See Privacy Policy effective before 2017-09-01.

Effective Date: 2017-09-01

1. Important introduction to our privacy policy

1A. What is a Privacy Policy?

This Privacy Policy explains how Ask.fm Europe Limited (“ASKfm,” “we”, “our”, or “us”) collects, uses, shares, and stores your information when you use the ASKfm website and/or the mobile applications that link to this Privacy Policy (“Services”).

1B. Why do I need to read and accept it?

When you use our Services, you are agreeing to our rules and policies, including this Privacy Policy and Terms of Use, and you consent to our collecting, processing and storing your information as described below. You must not access or use the Services if you do not agree with our Privacy Policy. You should also read our Terms of Use because they also apply to your use of the Services.

1C. What company owns ASKfm?

Ask.fm Europe Limited is an Irish limited liability company with registration number 551873 and a registered office at 6th Floor, South Bank House, Barrow Street, Dublin 4, Ireland.

1D. What privacy law applies to ASKfm?

The personal information you provide to us that is collected through our Services is controlled by ASKfm in accordance with the Irish Data Protection Acts of 1998 and 2003 as amended.

2. How do you collect my data?

How we collect, process and store information depends in part on how you use the Services. You may register to use the Services (“Registered User”). You can use some of the Services without creating an account (“Guest User”) or providing any information other than information that is automatically collected as explained below. The different categories of information we collect from you are described below.

3. What data do you collect about me?

We may collect information from you during your use of the Services, including your name, username, password, e-mail address, postal address, phone number, mobile phone number, payment information, gender, birth year, and other information you provide or post on our Services or allow us to access when you do certain things, such as:

• Sign up and complete our registration form;
• Create or edit your user profile;
• Login to the Services;
• Submit questions or answer questions;
• Contact our customer support team or use our reporting mechanisms;
• Enter a sweepstakes or contest or register for a promotion;
• Participate in voting or polling activities;
• Request certain features (e.g., newsletters, updates, or other products);
• Connect with the Services or otherwise allow us to access certain information about you via a social media service; or
• Post user-generated content to or on our Services.

4. What data do you collect about my friends?

You can choose to invite your friends to join ASKfm so that you can stay in touch with them on the Services. To allow you to use this feature, we will ask your permission to access your personal contact list, which we will only access to store for your own use, to assist you with inviting friends to join you on the Services and to notify you when someone you know joins the Services. To make it easier to search and find friends and people you know on ASKfm, users may search for other members using first and last name, e-mail address, and location.

5. Do you collect data about my computer/my phone?

We may automatically collect certain information about the computer or devices (including mobile devices) you use to access the Services, and about your use of the Services, even if you use the Services as a Guest User. We may collect information such as (a) IP addresses, unique device identifiers (e.g. IDFA or other device IDs on Apple devices like the iPhone, iPad and iPod Touch), and other information about your mobile phone or other mobile device(s) browser types, browser language, operating system, the state or country from which you accessed the Services; and (b) information related to the ways in which you interact with the Services, such as: referring and exit pages and URLs, platform type, the number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used the Services, error logs, and other similar information. As described further below, we may use third party analytics providers and technologies, including cookies and similar tools, to assist us in understanding how our Services are used. Such tools may collect and use your data, after we have depersonalized it, with other ASKfm users’ data.

6. Do you collect data about my location?

We may collect general information (e.g. IP address, zip code) about your location, and may use that information to customize the Services with location-based information, advertising, and features that need to know your location to work properly. By accessing and using the Services, you consent to this collection and processing of location information. If you choose to turn off location services on your device, some features may not be available to you.

7. I’ve heard about cookies, do you collect them too?

When you use the Services, we use persistent and session cookies and other similar technologies to: (a) store your username and password; (b) analyze the usage of our sites and Services by collecting the information discussed above; (c) customize the Services to your preferences; and (d) display advertising on the Services. We may also use other Internet technologies, such as web beacons or pixel tags and other similar technologies, to deliver or communicate with cookies and analyze your use of the Services. We also may include web beacons in e-mail messages or newsletters to determine whether the message has been opened and for other analytics. Most browsers automatically accept cookies, but you can modify your browser setting to decline cookies by visiting your browser’s help page. If you choose to decline cookies, please note that you may not be able to sign in, customize, or use some features of the Services. For more information about our use of cookies, please see our Cookie Policy. By using our Services with your browser set to accept cookies you are consenting to our use of cookies in the manner described above and in our Cookie Policy.

8. Do you collect data about me from anyone else?

We may collect, process and store:

• your user ID associated with any social media account (such as your Facebook account) that you use to sign in to the Services or connect with or use with the Services. When you sign in to your account or mobile application with your social media account information, or otherwise connect to your social media account with the Services, you consent to our collection, storage, and use, in accordance with this Privacy Policy, of the information that you choose to make available to us through the social media interface. This could include, without limitation, any information that you have made public in connection with your social media account, information that the social media service shares with us, or information that is disclosed as being shared during the sign-in process. Please see your social media provider’s privacy policy for more information about how they share information when you choose to connect your account.
• We may also obtain information about you if it is contained in user-generated content that other users post to or on our Services. For example, one of your friends could post something about you in a question they ask you, or in an answer they post.
• We may obtain additional information about you from affiliates and may combine that information with information which we collect from or about you and information derived from any other product or service we or our affiliates provide.

9. Do you anonymize my data so no-one knows its mine?

Sometimes we may anonymize and/or de-identify information collected through the Services or via other means, including via the use of third-party web analytic tools so that the information no longer relates to you. Where we have appropriately anonymized and/or de-identified information it no longer constitutes your personal information (also known as personal data). As a result, our use and disclosure of aggregated and/or de-identified information is not subject to this Privacy Policy and may be disclosed to others on such basis.

10. If I ask a question anonymously, do you still know who I am?

The fact that you can send messages without other people knowing who you are is part of what makes ASKfm unique and so much fun. It means that you can ask things that you might be too embarrassed or shy to say if anyone knew it was you. People may often be more honest when they are anonymous, whether they’re asking a question anonymously, or answering a question where they don’t know who has asked it. You have the ability to decide whether to ask a question anonymously or on a named basis each time you submit a question to another user. However, this also means that when you receive questions or comments, you may not know who they come from either! Remember, as a Registered User, that even if you ask a question anonymously, our Service will still have a record of the fact that you asked the question (even if we keep this private). If you are a Guest User, we may not know who you are.

11. Does that apply to me if I am a Registered User?

Remember, as a Registered User, that even if you ask a question anonymously, our Service will still have a record of the fact that you asked the question (even if we keep this private). If you are a Guest User, we may not know who you are.

12. How do I stop receiving annonymous questions?

Some people don’t like receiving things from people if they don’t know who they are. So we provide all users with the ability to choose not to receive questions from anonymous users on the “Settings” page on the website and mobile application.

If you do choose to allow anonymous questions, please know that our intention is that they will foster candid, open conversations. However, if someone does abuse the option of being anonymous through inappropriate communications that violate our Terms of Use because they know you don’t know who they are, you have the ability to report that user to us so that we may take appropriate action. We have also built-in site moderation techniques to protect you and to prevent users from transmitting harmful content. For more information, see our Terms of Use and our Safety and Security Essentials.

13. Can law enforcement get my data from you?

We may assist the police or other law enforcement agencies with their requests, or produce information in response to legal process where we, in good faith, believe that such disclosure is required by law, or to protect our rights and property, or the safety of individual users or the public, or where otherwise permitted by this Privacy Policy.

14. What do you use my information for?

We use the information we receive from and about you for the following purposes:

• To provide the Services including any special features;
• To process and respond to your inquiries;
• To send you information about your relationship or transactions with us;
• To contact you if you have filed a complaint or report, or if someone has made any claim or report against you;
• To make suggestions to you and other Registered Users, such as suggesting Registered Users’ profiles to follow;
• To notify you about new features of the Services, special events, or products, services, and special offers, or to send you questions of the day;
• To moderate content and to keep the Services safe and secure and address any security issues;
• To generate advertising and promotional materials for our Services;
• To understand and assess the effectiveness of advertisements on the Services;
• To process payment for virtual goods that may be available from time to time;
• To administer sweepstakes and contests;
• To generate and review reports and data about our user base and Service usage patterns;
• To analyze the accuracy, effectiveness, usability, or popularity of the Services;
• To improve the content and features of the Services;
• To allow us to personalize the content and advertising that you see on the Services;
• To safeguard ASKfm’s and others’ rights or property;
• To investigate, prevent, or take action regarding illegal activities, involving potential threats to the physical safety of a person, prevention of fraud, and violations of our Terms of Use; and
• To administer and troubleshoot the Services.

15. Does ASKfm share my information with other users?

15A. Sharing your profile information

If you are a Registered User, anyone who uses the Services is able to see your username and any information posted on your profile, including photos. Any questions that you receive in your inbox cannot be seen by anyone else until you reply to them. If you do reply, then the question and your answer will be posted on your profile, where they can be seen by anyone who uses the Services and views your profile. While you have the ability to delete posted questions and answers on your profile at any time by clicking the “x” next to the question/answer, you should be careful to only include information in your profile, including in any questions and answers, that you would not mind making public. If a Registered User “likes” a question or answer on your profile, the fact that the Registered User “liked” the content will be automatically visible.

15B. Does my profile show up in search engine results?

Your profile information will also be searchable via public search engines (e.g., Google, Bing, Yahoo).

15C. Can other people see my location?

Your location data is used for some user features like Shoutouts, to target your questions to people within a geographic range, but we do not disclose your exact location to any other user.

15D. How can I protect myself?

In general, please be careful and responsible whenever you are online. Should you choose to voluntarily disclose information through the Services, such as by submitting a question to another user or by answering a question to be posted on your profile, that information can be viewed publicly and people can copy content that is posted on the Internet. It could also be collected and used by third parties without our or your knowledge, which may result in unsolicited messages from other individuals or third parties. You should not share personal information that might allow others to contact or locate you or other users, and you should think before you post.

16. Does ASKfm share my information with third parties?

16A. When and why we share your information with third parties

We don’t sell or share any personal information about you with third parties, except as provided in this Privacy Policy. We may share your information in the following circumstances:

• To assist in providing the Services;
• To provide you with services or products that you have requested;
• With companies that perform services on our behalf (including both third parties and our affiliates), such as advertising providers, advertising networks/advertising exchanges, payment processors, providers of technical infrastructure (such as servers) or engineering or other support, order fulfillment companies, moderation companies, technical services and features developers, research and analytical companies, and e-mail service providers;
• With our affiliates for the collective benefit of our affiliates’ businesses and for operational purposes;
• When we believe in good faith that such sharing is permitted by law or is reasonably necessary in order to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of this Privacy Policy or the Terms of Use;
• In order to respond to the claims of violation of the rights of third parties and/or to protect the rights, property, and safety of ASKfm, our employees, Registered and Guest Users, or the public. This may involve the sharing of your information with law enforcement, government agencies, courts, and/or other organizations;
• As we continue to develop our business, we may sell, buy, merge or partner with other companies or businesses, or sell some or all of our assets. In such transactions, user information may be among the transferred assets;
• We may share your information in any other circumstances where we have your consent or are otherwise permitted to share it by law.

16B. Do you use any other companies to help ASKfm provide the services to me?

For some elements of the Service we get technical assistance from other companies, and we may need to share your information with them so that we can provide those Services to you.

We might use third parties to provide technical functionality for some of the Features of the Services (like stickers and multimedia posts). We call those Feature Tools. If you choose to use the Feature Tools, we may collect and store non-personally identifiable anonymous statistical data if you use that feature tool, where such tool is operated by a third party. We do not co-operate with Feature Tool providers that sell or otherwise transfer any of your data to third parties without your consent. You should review the privacy policies of the Feature Tools and to enable you to do that we provide a list here of the Feature Tool Providers we currently work with.

Feature Tool Providers List: Kanvas Labs Inc, which has its privacy policy available to view at https://www.getkanvas.com/privacy

16C. Do you use my questions and answers for research?

We or third parties we use may analyze your questions and answers for research purposes. When we use a third party to do this, we do not share any personal information with that party, we only provide anonymized questions and answer content and other non-personalised statistical data for analysis purposes.

16D. Tell me more about sharing my anonymous data for advertising purposes?

In addition to helping us to measure the usage of our app so we can better understand our audience and improve our service, such anonymous information is provided to third parties for their business purposes, including the creation of reports, market research, and trend analysis. This information does not contain information from which users can be identified and we will not provide additional information to such third parties that enable such third parties to identify you. Notwithstanding any other provision, we may also engage a third party partner for the purpose of identifying users and delivering to them interest-based content and advertisements. We may share information about you with our partners such as your name, postal address, e-mail, or other identifier and may do so in non-human readable format to ensure the security of your information. Our partners also may collect information directly from your device, such as your IP address, device ID, information about your browser or operating system, and depending on your device settings, your geographic location data, including GPS coordinates (e.g. latitude and/or longitude) or similar information regarding the location of your mobile device; may combine our personal and non-personal information about you with information from other sources; and may place or recognize a unique cookie on your browser. To opt out of third party cookies, please go to http://www.aboutads.info/choices. To opt out of the use of your mobile device ID for targeted advertising, please see http://www.aboutads.info/appchoices.

Our current Partner List, that means companies we have agreed to share anonymous data with for the above purposes, includes the following companies:

Huq Industries Limited, Cross Pixel Media Inc, Factual, adsquare GmBH (review their privacy policy at http://www.adsquare.com/privacy/), BeaconsInSpace Inc, CrossChannel Inc, Eyeota, Crosswise, AreaMetrics, Airpush, Inc., LiveRamp, Inc. and Verve Wireless, Inc.

17. What are online analytics?

To help us better understand your use of the Services, we may use third-party web analytics on our Services, such as Google Analytics or Flurry. These service providers use the sort of technology that we’ve explained above for data that is automatically collected about your device, for example. The information collected by this technology will be disclosed to or collected directly by these service providers, who use the information to evaluate ASKfm users’ use of the Services. We also use Google Analytics as described more below. To prevent Google Analytics from collecting or using your information, you may install the Google Analytics Opt-Out Browser Add-on; to opt-out of Flurry collecting or using your information, go to Google Analytics Opt-Out Browser Add-on.

18. What is tailored advertising?

Third parties whose products or services are accessible or advertised via the Services may also use cookies or similar technologies to collect information about your use of the Services. This is done in order to help them (i) inform, optimize, and serve ads based on past visits to our website and other sites and (ii) report how our ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to our website. We also allow other third parties (e.g., ad networks/ad exchanges and ad servers such as Google Analytics, DoubleClick and others) to serve tailored ads to you on the Services, and to access their own cookies or similar technologies on your computer, mobile phone, or other device you use to access the Services. We neither have access to, nor does this Privacy Policy govern, the use of cookies or other tracking technologies that may be placed on your computer, mobile phone, or other device you use to access the Services by non-affiliates, third-party ad technology, ad servers, ad networks, ad exchanges, or any other non-affiliates third parties. Those parties that use these technologies may permit you to opt out of ad targeting as described below. You may receive tailored advertising on your computer through a web browser. If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your computer to deliver tailored advertising (i.e., not just for the Services), you may visit the Network Advertising Initiative’s Consumer Opt-Out Link, European Interactive Digital Advertising Alliance, “Your Online Choices” page and/or the Digital Advertising Alliance’s Consumer Opt-Out Link to opt-out of receiving tailored advertising from companies that participate in those programs. To opt out of Google Analytics for Display Advertising or customize Google Display Network ads, you can visit the Google Ads Settings page. Please note that to the extent advertising technology is integrated into the Services, you may still receive advertisements even if you opt-out of tailored advertising. In that case, the ads will just not be tailored to your interests. Also, we do not control any of the above opt-out links and are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.

When accessing the Services from a mobile application you may also receive tailored in-application advertisements. Each operating system: iOS, Android and Windows Phone provides its own instructions on how to prevent the delivery of tailored in-application advertisements. You may review the support materials and/or the privacy settings for the respective operating systems in order to opt out of tailored in-application advertisements. For any other devices and/or operating systems, please visit the privacy settings for the applicable device or operating system or contact the applicable platform operator.

19. Important notice about our do not track disclosure

We are committed to providing you with meaningful choices about the information collected on our Services for third party purposes, and that is why we provide the above links to the NAI “Consumer Opt-out”, DAA opt-out, and Google opt-out. However, we do not currently recognize or respond to browser-initiated Do Not Track signals, as the Internet industry is still working on Do Not Track standards, implementations and solutions.

20. How can I update my privacy choices?

You have a variety of choices regarding the collection, use, and sharing of your personal information through the Services, including the ability to prevent other users from submitting questions to you.

• The “Privacy” tab of the Settings page allows you to: (1) switch off receiving anonymous questions; and (2) hide your answers from appearing in the “Stream”.
• You can opt out of receiving certain e-mail notifications from us, including e-mails advertising ASKfm products and services, by clicking the “Notifications” tab of the Settings page on the mobile app and through the “Privacy” tab of the Settings page on the site.

21. How can I block other users?

You have the ability to add any user to your “blocklist” at any time by clicking on the “block” button on that user’s profile. This will prevent the user from asking you a question.

22. How does ASKfm protect my information?

We have put in place appropriate physical, electronic, and managerial procedures to safeguard and help prevent unauthorized access to your information and to maintain data security. These safeguards take into account the sensitivity of the information that we collect, process and store and the current state of technology. Although we take appropriate measures to safeguard against unauthorized disclosures of information, the Internet and the Services are not 100% secure so we cannot assure you that personal information we collect or store will never be disclosed in a manner that is inconsistent with this Privacy Policy. We strongly urge you to take steps to keep your personal information safe (including your password) and to log out of your account after use. You should not tell anyone (other than your parents or guardian, if you are a minor) your password. If you lose your password or give it out to someone, your personal information will be at risk. If that happens, you should report it to us immediately by clicking here. You must also change your password immediately via your “Settings” page. We are not responsible for your failure to keep your password secure, and failure to do so may breach our Terms of Use. We also strongly recommend that you change your password from time to time.

23. I want to deactivate my profile or leave ASKfm

You also have the right (in certain cases) to modify or delete the personal information we hold about you. You can generally exercise these rights by following the process described in the “De-activating Your Profile” and “Leaving ASKfm” sections of this Privacy Policy. However, you can also contact us using the details in Section 28 below, if you wish to modify information that cannot be amended or deleted through the Service.

23A. De-activating Your Profile

You can deactivate your profile by signing in to the Services with your password and opting to deactivate your profile. This option is available from your Settings page. By deactivating your account, it will no longer be visible to other users of the Services. Your profile information will be retained in case you later decide to restore your account. Many members deactivate their accounts for temporary reasons and in doing so expect us to maintain their information until they return to ASKfm. You should ordinarily be able to restore your account and the whole of your profile within 12 months of deactivating it, but we cannot guarantee that this will always be the case.

23B. Leaving ASKfm

Should you choose to leave ASKfm, you may do so by selecting the “I want to leave ASKfm” tab on the Contact Us page. Once received, we will process your request to leave as soon as practicable. Once processed, your profile data will be removed from the Services and your questions to friends will be converted to anonymous questions (in other words, questions you have asked will remain visible but will appear to be from an anonymous user). You will be able to reactivate your account by logging back in for a period of 30 days after your request to leave ASKfm is processed. At the end of that period, your account will be deleted and all “likes” which you have added to questions will be removed. We will delete your data as soon as reasonably practicable, but in certain cases limited types of data, including log files and backups, may take up to 90 days to be fully deleted. In order to enforce our Terms of Use and to prevent abuse of the Services, we may retain basic account information reasonably necessary to ensure a former user whose account has been terminated for breach of the Terms of Use does not open a new account and profile in further breach of our Terms of Use. We may also retain additional information where we reasonably believe that we are legally obligated to do so (such as where such information may be relevant for a law enforcement investigation). Warning: After you have deactivated your account or left ASKfm, questions you have previously transmitted through the Services may still appear on the Services, but will be anonymized and no longer associated with you directly (in other words, a question you asked on your friend’s profile will still be visible, but will not include your username). Please also note that even after you remove information from your profile or deactivate your account, copies of such content may still be visible and/or accessed on the Internet to the extent such information has been previously shared with others, or to the extent such information has been shared with, indexed by or cached by search engines. Similarly, if you have given third party applications or websites (e.g. other social networks) access to your personal information, they may keep that information. We cannot control this, nor do we accept any responsibility or liability for this.

24. Are my privacy rights different depending on where I live?

24A. Your rights, if you live in Europe

Because you control your profile, you can see the personal information you’ve provided to us by accessing your “Profile” page, which gives you the option to correct or update your information at any time by just logging into the Services. Once you register, you will be able to change most of your personal information, including: your name; your country; your contact e-mail address; your profile picture; and your password. You will not be able to change your birth date. You will also have the option to delete questions and answers posted to your profile at any time. You have a right to request a copy of the information we hold about you. Such a request must be in writing. You can do this via our contact form: Feedback. We will contact you to let you know what else we need from you before we send you a copy of your personal information. We reserve the right to charge the statutory fee (currently €6.35) to process such a request.

24B. Your rights, if you live in California, USA

California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties. If you are a California resident and would like to request this information, please submit your request by clicking here.

24C. My rights, if I live elsewhere

While the Service is provided from Ireland, it is a global website that operates and provides Services in various countries around the world. By giving us any personal information or by using the applications available on the Services, you agree that your personal information may be transferred to and stored and processed in our and our third-party vendors’ facilities in various countries around the globe, including the United States. These countries may have privacy laws that differ from the laws in your country or the laws of Ireland.

25. What are your rules on children’s data?

The Services are not intended for use by children under the age of 13. We do not knowingly collect (or knowingly allow any third party to collect) personal information from persons under the age of 13. If we become aware that personal information has been collected from a person under the age of 13, we will delete this information and terminate the person’s account as quickly as possible. If you believe that we may have personal information from or about a child under the age of 13, please contact us using the contact information below.

26. What about third party links and services?

The Services may contain links to third-party websites, including other social media services. Your use of these features may result in the collection, processing or sharing of information about you by a third party, depending on the feature. Please be aware that we are not responsible for the content or privacy practices of other websites or services which may be linked to the Services. We do not endorse or make any representations about third-party websites or services. The personal information you choose to provide to or that is collected by these third parties is not covered by our Privacy Policy. We strongly encourage you to read such third parties’ privacy statements.

27. Can ASKfm make changes to this privacy policy?

We reserve the right to make changes to this Privacy Policy at any time to reflect changes in the law, our data collection and use practices, the features of our Services, or advances in technology. Please check this page periodically for changes. If we make any material changes to this Privacy Policy, we will post the updated Privacy Policy here and notify our Registered Users by e-mail or by means of a notice on the Services. Save for urgent changes (such as those required by law) we will post such a notice on our website prior to the changes becoming effective. Please review the changes carefully. Your continued use of the Services following the posting of changes to this policy will mean you consent to and accept those changes. If you do not consent to such changes, you can delete your account by following the process described in the “De-activating Your Profile” and “Leaving ASKfm” sections of this Privacy Policy.

28. How do I contact you, if I have a question about this policy?

If you have any questions about this Privacy Policy, you can contact us by clicking here or by writing us at the following address:

Ask.fm Europe Limited
6th Floor, South Bank House, Barrow Street,
Dublin 4, Ireland