By registering and using YUBO (including but not limited to Yubo’s website, application and other services, collectively the “YUBO”) you will provide us, and we will collect, information about you, including information used to identify you. This is what we call your “Personal Data”. This means data that lets you identify yourself directly, like your family name, first name or your image, or indirectly such as your password, phone number, or your browsing or session data. It is important for you to know how this Data is collected, what we do with it and for how long, so you can be fully informed about your rights. This is why we have prepared this document, which we have tried to make as clear and simple as possible. If, despite our efforts, you would still like to ask us any questions please do not hesitate to contact us using the contact details in section 10.
WHO IS RESPONSIBLE FOR PROCESSING YOUR PERSONAL DATA?
It’s TWELVE APP SAS. We are a French company and our head office is at 8 rue de Charonne, 75011 Paris, France.
TWELVE APP SAS publishes the YUBO application, a social network that enables you to make friends and chat with them, in particular through live video.
WHAT DATA DO WE COLLECT?
In order to operate YUBO, we collect the information (i) which you provide to us directly, as well as (ii) data which we collect automatically, within the territory where we provide our services and where the user is located.
(i) Data you provide to us directly
Registration data: in order to be able to use YUBO, you must create an account and provide us with the following personal details:
- Your mobile number (which is not shared with other users)
- Your name and pseudonym (both of which are visible to other users)
- Your date of birth: this information will not be provided to other users, although they will be able to see your age. Minors under 13 are not permitted to use YUBO.
If you are a minor aged between 13 and 17 you may require permission from your legal guardian in order to register on YUBO.
- Your gender: you can choose whether or not to specify you are male or female, but you must tick one of the boxes. This information will not be visible to other users.
- Your profile picture: the photo that you choose to use as your profile picture must be of you. This will allow other users to identify you on YUBO and allow us to ensure that people do not use false profiles, which guarantees not only the security of the application, but your security too.
- The password that will enable you to log into your account. Naturally, this data is not visible to other users, and you should never share it with other users. Your password is personal and secret. It must contain at least 8 alphanumeric characters. It is required to ensure the security of your account.
All this information is mandatory in order for you to create your profile and to register on YUBO.
You may, if you so wish, complete other sections of your profile (emoji biog, social networks, e-mail). This information is optional.
Data concerning your interaction with YUBO: if you report a problem to us, request help or exercise your rights, we will process the information you provide to us.
In addition, in case of reasonable doubt as to your age, we may ask you to verify your age and ask you for the following information;
Copy of your ID document or school card (which is not shared with other users and is immediately deleted after verification by our teams).
A short video of you pronouncing 3 random words (which is not shared with other users and of which we only keep a screenshot after our teams have checked it).
Data concerning your activity on YUBO: when you use YUBO, we can collect and process information such as the date you register, the date you last logged in, your interactions with other users (number of likes or dislikes via swipes) and your posts. We will also detect inappropriate contents such as explicit language, emojis with hidden meaning, sexual images (e.g. nude or underwear photos), gory, violence, terror, racism, extremism, drugs, self-harm, suicide, gamble, infringement of others’ rights and other illegal or dangerous contents automatically in order to ensure the security of the application and our users.
Data concerning your location (geolocation): subject to your consent and the consent of your legal guardian where required, we collect and process data concerning your location. This enables you, depending on your settings, to include the town/city where you are located in your profile and/or to suggest people in your town/city to add as friends. Your city is hidden by default unless you change the settings to make it visible. If you no longer wish us to know your location, simply untick the relevant box in your account settings. We will therefore no longer be able to display your town/city or suggest meeting nearby friends.
Data concerning content: the photos and/or videos that you decide to upload to your profile will be visible to all users. Be careful what you share with others and don’t forget that all users can save the content you share and that we cannot do anything to stop this and therefore bear no liability for any loss or damage related to it. When you are using the application, be aware that it is possible to deactivate screenshots and screen-record (images and video) by other users in the application, but it is also possible for other users to make screenshots and screen-record (images and video) using the tools on their device, over which we have no control and therefore bear no liability for any loss or damage related to it. The same goes for the videos you post and comments you make via the YUBO live video service. The messaging service is only available to users who are friends. Messages exchanged between users remain private and are not forwarded to other users or third parties under any circumstances, except in the event of a judicial inquiry and/or in accordance with the laws and regulations in force.
Data concerning search preferences: you can configure your settings for privacy and discovery settings by going to ‘Settings’ in your account. You can also use your settings to choose to meet female friends, male friends or both. You can also choose whether or not you wish your contacts that are registered on YUBO to be able to find you and send you a friend request via the application.
Data concerning devices and hardware: we collect information from and on the devices and hardware you use to access YUBO such as the IP address, type of device, advertising identifier (e.g., Google’s AAID and Apple’s IDFA, both of which are randomly – generated numbers that you can reset by going to your device settings), application bugs, version and language, operating system, etc.
Device address book: as YUBO is an application for making and staying in touch with friends, you are permitted to identify your contacts who are already registered on YUBO and to add them, if you so wish, as friends on the application. You can also choose to send a message to your contacts who are not on YUBO to ask them to join you on the app. In order for us to provide this service, we need access to your address book, which we will use to collect data for the above purpose only. We will never add your contacts without your permission, or send them any spam.
Cameras and photos: in order to be able to send and upload your photos from your camera, you must give us permission to access them.
Face geometry: when we have your consent or based on our legitimate interest when allowed by law, we can process your face geometry (i) to estimate your age based on your profile pictures, (ii) to make an identity verification based on an identity document (e.g., ID card or passport), and a picture or a video. You can object to the age estimation in your settings. Our partner Yoti Ltd is processing these data and only communicates to us the results. Once the verification is done, Yoti ltd deletes all data. Our only purpose here is our users’ safety.
Face detection: when we have your consent or based on our legitimate interest when allowed by law, we analyze profile pictures to filter out pictures that do not show a face, and we may also use information from Apple’s TrueDepth camera to improve the quality of our augmented reality experiences.
WHAT ARE THE LEGAL REASONS WHY WE COLLECT DATA?
When we collect and process your Personal Data, we may do so for the following reasons:
- In the legitimate interests of TWELVE APP SAS: we may use your data if we have a legitimate reason to do so. For example, we process data for administrative purposes, to guard against fraudulent and illegal conduct (e.g.: false age), and to ensure that the application remains secure.
- To fulfil a legal obligation: we are required, for example, to keep data identifying new content and to forward it to the authorities if requested to do so.
- With your consent or that of your legal guardian: while we process data with your consent, you may withdraw such consent at any time by going to ‘Settings’.
HOW DO WE USE THE DATA WE COLLECT?
We collect, use and store your Personal Data in order to process your requests, manage our relationship and your use of YUBO, optimize our services and tools in order to create and maintain a secure environment, and fulfill our legal obligations, as explained below.
Managing our relationship and access to YUBO
- To create and manage your user account (including access to YUBO services and Help);
- Geolocate you to put you in touch with friends nearby;
- To manage and store messages exchanged between users who have become friends and live videos;
- Where appropriate, to show you offers, content and adverts we think you’ll like, in particular when using certain paid services (‘Power Pack’);
- To send information message concerning YUBO services and your interactions with other users (Notifications) and for the marketing of YUBO;
- To improve the quality of our augmented reality experiences, information from the TrueDepth camera is used in real time, we don’t store this information on our servers or share it with third parties.
Security and fulfilment of legal and contractual obligations
- To respond to requests from and fulfil the requirements of applicable laws, administrative and judicial authorities, law enforcement officials and legal officers, and to abide by court decisions;
- To identify and prevent fraudulent activity and threats to the security of YUBO pursuant to and in accordance with the law;
- To improve the safety and security of our services;
- To use information collected via cookies or any other technology to improve our services and your user experience. You can read our Cookies Policy by clicking here;
- To counter fraud (for example related to age), confirm your identity, and fight against illegal activity.
HOW LONG DO WE KEEP YOUR DATA FOR?
You can delete your account at any time by clicking on the relevant button in your ‘Settings’. When you delete your account, you will immediately stop communicating your current and future details to TWELVE APP SAS and your profile will no longer be accessible.
We will only keep your Personal Data for the period of time required to fulfil the purposes for which we process your details, unless we are permitted or required by law to keep it for a longer period of time. Generally, we will delete your Data as soon as you delete your account, unless:
We are required, due to an unresolved issue, claim or dispute or applicable law, to retain relevant information until the matter has been resolved;
If the data must be retained in our legitimate commercial interests, for example in order to prevent fraud and improve users’ safety and security. For example, we may be required to retain data in order to prevent a user who has been banned from opening a new account due to their illegal or dangerous conduct or a security incident; or If the users request us to delete their Personal Data.
If your age is checked, we immediately delete your ID document or school card after verification and only keep a screenshot from the short video that you will have sent us.
WHO HAS ACCESS TO THE DATA WE COLLECT?
The data we collect is intended solely for internal use by TWELVE APP SAS and our partners and service providers.
Only certain TWELVE APP SAS authorized managers and employees will process your Personal Data for the above purposes, and they are only permitted to access the data strictly required in order to carry out their work. TWELVE APP SAS may also enter into an agreement with authenticated and reliable service providers and partners who may access and/or process users’ personal data and who guarantee that such data will remain secure and confidential in accordance with this Policy.
These service providers and partners help us to operate and improve YUBO, particularly in relation to the hosting of data, studies, analyses, and statistics, the use and/or operation of the application, targeted advertising, the fight against fraud linked to the age of the user, and the assistance required by users.
Lastly, the data we process may be forwarded to the police and to the judicial and administrative authorities in order for us to fulfil our legal obligations.
WILL YOUR DATA BE TRANSFERRED OUTSIDE OF YOUR COUNTRY?
We guarantee that such transfers are carried out in such a way as to ensure that the data remains confidential and secure and that it is adequately protected in accordance with the regulations in force for the protection of personal data. In this case, we offer guarantees provided by current regulations, such as standard contractual clauses approved by the European Commission, which represent commitments made between companies that transfer Personal Data in order to ensure that such data remains confidential and secure.
HOW IS YOUR DATA PROTECTED?
TWELVE APP will ensure that your data is processed securely and confidentially, including in cases where certain operations are carried out by our partners. Accordingly, appropriate technical and organizational measures are implemented to prevent the loss, misuse, alteration and erasure of your Personal Data.
Nevertheless, there is no ‘zero risk’ on the internet and we cannot guarantee the security of your Personal Data 100%.
That’s why it is important to let us know right away if you think you have been a victim of being attacked, stolen, disclosed, altered, or otherwise infringed of your Personal Data, by writing to us here.
You have the right to access your Personal Data and to request that it be corrected, adjusted, completed, updated. You may also request that your Data be deleted (or you can delete your account in the “Settings” section of the application), request a copy, limit or refuse the processing of your Data, or request that it be limited within the terms of current legislation. You may ask to exercise your right to data portability; in other words, your right to receive your Personal Data in a frequently used structured format and your right to send such data to another processor. As indicated in Section 3 above, your data is processed with your consent and you can withdraw your consent at any time by going to “Settings”.
You also have the right to issue instructions as to how your Personal Data should be used after you die. In order to exercise your rights, you will be asked to produce proof of your identity of any kind. You may submit your request by sending a letter or an e-mail to email@example.com or on YUBO in the ‘Assistance’ section. We will do our utmost to fulfil your requests, but don’t forget that this right is not unlimited and must be exercised according to the conditions of current legislation. Any request to exercise your rights should be reasonable. Where necessary, we will explain the reasons why we are unable to meet your request. If applicable, we may also charge a fee to cover necessary costs arise from the request to review or obtain copies of the Personal Data.
Refusing and/or limiting all or part of the use of your Personal Data by YUBO will impact the way you register and use YUBO. Consequently, all or part of YUBO’s functions and services are likely not to be provided.
Should you have any other complaint, please contact the appropriate national data protection authority.
By completing the online contact form on the YUBO website (support.yubo.live) or directly via the application;
By sending an e-mail to firstname.lastname@example.org; or
By writing to us at the following postal address: TWELVE APP – Privacy, 59, rue de Ponthieu, bureau 562, 75008 Paris, France.
Last updated: November 18th, 2020