Sangha App Privacy Policy

Effective as of April 15, 2022

This privacy policy (the “Privacy Policy”) applies to the Sangha Social mobile application (the “App”), owned and operated by Fractal Think Inc. dba Sangha Social App (“Sangha,” “we,” “us,” or “our”), an Illinois corporation. We have created this Privacy Policy to tell you what information the App collects, how we use that information, and who we will share that information with, if at all. This Privacy Policy does not address the privacy practices of any third parties that we do not own, control, or are affiliated with. Capitalized terms not defined in this Privacy Policy will have the meaning set forth in our Terms of Use. By visiting and/or using our App, and the services provided through the App (the “Services”), you are agreeing to the terms of this Privacy Policy and the accompanying Terms of Use. We encourage you to read the Privacy Policy, and to use the information it contains to help you make informed decisions.

1. Information We Collect or Receive. In the course of operating the App, we will collect and/or receive the following types of information. You authorize us to collect and/or receive such information.

(a) Personal Information. In order to provide you with the Services, we may collect information that identifies you personally. When you sign up to become a user and open an account, you will be required to provide us with personal information about yourself (collectively, the “Personal Information”). Such Personal Information may include your e-mail address, country and time zone of residence. When you use the App or engage us for dispute resolution, we may collect that information and more, including, but not limited to, information about anu messages sent or received. We do not collect any Personal Information from you unless you provide us with the Personal Information voluntarily.

(b) Third-Party Log In. If you sign in through Google Sign-in, you are authorizing us to collect, store, and use, in accordance with this Privacy Policy, any and all information that you agreed that Google Sign-in would provide to us through its Application Programming Interface (“API”). Such information may include, without limitation, your first and last name, unique identifier and access token, and e-mail address. Such will be collected and processed by our Google pursuant to the terms and conditions of its privacy policies and terms of use. For more information, see https://policies.google.com/privacy.

(c) Geolocational Information. Certain features and functionalities of the App are based on your location. In order to provide these features and functionalities while you are using your mobile device, we may, with your consent, automatically collect geolocational information from your mobile device or wireless carrier and/or certain third-party service providers (collectively, “Geolocational Information”). Collection of such Geolocational Information occurs only when the App is running on your device. You may decline to allow us to collect such Geolocational Information, in which case we will not be able to provide certain features or functionalities to you.

(d) Third-Party Analytics. We and the third-party technology providers, ad exchanges, ad networks, advertisers, agencies, ad exchanges, and ad servers with which we work use third-party analytics services (e.g., Google Analytics for Firebase) to evaluate your use of the App, compile reports on activity, collect demographic data, analyze performance metrics, and collect and evaluate other information relating to the App and mobile and Internet usage. These third parties use cookies and other technologies to help analyze and provide us the data. You consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy. For more information, please visit https://policies.google.com/privacy?hl=en-US. Please be advised that if you opt out of any such service, you may not be able to use the full functionality of the App.

(e) Other Information. In addition to the Personal Information, Payment Information, and Geolocational Information, we may automatically collect or receive additional information regarding you and your use of the App; your interactions with us and our advertising; and information regarding your computer and mobile devices used to access the App (collectively, the “Other Information”). Such Other Information may include:

(i) From You. Additional information about yourself that you voluntarily provide to us, such as information about your use of the Services and any disputes with other users.

(ii) From Your Activity. We may collect or receive information regarding:

(A) IP address, which may consist of a static or dynamic IP address and will sometimes point to a specific identifiable mobile device;

(B) date and time; and

(iii) About Your Mobile Device. We may collect or receive information regarding:

(D) type of mobile device;

(E) mobile device identifier;

(F) operating system and version (e.g., iOS, Android or Windows);

(G) carrier; and

(H) network type (WiFi, 4G LTE, 5G).

2. How Information Is Used and Shared.

(a) You authorize us to use the Personal Information, Payment Information, Geolocational Information, and the Other Information (collectively, the “Information”) to:

(i) provide and improve our App;

(ii) provide our services;

(iii) administer our promotional programs;

(iv) solicit your feedback; and

(v) inform you about our products and services.

(b) In order to provide our services and administer our promotional programs, we may share the Information with our third-party promotional and marketing partners, including, without limitation, businesses participating in our various programs.

(c) We engage third-party companies and individuals to perform functions on our behalf. Examples may include providing technical assistance, customer service, marketing assistance, and administration of promotional programs. These other companies will have access to the Information only as necessary to perform their functions and to the extent permitted by law

(d) In an ongoing effort to better understand our users, the App, and our products and services, we may analyze certain Information in anonymized and aggregate form to operate, maintain, manage, and improve the App and/or such products and services. This aggregate information does not identify you personally. We may share and/or license this aggregate data to our affiliates, agents, business and promotional partners, and other third parties. We may also disclose aggregated user statistics to describe the App and these products and services to current and prospective business partners and investors and to other third parties for other lawful purposes.

(e) We may share some or all of your Information with any of our parent companies, subsidiaries, joint ventures, or other companies under common control with us.

(f) As we develop our businesses, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, the Information may be part of the transferred assets.

(g) To the extent permitted by law, we may also disclose the Information:

(i) when required by law, court order, or other government or law enforcement authority or regulatory agency; or

(ii) whenever we believe that disclosing such Information is necessary or advisable, for example, to protect the rights, property, or safety of us or others, including you.

(h) We will use your Payment Information to process your authorized payments facilitated through the App. We will share your Payment Information with a third-party service provider as necessary to process your payment. The third-party service provider stores your Payment Information; we do not store this information. Storage by the third-party service provider of your Payment Information is subject to the privacy policies and practices of the third-party service provider and is not subject to the terms of this Privacy Policy. By providing your Payment Information, you acknowledge and agree to use of such information by the third-party service provider for purposes of processing your payment to us.

(i) We will not sell your Information for any purpose.

3. Accessing and Modifying Information and Communication Preferences. If you have provided us any Personal Information, you may access, remove, review, and/or make changes to the same by contacting us as set forth below. In addition, you may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of any of our marketing e-mails. We will use commercially reasonable efforts to process such requests in a timely manner. You should be aware, however, that it is not always possible to completely remove or modify information in our subscription databases. You cannot opt out of receiving transactional e-mails related to the App (e.g., requests for support).

We may also deliver notifications to your mobile device (e.g., push notifications). You can disable these notifications by deleting the relevant service or by changing the settings on your mobile device.

4. How We Protect Your Information. We take commercially reasonable steps to protect the Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases or the databases of the third parties with which we may share such Information, nor can we guarantee that the Information you supply will not be intercepted while being transmitted over the Internet. In particular, e-mail sent to us may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.

5. App Stores; External Websites. Your app store (e.g., iTunes or Google Play) may collect certain information in connection with your use of the App, such as Personal Information, Payment Information, Geolocational Information, and other usage-based data. We have no control over the collection of such information by a third-party app store, and any such collection or use will be subject to that third party’s applicable privacy policies.

6. Children. The App is not directed to children under the age of 13. We adhere to the Children’s Online Privacy Protection Act (COPPA) and will not knowingly collect Personal Information from any child under the age of 13. We ask that minors (under the age of 13) not use the App. If a child under the age of 13 has provided us with Personal Information, a parent or guardian of that child may contact us and request that such information be deleted from our records.

7. California Privacy Rights. If you are a resident of the State of California, under the California Consumer Privacy Act (CCPA), you have the right to request information on how to exercise your disclosure choice options from companies conducting business in California. Specifically:

Exercising the right to know. You may request, up to twice in a 12-month period, the following information about the personal information we have collected about you during the past 12 months:

the categories and specific pieces of personal information we have collected about you;
the categories of sources from which we collected the personal information;
the business or commercial purpose for which we collected the personal information;
the categories of third parties with whom we shared the personal information; and
the categories of personal information about you that we disclosed for a business purpose, and the categories of third parties to whom we disclosed that information for a business purpose.

Exercising the right to delete. You may request that we delete the personal information we have collected from you, subject to certain limitations under applicable law.

Exercising the right to opt-out from a sale. You may request to opt out of any “sale” of your personal information that may take place.

Non-discrimination. The CCPA provides that you may not be discriminated against for exercising these rights.

To submit a request to exercise any of the rights described above, you may contact Sangha App either via email to privacy@sangha.com or contact us via postal mail, proper postage prepaid, at:

Sangha App,

Attn: Your California Privacy Rights

Northwest Registered Agent

2501 Chatham R. Ste. N

Springfield, IL 62704

Please indicate your preference as to how you would like us to respond to your request (i.e., email or postal mail).

All requests sent via postal mail must be labeled “Your California Privacy Rights” on the envelope or postcard and clearly stated on the actual request. For all requests, please include your name, street address (if you would like a response via postal mail), city, state, and zip code. We may need to verify your identity before responding to your request, such as verifying that the email address or contact information from which you send the request matches your email address or contact information that we have on file. Authentication based on a government-issued and valid identification document may be required. We will not accept requests via telephone or fax. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.

8. Changes to This Privacy Policy. This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time. Any such changes will be posted on the App. By accessing the App after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please be aware that, to the extent permitted by applicable law, our use of the Information is governed by the Privacy Policy in effect at the time we collect the Information. Please refer back to this Privacy Policy on a regular basis.

9. How to Contact Us. If you have questions about this Privacy Policy, please e-mail us at privacy@sangha.com with “Privacy Policy” in the subject line or mail us at the following address:

Sangha App,

Attn: Your California Privacy Rights

Northwest Registered Agent

2501 Chatham R. Ste. N

Springfield, IL 62704