PRIVACY POLICY

    This Privacy Policy became effective on May 25, 2018.

    ROKO Labs LLC (d/b/a Instabot) (“Instabot”, “us” or “we”) has prepared this Privacy Policy to describe our practices regarding the information we collect from visitors to our website located at www.instabot.io (the “Corporate Site”) and Instabot Platform website located at app.instabot.io and any successor URLs (“Services”).

    Our Corporate Site provides information about Instabot and the services we provide. It is also a portal for customers of the Instabot Platform (“Platform”) to sign in to the Platform. A “Site Visitor” is anyone who visits our Services.

    This Privacy Policy covers the information we collect about you when you use our Services. We will not use or share your information with anyone except as described in this Privacy Policy.

    We may change this Privacy Policy from time to time. We will notify you of important changes by posting a notice on the Services. The Privacy Policy posted on the Services will say when that version went into effect. If you continue to use the Services after a change, then you have accepted the new Privacy Policy.

    The Services are controlled and operated from the United States. Accordingly, this Privacy Policy and our collection, use and disclosure of your information are governed by U.S. law. The Services are not intended to subject Instabot or any of its affiliates to the laws or jurisdiction of any state, country or territory other than that of the United States.

    1. information collected

      Personal Information” is information that can be used to identify a specific living person. Typical examples of Personal Information include your name, email address, employer, postal address, and telephone number. Personal Information also includes information that is linked to your Personal Information for so long as it is so linked. “Other Information” is information that is not sufficient to identify a specific person.

      The Corporate Site collects:

      • The Personal Information that you provide.

      • The Other Information that you provide, or that is automatically generated by your visit.

      In Section 2, we describe the Personal Information that is collected by the Corporate Site or Platform, when it is collected and how it is used. In Section 3, we do the same for Other Information. In Section 4, we describe how we share the Personal Information and Other Information (together “Information”).

      The Corporate Site and Platform are available only to individuals who are 13 years or older. The Corporate Site is not directed to children younger than 13 years old, and Instabot does not knowingly collected Personal Information from children younger than 13 years old.

      If you are a visitor to or user of a third-party website or service (“Third-Party Service”) that utilizes any Services (such as the Instabot bot widget), then any information you submit to such Third-Party Service (including via the Instabot Services) is collected under the privacy policy of the owner of such Third-Party Service, and you should contact such owner with any related requests or inquiries you may have.

    2. about personal information collected by the corporate site and platform

      a. The Personal Information We Collect.

      We collect Personal Information through the Corporate Site and Platform when you:

      • Request information about a product or service.

      • Register for emails, newsletters or other communications.

      • Contribute content to the Corporate Site or Platform.

      • For Platform users only:

        • Provide Personal Information in order to establish log-in credentials for the Platform, or enter Personal Information about yourself or others in connection with your use of the Platform, or direct the Platform (with our written consent) to collect Personal Information about your users, or provide payment information in order to receive fee-based services on the Platform.

        • You may submit various types of information and data into Services (“User Data”). User Data may include information, data and other content that identifies your end user customers, potential customers and other users of and visitors of your websites and applications and is provided in connection with authorized use of the Platform and Services, including without limitation all data and information transmitted to the Platform using scripts, APIs and other code implemented on such properties.

      We may combine Personal Information that you submit on or through the Corporate Site and Platform with information that we collect from and about you from other sources, offline and online.

      b. How We May Use Personal Information. We use Personal Information to do the following:

      • Provide the services that you request when you use the Corporate Site and/or Platform.

      • Send you updates and messages that you request.

      • Send you administrative information, including information regarding the Corporate Site, Platform, and/or changes to our terms, conditions and policies.

      • Personalize your experience on the Corporate Site and/or Platform by presenting content tailored to you.

      • Allow you to send messages to a friend through the Corporate Site and/or Platform. By using such functionality, you are telling us that you are entitled to provide us with your friend’s name and email address for this purpose, and that we are entitled to send your friend the requested message.

      • For our business purposes, such as data analysis, audits, research, product development and enhancement, and product and service improvement.

      • As we believe appropriate (a) to comply with applicable law and legal process, (b) to enforce our terms and conditions, (c) to protect our operations or those of our affiliates, (d) to protect our rights, privacy, safety, or that of our affiliates, you or others, or (e) to allow us to pursue available remedies or limit the damages that we may sustain (these goals, collectively, the “Compliance Purposes”).

      c. When We May Disclose Personal Information. Your Personal Information may be disclosed:

      • To our third-party service providers who provide services such as hosting, data analysis, IT infrastructure, IT services, customer service, email delivery, auditing and other similar services to enable them to provide such services.

      • To identify you to anyone to whom you send messages on or through the Corporate Site or Platform.

      • By you, on or through the user forums available on the Corporate Site or Platform. The information and materials that you post or disclose on or through the user forums available on the Corporate Site or Platform will be viewable by others. WE ARE NOT RESPONSIBLE FOR THE USE OR DISCLOSURE OF ANY INFORMATION THAT YOU VOLUNTARILY DISCLOSE ON OR THROUGH THE USER FORUMS.

      • To a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceeding).

      • As we believe appropriate for Compliance Purposes (defined above).

      d. How Long We Retain Personal Information.

      We will retain your Personal Information (including User Data) for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law, as described in further detail below. After such time, we will either delete or anonymize your information.

      Account information: We retain your account information for as long as your account is active and a reasonable period thereafter in case you decide to re-activate the Services. We also retain some of your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations, and to continue to develop and improve our Services.

      Information you share on the Services: If your account is deleted, some of your information and the content you have provided will remain in order to allow your team members or other users to make full use of the Services.

      Managed accounts: If the Services are made available to you through an organization (e.g., your employer), we retain your information as long as required by the administrator of your account under our agreement with your employer.

      Marketing information: If you have elected to receive marketing emails from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our Services, such as when you last opened an email from us or ceased using your Instabot account. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.

    3. about other information

      a. The Other Information We Collect.

      Other Information includes:

      • Browser and device information.

      • Information collected through cookies, pixel tags and other technologies.

      • Information about how you interact with and use the Corporate Site and Platform.

      • Other aggregated information.

      b. How We May Collect Other Information

      We collect Other Information in a variety of ways, including:

      • From your browser or device: Most browsers send standard information when you use the Internet. This information includes your device type, screen resolution, operating system version, and Internet browser type and version.

      • Through web technologies: We and our service providers may use cookies, pixel tags, web beacons, and other similar technologies to, among other things, facilitate your ongoing access to and use of the Corporate Site and Platform, present you with more tailored information about our products and services, and collect and store information about your use of the Corporate Site and Platform. To decline the use of cookies, consult “Your Choices” in Section 7.

      • That you volunteer: You may volunteer demographic information, as well as other information, such as your preferred means of communication. Unless combined with Personal Information, this information does not personally identify you or any other user.

      • Through activity reports: Information about how you interact with the Corporate Site or Platform is collected in your visits, and is used to determine usage levels, diagnose server problems, and operate and maintain the Corporate Site and Platform.

      • By aggregating information: We may aggregate information collected from the Corporate Site. Aggregated information will not include information that personally identifies you or any other user of the Corporate Site.

      c. How We May Use and Disclose Other Information.

      We may use and disclose Other Information (by definition, non-personally identifiable) for any purpose permitted by applicable law. If we are required to treat any element of Other Information as Personal Information, then we may only use that information as described in the “Personal Information” section above. If we combine Other Information with Personal Information, we will treat the combined information as Personal Information as long as it is combined.

      For clarity, Other Information collected from Corporate Site visitors is non-personally identifiable and cannot be linked to Personal Information, except in the case where the Corporate Site visitor provides Personal Information to the Corporate Site (e.g., in a request for information). By contrast, the Other Information collected from Platform users is, in many cases, linked to Personal Information through the user log-in, and would be Personal Information.

    4. how we share information we collect.

      Service Providers: We work with third-party service providers to provide website and application development, hosting, maintenance, backup, storage, virtual infrastructure, payment processing, analysis and other services for us, which may require them to access or use Information about you. If a service provider needs to access information about you to perform services on our behalf, they do so under close instruction from us, including policies and procedures designed to protect your Information.

      Third Party Apps: You, your administrator or other Service users may choose to add new functionality or change the behavior of the Services by enabling integrations with third party apps within the Services. Doing so may give third-party apps access to your account and Information about you like your name and email address, and any content you choose to use in connection with those apps.

      Third-party app policies and procedures are not controlled by us, and this privacy policy does not cover how third-party apps use your Information. We encourage you to review the privacy policies of third parties before connecting to or using their applications or services to learn more about their privacy and Information handling practices. If you object to Information about you being shared with these third parties, please uninstall the app.

      Links to Third Party Sites: The Services may include links that direct you to other websites or services whose privacy practices may differ from ours. If you submit Information to any of those third party sites, your Information is governed by their privacy policies, not this one. We encourage you to carefully read the privacy policy of any website you visit.

      Compliance with Enforcement Requests and Applicable Laws; Enforcement of Our Rights: In exceptional circumstances, we may share Information about you with a third party if we believe that sharing is reasonably necessary to (a) comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements, (b) enforce our agreements, policies and terms of service, (c) protect the security or integrity of our products and services, (d) protect Instabot, our customers or the public from harm or illegal activities, or (e) respond to an emergency which we believe in good faith requires us to disclose Information to assist in preventing the death or serious bodily injury of any person.

    5. about data security

      We seek to use reasonable physical, technical and administrative measures to protect Personal Information under our control. However, no data transmission over the Internet or data security system can be guaranteed to be 100% secure.

    6. international transfer of data.

      We collect information globally and primarily store that information in the United States. We transfer, process and store your information outside of your country of residence, to wherever we or our third-party service providers operate for the purpose of providing you the Services. Whenever we transfer your information, we take steps to protect it.

      International transfers to third parties: Some of the third parties described in this privacy policy, which provide services to us under contract, are based in other countries that may not have equivalent privacy and data protection laws to the country in which you reside.

    7. your choices

      a. Opt-Outs. We may provide you with the opportunity to “opt-out” of having your personal information used for certain purposes when we ask for this information. If you decide to opt-out, we may not be able to provide certain features of the Offerings to you.

      b. Access and update your information: Our Services and related documentation give you the ability to access and update certain information about you from within the Service. You can update your profile information within your profile settings. Please note that if you cease using the Service or we terminate your access to the Service in accordance with your Agreement, you may no longer have the ability to access or update your information.

      c. Delete your account: If you no longer wish to use our Services, you or your administrator may be able to delete your Services account. If you can delete your own account, that setting is available to you in your account settings. Otherwise, please contact your administrator. You may also contact Instabot support (help@instabot.io) to request your account be deleted.

      d. Right to Access. You may request a copy of the Personal Information that Instabot holds. To request this information, please email us at privacy@instabot.io

      e. Objections to processing. If you object to our processing of your information, or you wish to erase your Personal Information, please email us at privacy@instabot.io

      f. Your choices regarding messages from us. We give you choices regarding the messages that you receive from us.

      • Newsletters and alerts. If you have signed up to receive newsletters or alerts from us, you can unsubscribe to a newsletter or alert, or change the frequency of the messages you receive, under the “Settings” tab of your account.

      • Marketing-related messages. You may opt out from receiving marketing-related messages from Instabot either by using the unsubscribe mechanism provided in the message or by emailing us at info@instabot.io. We do not share your Personal Information with our partners for their marketing purposes unless you give us permission.

      g. Your choices regarding cookies. If you do not want our cookies to collect information about you, there is a simple procedure on most devices that allows you to decline the use of cookies. To learn more about cookies, please visit http://www.allaboutcookies.org/. However, if you choose to decline cookies, then some or all of the features, functionality and promotions available through the Corporate Site may not be available to you.

    8. how to contact us

      If you have any questions about this Privacy Policy, please contact us by email at info@instabot.io, or write to the following address: Instabot, 1140 Broadway, Suite 501, New York, NY 10001.