- 1. OUR CORE VALUES
- 2. WHO IS RESPONSIBLE FOR PROCESSING YOUR PERSONAL DATA?
- 3. DATA WE COLLECT
- 4. HOW WE USE YOUR DATA
- 5. HOW LONG DO WE KEEP YOUR DATA
- 6. WHO WE SHARE YOUR DATA WITH
- 7. INTERNATIONAL DATA TRANSFER
- 8. DATA SECURITY
- 9. YOUR PRIVACY RIGHTS
- 10. CHILDREN’s PRIVACY AND AGE GATES
- 11. CANDIDATE PRIVACY
- 12. CONTACT
Last update: 27 March 2023
YUBO is a social live-streaming platform that connects millions of young people all over the world. Our goal is to provide a safe and trusted space so that all users can have a positive and respectful experience on YUBO. Protecting our users as well as their privacy is a major priority for us.
We have made the policy as clear and accessible as possible, but if you have any questions about it or about how your data is being used, please contact our team at firstname.lastname@example.org.
By “personal information” or “personal data”, we mean any piece of information that identifies you directly (for example: your photo, your name, your email address) or indirectly (for example: your user id, your location, the technical information related to your device).
When you use the YUBO App (“YUBO”) or visit our website, we collect information about you.
1. OUR CORE VALUES
We are driven by two core values when providing our products and services:
- We highly value your privacy. It means that all the features on YUBO have been built to be privacy-oriented from day one and so that we do not have to seek data that we do not need. It is called "privacy by design".
- Your safety is our priority. Our teams are dedicated to ensuring that you can use YUBO in a safe and appropriate manner. As a technology platform, we have various means to combat conduct and content that may be harmful or offensive to a young audience. You can report any behavior that you feel is inappropriate directly in the app. Our moderation specialists work hard to make sure our Community Guidelines are respected.
In short, we carefully design our products and services to protect your privacy while providing you with a safe experience. We believe that this will give you confidence to make meaningful connections on YUBO.
2. WHO IS RESPONSIBLE FOR PROCESSING YOUR PERSONAL DATA?
TWELVE APP SAS publishes YUBO, a social network that enables you to make friends and engage with them, in particular through live video. It also publishes www.yubo.live.
3. DATA WE COLLECT
3.1. 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 visible to other users.
- Your name and pseudonym, both of which are visible to other users.
- Your date of birth. Other users who are your friends will be able to see your age but not your date of birth.
- Your gender. You can choose to specify it or not. This information is not visible to other users.
- Your profile picture. Your face should be clearly recognizable in your profile picture. This allows us and other users to identify you on YUBO.
- We also require an additional picture of your face to estimate your age from your facial features, to make sure that it is consistent with the birth date you indicated in your profile.
- The password that will enable you to sign in. This data is not visible to other users, and you should never share your password with anyone.
All the foregoing information is necessary in order for you to create your profile and sign up on YUBO.
You may, if you so wish, complete other sections of your profile: emoji, bio, e-mail. This information is optional.
Your interaction(s) with us. If you report a user or content on YUBO, request help, make a claim, participate in a survey or exercise your privacy rights (as mentioned in Section 9 below), we will process the information contained in your request/report/claim/feedback as well as the data relating to your YUBO account. We will also process information if another user reports you. This kind of information is not shared nor visible to other users.
If you wish to become a verified profile, or if we have a reasonable doubt about your identity or age, we will request an ID document (which we will remove shortly after the ID verification).
Your location (GPS coordinates). Subject to your consent, we collect and process data concerning your location. This allows you, depending on your settings, to display the city where you are located in your profile and to add people around you as friends. In addition, this location service based on GPS data is not available to users under 15 years old. Other restrictions may apply depending on your age, country and applicable laws.
Your approximate location (IP Address): If geolocation based on GPS data is not activated or is not available to you as explained above, we collect your approximate location - such as your city - derived from your IP address to deliver a better experience.
The contents you share on YUBO. When you use features available on YUBO we will process and store the contents you share such as photos, videostream and messages. We also need to process the technical data associated with the content you post (such as the date, device information, IP address).
You should always be aware that the content you share on YUBO may be viewed by other users with whom you are interacting, who may save your content through their device (for example by taking a screenshot of their phone).
When using YUBO, we do not encourage you to share sensitive information such as data revealing your racial or ethnic origin, your political opinions, religious beliefs, or data concerning your health, your sex life, or your sexual orientation. It is, however, your freedom of expression to do so as long as you respect the rules in force on the platform. In this case, you should be aware that you are manifestly making this information public.
Your app preferences. We save and follow your settings related to the app features. For examples, if you choose to view lives only from your country and/or from your friends. These settings are not visible to other users. In addition, you can choose not to be seen by other users in the swipe features.
Access to your camera, photos, and videos. In order to send and upload your photos or videos from your device and use the live video feature, we need your permission to access your media and your camera.
3.2. Data we collect automatically when you use our services
Information on user acquisition. With your permission, we collect technical information such as your advertising IDs (which are randomly generated numbers that you can reset in your device’s settings) to help us measure the performance of our marketing campaigns and attribution (more information in Section 4.3 below).
Information about your activity on YUBO. Your use of our services leads to the collection of the following data:
- the YUBO id associated with your account,
- the date you signed up,
- the date you last logged in,
- your country of residence, based on the country code of your phone number (not your geolocation),
- your settings on YUBO, such as notification preferences,
- your interactions with the YUBO features and other users (such as the number of likes or dislikes via the swipe feature).
Information about your purchases on YUBO. If you purchase paid items available on YUBO, we will keep your purchase and subscription history; however, we do not process your payment details. This information is collected and processed by your app store (App Store, Google Play Store).
Data concerning devices and hardware: We collect the following information relating to the device(s) and hardware you use to access our services:
- your IP address,
- your device brand and model,
- the advertising IDs e.g., Google’s AAID and Apple’s IDFA, both of which are randomly generated numbers that you can reset via your device settings,
- app bugs and crashes,
- version and language,
- your device’s operating system.
4. HOW WE USE YOUR DATA
We mostly need to use your personal data to provide you with the services offered on YUBO and to create a safe, smooth and high-quality experience for you. To give you more details and examples, you can read below the list of purposes for which your data may be used.
4.1. To manage your account and your relationship with YUBO, and to make the app features available to you
- Create and manage your user account (including access to YUBO services and Help). Depending on your jurisdiction, we may request parental permission before you can use YUBO.
- Allow you to enjoy the features available on YUBO and that you request, including watching or streaming live videos, using the swipes to make new friends, adding fun content in your profile or in other features, getting your account ‘verified’, sending messages and photos to your friends, purchase paid items and/or subscriptions if you wish.
- Manage and store messages exchanged between users who have become friends and live videos.
- Where appropriate, show you offers and content we think you’ll like, in particular when using certain paid services (e.g., YUBO’s ‘Power Pack’);
- Manage and respond to your requests, questions and complaints addressed to our support team.
Consent may be an additional legal basis in situations where we need parental permission to let you join YUBO.
4.2. To improve our services and the user experience
- Measure how you use our services, which features you like the most, which ones you like less, make usage statistics of our app, and analyze them.
- Create and develop new features on YUBO, and perform tests before launching new features.
- Understand the technical issues you may encounter, to resolve them.
- Manage our internal communication and marketing activities, such as the animation of the YUBO community, or internal statistical studies.
- Evaluate the quality of our responses when you contact our support team.
- Improve the user experience, the technical operation of the app, and the way users can communicate through the app.
We rely on TWELVE APP’s legitimate interests as a legal basis for processing your personal data under this Section 4.2. so that we understand your expectations and make your experience on YUBO fun and smooth.
4.3. To provide tailored services and access to some information from your device
- Personalization of services according to location data, to show you live videos nearby, or suggestions of friends nearby. The distance cannot be less than 30km.
- Access to your device's photo album, camera and micro to share images, videos and sound on 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.
- Send you push notifications containing information about our products, safety updates, and interactions with other users.
We rely on your consent as a legal basis for processing your personal data under this Section 4.3 where consent is the legal basis required under applicable laws.
You may withdraw your consent whenever you want or opt out of the processing of your data (depending on applicable laws). Your consent or right to opt out is usually managed via the settings of YUBO and/or of your device.
4.4. To ensure and enhance online safety on YUBO
- Enforcement of policies and procedures to moderate content and profiles that go against our Community Guidelines. This may includes actions like sending you a warning, removing or filtering inappropriate content, requiring you to get verified, or ban your account temporarily or permanently. Actions that may materially affect your use of YUBO (such as a permanent ban) are decided by moderators, according to our internal policies. Some content can be automatically filtered to prevent users from being exposed to it.
- Development and implementation of automated technologies to detect violations of our Community Guidelines and/or manifestly illicit content. Using artificial intelligence, these technologies seek to recognize violations of our rules in the textual content, images, and audio of some live videos. We strive to detect violations such as violence, drug use, spam, and sexually explicit, hateful, or discriminatory content as quickly as possible, even before they are reported. These tools support our moderation efforts and allow us to take immediate action when such violations happen.
- Development and implementation of procedures and technologies to fight against fraud, fake profiles, unsafe and/or harmful behavior for young people (for example, grooming), and ensure the identification of our users.
To this end:
- We automatically detect if your profile picture shows your face.
- We will ask you to verify your identity before accessing your YUBO account if we have reasonable doubts about you based on your activity and your profile information.
- We also request to estimate your age from a picture of your face to ensure that it matches the information you entered in your profile. Our facial age estimation is an age-checking technology provided by our partner Yoti that can estimate a person’s age by algorithmically assessing his/her facial features. We only receive the result of the age estimation carried out by Yoti, who does not keep he photo.
- Profiling for safety purposes. We temporarily flag users who we believe are engaging in unsafe or unlawful conduct on Yubo. Flagging these accounts allows our moderators to conduct investigations and take moderation action, if necessary. Actions that may materially affect your use of YUBO (such as a permanent ban) are decided by moderators according to our internal policies.
- Evaluation of the performance of our safety procedures, policies, and technologies mentioned in this Section 4.4, in order to improve them and develop new ones that we think could be more effective in improving your well-being and safety on YUBO. This includes, for example, the quality review of the work done by our moderators and support specialists, and training of our automated technologies to improve their accuracy over time using artificial intelligence.
We rely on TWELVE APP’s legitimate interests as a legal basis for processing your personal data under this Section 4.4. so that YUBO remains a safe and respectful place of expression and safeguards the trust of our users.
In jurisdictions where analysis of a photo for age estimation purposes is considered biometric information, we request your consent to process this information.
4.5. To comply with our legal obligations and cooperate with the competent authorities where necessary.
- Implementation of a reporting functionality available to users and embedded in all app’s features, i.e. live videos, chat, and swipes. This allows you to report users or content that you believe violates our Community Guidelines. The reports you submit will then be reviewed by our moderators, who will take action against the reported content or user where appropriate.
- Assist law enforcement and remove manifestly unlawful content. We are required to contribute to the fight against criminal offenses online, to promptly remove or disable access to unlawful content as soon as we become aware of it, to notify competent authorities of some types of infringements, and to preserve data for investigations upon request.
- Compliance with any applicable legal or regulatory requirement. This notably includes the processing of your requests to exercise your privacy rights in accordance with Section 9.
We rely on the relevant legal obligation to which we are subject as a legal basis for processing your personal data under this Section 4.5.
Also note that, if necessary, we will use personal information to exercise or defend our legal rights in court, relying on our legitimate interest(s).
4.6. To manage life-threatening emergency situations for anyone using our services.
- Report to competent authorities. We will report situations or content presenting a life threat (such as self-harm or violence) to the competent authorities. Our moderators are trained to identify situations requiring urgent reporting to authorities, depending on the context; they create internal reports to be examined before being transmitted to the competent authorities.
- User assistance. Our specialists provide users in distress with relevant information and documentation.
We rely on the protection of the vital interests of any natural person as a legal basis for processing personal data under this Section 4.6.
5. HOW LONG DO WE KEEP YOUR DATA
5.1. Account Validity Period
We keep your personal information as long as we need it to enable you to use our services.
You can delete your account at any time in the YUBO settings by clicking on ‘Delete my account’. When you delete your account, you will no longer be able to use our services, and your profile will no longer be accessible or visible to other users.
Please note that we will delete your account if you are inactive on YUBO for two years, meaning that you do not access the app for a continuous period of two years.
5.2. Specific Data Retention Periods
Not all the data we process have the same retention period, in particular regarding the following types of data:
- Photos you sent in the chat, including those you may have deleted in the chat, are kept for 12 months and direct messages are kept 24 months.
- Videos and images from live videos are deleted quickly (within minutes to hours). Only screenshots of the live videos may be kept longer if the live videos are reported or if violations of our Community Guidelines are detected.
- We will retain content that is in violation of our Community Guidelines for a certain period of time, even if that content has been removed from the YUBO platform. The retention period may vary depending on the type of content and the type of violation.
- Your interactions with our support team can be kept for up to 5 years after the ticket is closed. It helps us follow up on our actions regarding support and defend ourselves in the event of a claim or legal action.
- Your geolocation (i.e. your device’s GPS data), if enabled, is kept until your next access to YUBO; then it is replaced by your current geolocation.
- An ID document to verify an account will be deleted a few days after verification.
Notwithstanding the provisions of Sections 5.1 and 5.2. above, we will retain some personal data for an additional period of time if we are legally required to do so. We may also need to keep personal information for the time necessary to resolve a dispute or to exercise or defend our legal rights.
7. INTERNATIONAL DATA TRANSFER
TWELVE APP is a French company with affiliates, contractors, and service providers located in several countries around the world. For that reason, TWELVE APP needs to transfer (via communication, access, storage…) your personal data in other jurisdictions than the one to which you belong, including in countries with different privacy laws and which may not be recognized as "adequate" by the European Commission, especially the United States of America.
Therefore, we implement appropriate safeguards (such as the European Commission’s Standard Contractual Clauses where EU data protection laws apply) to ensure that all cross-border transfers comply with applicable rules. To obtain a copy of these Standard Contractual Clauses, you can contact our privacy team at the following address: email@example.com.
8. DATA SECURITY
TWELVE APP has taken steps to protect the confidentiality, integrity, and availability of your personal data. We are doing our best efforts to maintain security measures appropriate to the level of risk involved in the data processing.
We are continually working to improve our security practices to ensure that your data is kept secure.
While we make every effort to help ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will be effective in all circumstances. That is why it is also your responsibility to keep your data such as your password confidential and to immediately notify us in case of a breach of confidentiality of your account data.
9. YOUR PRIVACY RIGHTS
TWELVE APP is committed to providing you with rights regarding your personal data, in accordance with applicable laws.
The conditions for exercising these rights may differ according to the applicable laws and regulations. These rights may be limited as provided by applicable laws and regulations, the rights and freedoms of other people, our confidentiality obligations, trade secrets, and/or the protection of intellectual property rights. Where relevant, you will be informed of the reasons why TWELVE APP could not fulfill all or part of your request.
Here are your privacy rights:
- You have a right to access your personal data and a right to data portability, in which case you may receive a copy of such data in a commonly used format. The easiest way to obtain the requested information is to exercise your right of access directly in the YUBO account settings > Safety and privacy > Personalization and data > Get my data.
- You have a right to obtain rectification of your personal data should they be inaccurate, incomplete, or obsolete. You can update most of your data directly in your YUBO account.
- You have a right to erasure (or “right to be forgotten”) of your personal data. You can also request to delete your account in the YUBO settings > Delete my account.
- You have a right to withdraw your consent if we rely on your consent to process your data. In most cases, you can withdraw your consent in the app settings 'Safety and Privacy' and/or in your device settings.
- You have a right to object to the processing of your personal data if you have a reason due to your particular situation.
- You have a right to restriction of the data processing in some cases, such as if you contest the accuracy of your data, if the processing is unlawful, or if we no longer need your personal data but you need them for the establishment, exercise or defense of legal claims.
- You have the right to issue instructions regarding the retention, deletion, and disclosure of your personal data after your death.
Read the U.S. Privacy Notice for more information about your privacy rights in the United States.
Please note that exercising one of these rights (e.g. by refusing the processing of all or part of your personal data) may impair your experience on YUBO.
If you cannot or do not wish to exercise your rights directly in the app, you can contact our privacy team at firstname.lastname@example.org or by submitting a request here. We will respond to you as soon as possible.
You also have a right to file a complaint before a competent data protection authority regarding the processing of your personal data. While we suggest that you contact TWELVE APP beforehand to fix the issue, you may directly contact the competent data protection authority. You can find more information about your data protection authority if you live in the European Union here, or in the UK here.
10. CHILDREN’s PRIVACY AND AGE GATES
Protecting children’s privacy is important to us. We do not direct YUBO to, nor do we knowingly collect any personal information from, children under the age of thirteen.
We do not allow you to create an account and use YUBO if you are under 13 years old, and we may monitor compliance with this restriction by scanning a photo of your face to ensure that you are over 13 years old. We may also if there is reasonable doubt, ask you to verify your identity.
If we learn that a child under the age of thirteen has provided us with personal information, we will use reasonable efforts to remove the individual’s personal information from our records.
Depending on applicable laws in the country where you reside, we may require parental consent before you can use YUBO.
In addition, age separation rules have been defined within each of YUBO's features. It means that you will not be able to interact with users of all ages on YUBO but only with users in your age range.
11. CANDIDATE PRIVACY
As an employer, TWELVE APP processes the personal data of candidates who apply for a job in our company, whether on the website www.yubo.live, by mail or email, or via a job platform where we publish job offers.
This usually includes the processing of data relating to the candidate’s professional background, education, references, qualifications, remuneration, and the analysis of documents such as a CV and cover letter provided by the candidate.
This information will be processed for the purpose of talent acquisition, reviewing applications, arranging interviews and tests, communicating with the candidate about his or her application, and managing the recruitment process. The data will be kept for up to 2 years after the last contact with the candidate, or sooner if requested by the latter. This retention period allows the candidate to stay informed of opportunities that might interest him or her.
We rely on TWELVE APP’s legitimate interests as a legal basis for processing your personal data under this Section 11.
- By completing the online contact form on the YUBO website (support.yubo.live) or directly via the application;
- By sending an e-mail to email@example.com; or
- By writing to us at the following postal address: TWELVE-APP – Privacy, 59 rue de Ponthieu, bureau 562, 75008 Paris, France.