course of operating the App, we may collect or receive the following types of information. You authorize us to collect or receive such information.

(a) Personal Information. We only receive or collect information that identifies you personally if you choose to provide such personally identifiable information to us via email or other means. When you sign up to become a user or contact us, you will be required to provide us with personal information about yourself (collectively, the “Personal Information”). Such Personal Information may include your name, e-mail address, physical address, and phone number. We do not collect any Personal Information from you when you use the App unless you provide us with the Personal Information voluntarily.

(b) Usage Information. As part of your interaction, you will record audio files through the App. We will store these audio files on a cloud server, for your interaction, using reasonable security measures and standard commercial security. You are free to request deletion of these files at any time. We will not make these files available to any third party, for any reason, unless we obtain your prior written permission.

(c) Payment Information. If you choose to make a purchase or subscribe to a feature or service of ours that requires a fee, you will be required to provide us with your payment information, including, without limitation, bank account numbers, credit card or debit card numbers, account details, ACH information, and similar data (collectively, “Payment Information”). Such Payment Information will be collected and processed by our third-party payment vendors pursuant to the terms and conditions of their privacy policies and terms of use, and we do not obtain access to any Payment Information in connection with such purchases or subscriptions.

(d) Third-Party Analytics. We and third-party technology providers, ad exchanges, ad networks, advertisers, agencies, and ad servers whom we work with may use third-party analytics services (e.g., Google Analytics) to evaluate your use of the App, compile reports on activity, collect demographic data, analyze performance metrics, and collect and evaluate other information relating to the App and mobile and Internet usage. These third parties use cookies and other technologies to help analyze and provide us the data. You consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy. For more information on these third parties, including how to opt out from certain data collection, please visit www.gktraining.com/contact-us. Please bear in mind that removing or blocking cookies can impact on your user experience and parts of the App may no longer be fully accessible. If you wish to opt out of third-party interest-based advertising, please visit http://www.networkadvertising.org and http://www.aboutads.info/choices for details on how to do so. Users of mobile devices may disable interest-based advertising in the settings, limiting ads tracking.

(e) Other Information. In addition to the Personal Information and Payment Information we may automatically collect or receive additional information regarding you and your use of the App; your interactions with us and our advertising; and information regarding your computer and mobile devices used to access the App (collectively, the “Other Information”). Such Other Information may include:

(i) From You.
Additional information about yourself that you voluntarily provide to us, such as your gender and your product and service preferences.

(ii) From Your Activity. We may collect or receive information regarding:
A. IP address, which may consist of a static or dynamic IP address and will sometimes point to a specific identifiable computer or mobile device;
B. browser type and language;
C. referring and exit pages and URLs;
D. date and time; and
E. details regarding your activity on the App, such as search queries and other performance and usage data.

(iii) About Your Mobile Device. We may collect or receive information regarding:
A. type of mobile device;
B. advertising Identifier (“IDFA” or “AdID”);
C. operating system and version (e.g., iOS, Android or Windows);
D. carrier; and
E. network type (WiFi, 3G, 4G, LTE).

(iv) From Cookies. We may use both session cookies, which expire once you close the App, and persistent cookies, which stay on your mobile device until you delete them. We may also use other technologies to help us collect performance data and to enhance your experience with the App. Cookies are small text files an App uses to recognize a repeat visitor to the app. We may use cookies for various purposes, including to:
A. determine the type of mobile device you use;
B. personalize your experience;
C. analyze which portions of the App are visited and used most frequently; and
D. measure and optimize advertising and promotional effectiveness. If you do not want us to deploy cookies in the App, you can opt out by setting your mobile device to reject cookies. You can still use the App if you choose to disable cookies, although your ability to use some of the features may be affected.

2. HOW INFORMATION IS USED AND SHARED. You authorize us to use the Personal Information and Payment Information (collectively, the “Information”) to:
(i) provide and improve our App;
(ii) provide our services;
(iii) administer our promotional programs;
(iv) solicit your feedback; and
(v) inform you about our products and services.
We may engage third-party companies and individuals to perform functions on our behalf. Examples may include providing technical assistance, customer service, marketing assistance, and administration of promotional programs. These other companies will have access to the Information only as necessary to perform their functions and to the extent permitted by law To better understand our users, and continuously improve the App, and our products and services, we may analyze certain Information in anonymized and aggregate form to operate, maintain, manage, and improve the App or such products and services. This aggregate information does not identify you personally. We may share or license this aggregate data to our affiliates, agents, business and promotional partners, and other third parties. We may also disclose aggregated user statistics to describe the App and these products and services to current and prospective business partners and investors and to other third parties for other lawful purposes. We may share some or all of your Information with any of our parent companies, subsidiaries, joint ventures, or other companies under common control with us. As we develop our businesses, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, the Information may be part of the transferred assets. To the extent permitted or required by law, we may also disclose the Information:
(i) when required by law, court order, or other government or law enforcement authority or regulatory agency; or
(ii) whenever we believe that disclosing such Information is necessary or advisable, for example, to protect the rights, property, or safety of us or others, including you.

3. ACCESSING AND MODIFYING INFORMATION AND COMMUNICATION PREFERENCES. If you have provided us any Personal Information, you may access, remove, review, and/or make changes to the same by contacting us as set forth below. In addition, you may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of any of our marketing e-mails. We will use commercially reasonable efforts to process such requests in a timely manner. You should be aware, however, that it is not always possible to completely remove or modify information in our subscription databases. You cannot opt out of receiving transactional e-mails related to the App (e.g., requests for support). We may also deliver notifications to your mobile device (e.g., push notifications). You can disable these notifications by deleting the relevant service or by changing the settings on your mobile device.

4. HOW WE PROTECT YOUR INFORMATION. Any Information we collect is stored on a secure, password-protected server and only authorized personnel have access to your Information. We use industry- standard encryption technologies with respect to the receipt and transfer of any Information you submit. Nevertheless, despite our best efforts, no transmission over the Internet and no data storage method can be guaranteed to be safe 100% of the time. We cannot ensure or warrant the security of any information you transmit to us or guarantee that your end user data stored on the Services may not be accessed, disclosed, altered, or destroyed by breach of any of our industry standard physical, technical, or managerial safeguards. When you enter sensitive information (such as a credit card number) we encrypt such information using secure socket layer technology (SSL).

5. IMPORTANT NOTICES TO NON-U.S. RESIDENTS. The App and its servers are operated in the United States. If you are located outside of the United States, please be aware that your Information, including your Personal Information, may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to use the App, you hereby irrevocably and unconditionally consent to such transfer, processing, and use in the United States and elsewhere.

6. APP STORES; EXTERNAL WEBSITES. Your app store (e.g., iTunes or Google Play) may collect certain information in connection with your use of the App, such as Personal Information, Payment Information, geolocational information, and other usage-based data. We have no control over the collection of such information by a third-party app store, and any such collection or use will be subject to that third party’s applicable privacy policies. The App may contain links to third-party websites. We have no control over the privacy practices or the content of these websites. As such, we are not responsible for the content or the privacy policies of those third-party websites. Please check the applicable third-party privacy policy and terms of use when visiting any other websites.

7. CHILDREN. The App is not directed to children under the age of 13, and we will not knowingly collect or solicit Personal Information from any child under the age of 13. If you are under thirteen years old, you may not use the App. If a child under the age of 13 has provided us with Personal Information, a parent or guardian of that child may contact us and request that such information be deleted from our records.

8. CHANGES TO THIS PRIVACY POLICY. This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time. Any such changes will be posted on the App, and you will have to accept them prior to your continued use of the App. If you do not consent to these terms, you may not continue using the App. Please be aware that, to the extent permitted by applicable law, our use of the Information is governed by the Privacy Policy in effect at the time we collect the Information. Please refer back to this Privacy Policy on a regular basis.

9. MISCELLANEOUS. If any part of the Privacy Policy is determined to be invalid or unenforceable pursuant to applicable law, then the invalid or unenforceable provision will be deemed superseded by a valid, enforceable provision that most closely matches the intent of the original provision and the remainder of the privacy policy shall continue in force and effect.

10. HOW TO CONTACT US. If you have questions about this Privacy Policy, please e-mail us at info@gktandc.com with “Privacy Policy” in the subject line or mail us at the following address: www.gktraining.com