PRIVACY POLICY

Chall AS
Last updated: January 2024

1. Introduction

This privacy policy (the “Privacy Policy”) applies to the personal information that Chall AS, a Norwegian limited liability company with reg. no. 927 063 352 processes in connection with Chall apps, websites, software and related services (the “Platform”), that link to or reference this Privacy Policy.

By using the Platform, you accept and acknowledge that the information collected, used and shared by Chall is collected in the legitimate interest of Chall to provide you and our community of users with the features of the Platform.

2. What Information We Collect

We collect your information directly form you, and from your usage of the Platform. You can see more details about what information we collect using the various methods below.

2.1. 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. 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, audio recordings, comments, hashtags, feedback, reviews, 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 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.

Information When You Contact Us. When you contact us, we collect the information you send us, such as proof of identity or age, feedback, or inquiries about your use of the Platform or information about possible violations of our Terms of Service (our “Terms”), Community Policy (our “Community Policy”), or other policies.

Information From Forms and Features You Use. We collect the Information You Provide when you fill in a form on the Platform. For example, you can ask Chall to set up an organization with you as an administrator.

2.2. Automatically Collected Information

Technical Information. We collect certain device and network connection information when you access the Platform. This information includes your device model, operating system, keystroke patterns or rhythms, IP address, and system language. We also 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.

Location Information. We automatically collect information about your approximate location (e.g. country, state, or city) based on your Technical Information (such as SIM card and IP address). Also, where you enable location services for the Chall app within your device settings, we collect approximate location information from your device.

Usage Information. We collect information about how you engage with the Platform, including information about the content you view, the duration and frequency of your use, your engagement with other users, your search history, and your settings.

Content Characteristics and Features. We detect and collect characteristics and features about the videos, images, and audio recordings that are part of your User Content, for example, by identifying objects and scenery, the existence or location within an image of a face or other body parts; and the text of words spoken in your User Content. We do this, for example, for content moderation and to provide special effects (such as video filters and avatars) and captions.

Inferred Information. We infer your attributes (such as age-range and gender) and interests based on the information we have about you. We use inferences, for example, to keep the Platform safe, for content moderation and, where permitted, to serve you personalized ads based on your interests.

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. To learn more about our use of cookies, please see our Web Cookies Policy and Platform Cookies Policy. We will obtain your consent to our use of cookies where required by law.

3. 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.
- Enforce our Terms, Community Policy, and other policies that apply to you. We review User Content and other information through a mix of technology (including through automated means) and human moderation to protect the safety and well-being of our community.
- 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, analyzing how people are using it, and by training, testing, and improving our technology, such as our machine learning models and algorithms.
- Share your information with third party platforms to provide you with features, like content sharing at your request when you integrate your Chall account with a third-party service.
- Facilitate research conducted by independent researchers that meet certain criteria.
- 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.

4. How We Share Your Information

4.1. Service Providers

We engage service providers that help us provide, support, and develop the Platform and understand how it is used. They may provide services such as: cloud hosting, content delivery, customer and technical support, content moderation, marketing, analytics, and online payments.

4.2. Partners

Third Party Platforms and Partners. We share limited information which may include both information you provide and technical information with third party platforms and partners whose platform or services are integrated with the Platform. We do this to give you a seamless experience, allow your content to be shared on other platforms, and/or enable third party platforms and partners to better authenticate users. Some examples include if you:

- sign-up or log-in to the Platform using your account details from a third party platform (such as Apple or Google), we will share certain technical information to facilitate this,
- share user content you publish on the Platform on other social media platforms, we will share your user content and related information.

Advertisers. We provide advertisers with aggregate information about the performance of their ads and other content on the Platform to help them measure their effectiveness. We create this aggregate information using your information. We share your information directly with advertisers where you give us your permission.

Measurement and Data Partners. We may also share your Information with third party measurement providers who help us measure advertising served on the Platform and help our advertisers determine how effective their ads have been.

Merchants, Payment and Transaction Fulfilment Providers, and Other Service Providers. At a later stage, Chall will introduce the possibility to make payments on the Platform. When you make a payment, we share certain of your information related to the transaction with the merchant, payment and transaction fulfilment providers, and other service providers. For example, we will share the order items, contact details and delivery information so your order can be processed. We may also share certain technical information about your device or connection with these parties to help ensure the security of the transaction.

4.3. Others

We share your information in other limited scenarios as follows:

Users and the Public. Based on your privacy settings, your information, including your profile information, user content, and usage information may be visible to other users and the public. For example, certain information on your profile will be visible for all users on the Platform. Similarly, your content may be made publicly available elsewhere through the Chall sharing feature, or for your contributions to a challenge or competition, in other media as selected by the host.

Hosts. When you contribute to a challenge or competition, the host may be given access to your
contact information (like your e-mail address or phone number, depending on what you have included
in your profile). This may, for example, be relevant if you have won a prize, and the host needs to
contact you to send it to you.

Users of Our Analytics Services. We provide aggregated statistics and insights to help certain users and businesses understand how people are engaging with the Platform. For example, creators and advertisers can receive information about the number of views, cheers, comments and shares of their videos, as well as aggregate demographic information about their followers and the viewers of their videos. We create this aggregate information using your information.

Independent Researchers: We may share your information with independent researchers to facilitate research that meets certain criteria.

Corporate Transactions. Your information may be disclosed to third parties in connection with a corporate transaction, such as a merger, sale of assets or shares, reorganization, financing, change of control, or acquisition of all or a portion of our business.
Legal Obligations and Rights. We may access, preserve, and share your information with law enforcement agencies, public authorities, researchers, 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,
- 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, Community Policy, or any other applicable terms, policies, or standards, or
- detect, investigate, prevent, or address criminal acts, misleading activity, copyright infringement, or other illegal activity.

5. Your Rights and Choices

You have rights and choices when it comes to your information:

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.

Delete your information. You can delete or ask us to delete some or all of your information.

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 user profile).

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 practice, this right is invoked by deleting your account.

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 defense 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 support@chall.no. 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.

6. Data Security and Retention

The 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 unauthorized 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 defense of legal claims.

The retention periods will be different depending on the type of information and the purposes for which we use the information.

All data collected by Chall is stored within the EEA, and it will not be transferred outside of the EEA without your consent.

7. Younger Users

You must be at least 13 years old to use the Platform. If you believe that there is a user who is below this minimum age, please contact us on support@chall.no.

8. Privacy Policy Updates

We may amend or update this Privacy Policy from time to time. We will notify you of any material changes to this policy. The “Last Updated” date at the top of this policy reflects the effective date of such policy changes.