Introduction

This privacy policy ("Privacy Policy") applies to the personal information that Ploy processes in connection with Ploy apps, websites, software and related services (the “Platform”), that link to or reference this Privacy Policy.

PLOY Technology Limited (“Ploy UK”), a UK company, ("Ploy," "our," "we," or "us") are the controllers of your information processed in connection with this Privacy Policy.

What Information We Collect

We collect your information in three ways: Information You Provide, Automatically Collected Information, and Information From Other Sources. More detail is provided below.

Information You Provide

Profile Information. We collect information that you provide when you set up an account, such as your date of birth, username, email address and/or telephone number, and password. You can add other information to your profile, such as a bio or a profile photo.

User Content. We collect the content you create or publish through the Platform, such as photographs, videos, comments, hashtags, and the associated metadata (such as when, where, and by whom the content was created). Even if you are not a user, information about you may appear in content created or published by users on the Platform. ​​We collect User Content through pre-loading at the time of creation, import, or upload, regardless of whether you choose to save or upload that User Content. We also collect content (such as text, images, and video) from your device's clipboard if you choose to copy and paste content to or from the Platform or share content between it and a third party platform.

Direct Messages. If you communicate with others using direct messages, we collect the content of the message and the associated metadata (such as the time the message was sent, received and/or read, as well as the participants in the communication).

Automatically Collected Information

Technical Information. We collect service-related, diagnostic, and performance information, including crash reports and performance logs. We automatically assign you a device ID and user ID. Where you log-in from multiple devices, we use information such as your device ID and user ID to identify your activity across devices to give you a seamless log-in experience and for security purposes.

Cookies. We use cookies and similar tracking technologies to operate and provide the Platform. For example, we use cookies to remember your language preferences, make sure you don’t see the same video more than once, and for security purposes. We also use these technologies for marketing purposes. We will obtain your consent to our use of cookies where required by law.

Information From Other Sources

We may receive information about you from others, for example, where you are included or mentioned in User Content, Direct Messages, in a complaint, appeal, request or feedback submitted by a user or third party, or if your contact information is provided to us by a user.

How We Use Your Information

We use your information to operate, provide, develop, and improve the Platform, including for the following purposes.

• Provide and administer the Platform, such as enabling you to create, share, and consume content, to interact with other users and their content, and provide user support.

• Personalise and customise your experience on the Platform, such as providing your “For You” feed.

• Enforce our Terms, Guidelines, and other policies that apply to you. We review User Content and other information to protect the safety and well-being of our community.

• Provide certain interactive features, such as enabling your content to be used in other users’ videos, and to suggest your account to other users to help connect you with other users.

• Maintain and enhance the safety, security, and stability of the Platform by identifying and addressing technical or security issues or problems (such as technical bugs, spam accounts, and detecting abuse, fraud, and illegal activity).

• Review, improve, and develop the Platform, including by monitoring interactions and usage across your devices, analysing how people are using it, and by training and improving our technology.

• Share your information with third party platforms to provide you with features, like content sharing at your request when you integrate your Ploy account with a third party service.

• Promote the Platform or third party services through marketing communications, contests, or promotions.

• Comply with our legal obligations, or as necessary to perform tasks in the public interest, or to protect the vital interests of our users and other people.

How We Share Your Information

Service Providers

We engage service providers that help us provide, support, and develop the Platform and understand how it is used. They provide services such as cloud hosting, content delivery, customer and technical support, content moderation, marketing, and analytics. We share Information You Provide, Automatically Collected Information, and Information From Other Sources with these service providers as necessary to enable them to provide their services.

Advertisers. We provide advertisers with aggregate information about the performance of their ads and other content on the Platform in order to help them measure their effectiveness. We create this aggregate information using Information You Provide, Automatically Collected Information, and Information From Other Sources. We share your information directly with advertisers where you give us your permission.

Others

We share your information in other limited scenarios as follows:

Other Users and the Public. Based on your privacy settings, your Profile Information and User Content may be visible to other users and the public. Your profile and content may also be visible to third parties, such as search engines, content aggregators, and news sites. You and other individuals may be able to share your User Content both on and off the Platform, depending on the choices you make in your privacy settings.

Legal Obligations and Rights. We may access, preserve, and share the information with law enforcement agencies, public authorities, copyright holders, or other third parties if we have good faith belief that it is necessary to:

• comply with applicable law, legal process or government requests, as consistent with internationally recognised standards,

• protect the rights, property, and safety of our users, copyright holders, and others, including to protect life or prevent imminent bodily harm. For example, we may provide information (such as your IP address) to law enforcement in the event of an emergency where someone’s life or safety is at risk,

• investigate potential violations of and enforce our Terms, Guidelines, or any other applicable terms, policies, or standards, or

• detect, investigate, prevent, or address misleading activity, copyright infringement, or other illegal activity.

Our Legal Bases and How We Process Your Information

We may only use your information when we have a “legal basis” to do so. We use different legal bases depending on why we use your information (in other words, the “purpose” of our processing). These legal bases are contractual necessity, legitimate interests (ours, yours or those of another party), consent, compliance with a legal obligation, performing a task in the public interest, and protection of vital interests.

Here we explain the legal bases we rely on when we process your information. This section also describes why we use your information, how this information is processed, the categories of information involved, and the associated rights (which always includes the right to access your information).

Contractual Necessity

We use Information You Provide, Automatically Collected Information, and Information From Other Sources where it is necessary to perform the contract you enter into (our Terms) when you register for, access, or use the Platform. This means we use your information to:

• Provide you with the Platform.
  We use your information to allow you to access and use the Platform, including allowing you to create and consume content, interact with others, utilise social features, and provide you with jobs. We also personalise your experience on the Platform, such as providing your “For You” feed, which shows you videos that we think you would be interested in and by suggesting accounts to you.

• Enforce our Terms, Guidelines, or policies.
  We use your information to enforce our Terms, Guidelines, and policies. This may include removing content (including through automated means) or suspending or banning your account if we determine that you are violating our Terms or Guidelines.

• Administer the Platform.
  We also use the information we have to administer the Platform, such as to communicate with you on service related matters, provide you with updates and support, and respond to and process your queries, claims or disputes (including when you tell us about a problem, or ask for a copy of your information).

Your Rights: Whenever we use your information on the basis that it is necessary for the contract we have with you, you have the right to port information you have provided to us.

Legitimate Interests

We use your information where this is necessary to achieve legitimate interests - whether belonging to us, you, or a third party - provided these interests are not outweighed by your interests or fundamental rights and freedoms. We use the information we collect to:

• Enable users to create content with interactive features.

  • Legitimate Interest relied upon: To provide users with tools to inspire creativity, collaboration, and enjoyment, and to create opportunities for users to reach new audiences.

  • Information used: Information You Provide and Automatically Collected Information.

• Suggest your account to other users.

  • We may suggest your account to other users.

  • Legitimate Interest relied upon: To enable users to quickly and efficiently find and connect with other users.

  • Information used: Information You Provide, Automatically Collected Information, and Information From Other Sources.

• Ensure the safety and well-being of our community.

  • We use your information to ensure the safety and well-being of our community, including by reviewing User Content (and if permitted under applicable law, Direct Messages and associated metadata) for breaches of our Terms, Guidelines, and other policies. We also infer your age range, and under certain circumstances, may ask you to provide additional information to confirm your age.

  • Legitimate Interest relied upon: To keep our community safe, review compliance with our Guidelines, and identify misuse of the Platform.

  • Information used: Information You Provide, Automatically Collected Information, and Information From Other Sources.

• Ensure the security and stability of the Platform.

  • We use your information to ensure the stability and security of the Platform, including by identifying and combating technical or security issues (such as technical bugs, spam accounts, and detecting abuse, fraud, and illegal activity).

  • Legitimate Interest relied upon: To ensure the ongoing stability and security of the Platform and to ensure it is continuously available and functioning.

  • Information used: Information You Provide, Automatically Collected Information, and Information From Other Sources.

• Review, improve, promote and develop the Platform.

  • We use the information we have to understand how people are using the Platform and to develop and improve the Platform, including to train, develop, and improve our technology such as our machine learning models and algorithms. We also use this information to better understand and promote the Platform, popular topics, and emerging trends.

  • Legitimate Interest relied upon: To improve, promote, and develop the Platform in an informed way.

  • Information used: Information You Provide, Automatically Collected Information, and Information From Other Sources.

• Share your information with third parties.

  • We share your information with third parties whose platforms or services are integrated with the Platform.

  • Legitimate Interest relied upon: To provide you with a seamless experience, allow your content to be shared on other platforms, enable third parties to authenticate users, and optimise user experience.

  • Information used: Information You Provide, Automatically Collected Information, and Information From Other Sources.

• Marketing communications.

  • We may send you direct marketing messages about features of the Platform and third party services that we think will interest you. We may also send you promotions, contests, or marketing campaigns or event information. We will obtain your consent to send you messages where required by law.

  • Legitimate Interest relied upon: To promote the Platform or third party products and services.

  • Information used: Information You Provide, Automatically Collected Information, and Information From Other Sources.

Your Rights: Whenever we use your information on the basis that it is necessary for legitimate interests, you can object to, and request restriction of, such usage.

Compliance with a legal obligation

We may use your information including your Profile Information or User Content where it is necessary to comply with a legal obligation. This includes situations where we have obligations to take measures to ensure the safety of our users, or comply with a valid legal request such as an order from law enforcement agencies or courts. We generally use Information You Provide and Automatically Collected Information, although it depends on the specific situation.

To perform a task in the public interest

We may use your information where it is necessary to perform a task in the public interest, including undertaking research, preventing and detecting crime, safeguarding children and promoting public safety, security, and integrity as laid down by applicable law. We generally use Information You Provide and Automatically Collected Information, although it depends on the specific situation. Your rights: When we use your information on the basis that it is necessary for a task carried out in the public interest, you have the right to object to, and seek restriction of, our usage.

To protect someone's vital interests

We may use your information where it is necessary to protect your or someone else's life, physical integrity, or safety. This could include providing law enforcement agencies or emergency services with information in urgent situations to protect health or life. We generally provide Information You Provide and Automatically Collected Information, although it depends on the specific situation.

Your Rights and Choices

You have rights and choices when it comes to your information. Some of these rights apply generally, while others will only apply in certain circumstances. Depending on the scenario, these rights may be subject to some limitations.

Your Rights: Whenever we use your information on the basis that it is necessary for legitimate interests, you can object to, and request restriction of, such usage.

• Access your information.
  You can ask us, free of charge, to confirm what information we process about you, to provide certain information about the processing, and for a copy of your information at hi@ploy.club.

• Delete your information.
  You can delete or ask us to delete some or all of your information. In-app controls enable you to:

  • delete the content posted on your profile, such as your User Content and your Profile Information.

  • delete your full account.

  • request the deletion of a particular piece of content by sending an email to hi@ploy.club.

• Rectify your information.
  You can change or ask us to change or correct your information where that information is not accurate. You can change or correct much of your information through the in-app controls and settings (such as your Profile Information and video content).

• Port your information.
  You have the right to data portability in circumstances where we rely on contractual necessity or consent as our legal basis. This means that you have the right to receive your information in a structured, commonly used, and machine-readable format and to share it with a third party.

• Object to the processing of your information.
  You also have the right to object to the processing of your information in certain circumstances. This right applies when we are performing a task in the public interest, pursuing our legitimate interests or those of a third party, or when your data is processed for the purpose of facilitating scientific or historical research in certain circumstances. In submitting an objection request, please provide all relevant information, including the processing activity you are objecting to, why you want to object and how the processing activity affects you, and any additional information that you think will help us review your request. We will stop the particular processing if we don't have compelling legitimate grounds to continue that processing or don’t need it for legal claims.

• Restrict the processing of your information.
  You have the right to request the restriction of the processing of your information where

  • (a) you are challenging the accuracy of the information,

  • (b) the information has been unlawfully processed, but you are opposing the deletion of that information,

  • (c) where you need the information to be retained for the pursuit or defence of a legal claim, or

  • (d) you have objected to processing and you are awaiting the outcome of that objection request.

To exercise any of the above rights, please contact us at hi@ploy.club. Before we can respond to a request to exercise one or more of the rights listed above, you may be required to verify your identity or your account details or provide additional information so that we can understand your request.

We encourage you to “Contact us” if you are not satisfied with how we have responded to any of your rights requests.

Data Security and Retention

Security of your information is important to us. We maintain appropriate technical, administrative, and physical security measures that are designed to protect your information from unauthorised access, theft, disclosure, modification, or loss. We regularly review our security measures to consider available new technology and methods.

We retain information for as long as necessary to provide the Platform and for the other purposes set out in this Privacy Policy. We also retain information when necessary to comply with contractual and legal obligations, when we have a legitimate business interest to do so (such as improving and developing the Platform, and enhancing its safety, security and stability), and for the exercise or defence of legal claims.

The retention periods will be different depending on the type of information and the purposes for which we use the information. For example, when we process your information to provide you with the Platform, we keep this information for as long as you have an account. This information includes your Profile Information, User Content, and Direct Messages. If you violate our Guidelines or Terms, we may remove your Profile Information and/or User Content from public view immediately but keep your information as is necessary to process the violation.

Younger Users

You must be at least 18 years old to use the Platform. If you believe that there is a user who is below this minimum age, please contact us at hi@ploy.club.

Changes to this policy

We will occasionally update this policy to reflect changes in our practices. We recommend that you check this page from time to time to inform yourself of any changes in this policy.

Contact Us

You can contact us about this Privacy Policy by email at hi@ploy.club.