Mobile Privacy Policy

jet-esrb-prvacy-certified-2u (1)

JET NETWORKS, INC.
MOBILE PRIVACY POLICY

Last Updated: March 22, 2016

Our Privacy Commitment
Jet Networks, Inc. (“Jet” or “we”) has developed its apps with the goal of creating a safe and enjoyable experience for users of all ages, including children. We respect the privacy rights of users of our mobile applications (“mobile apps” or “apps”) and recognize the importance of protecting all information that our users may choose to share with us. To further this commitment, we have adopted this mobile privacy policy (“Mobile Privacy Policy” or “MPP”) to guide how we collect, use, and disclose the information you provide us through our apps.

Jet is a new social app that lets users share texts, photos, stickers, moods, and videos. Jet is open to everyone, including those who are under the age of 13 (“Child” or “Children”). Jet Parent is a separate app that syncs with Jet, connecting a parent to the account of a Child. This proprietary two-app system gives kids the independence they want and parents the control they need. We encourage you to review this Mobile Privacy Policy carefully to understand our privacy practices surrounding both apps.

This Mobile Privacy Policy and the ESRB certification seal shown in our MPP confirm that Jet is a valid licensee, and participating member, of the Entertainment Software Rating Board’s Privacy Certified Program. To protect your privacy, we have voluntarily undertaken this privacy initiative. All of our mobile apps displaying this MPP have been reviewed and certified by ESRB Privacy Certified to meet established online information collection and use practices. As a licensee of this privacy program, we are subject to frequent audits of our apps and other enforcement and accountability mechanisms administered independently by the ESRB.

By using and submitting personal information to any of our apps, you signify your consent to this Mobile Privacy Policy. If you do not agree to this MPP, please do not use our apps.

 

Table of Contents

  1. What this Mobile Privacy Policy covers
  2. Information collected, used, and disclosed
  3. Children’s privacy
  4. Tracking technologies used to collect information
  5. Your California privacy rights
  6. Security measures we take to safeguard your personally identifiable information
  7. Review, update, or delete your (or your Child’s) personal information
  8. Ask questions or send us comments about this Mobile Privacy Policy
  9. Changes to this Mobile Privacy Policy

 

  1. What this Mobile Privacy Policy covers

This Mobile Privacy Policy applies only to information collected on the mobile apps where this MPP is posted, and does not apply to any other information collected by Jet through any other means. This MPP does not apply to Jet’s website. This MPP applies only to apps maintained by Jet, and not to any apps or websites maintained by other companies or organizations to which we link. We encourage you to review the privacy policies of all third-parties and exercise caution in connection with them.

This MPP applies to use and sharing of personal information collected on and after the date that this MPP is posted. The terms of this MPP are subject to all applicable laws.

  1. Information collected, used, and disclosed

Personal information is information that can be used to directly identify and contact you (e.g. first and last name, email address, phone number, etc.). All of the personal information we receive comes directly from our guests. Whatever the purpose may be, we will only collect information to the extent reasonably necessary to fulfill your requests and our legitimate business objectives. We will only retain personal information about you for the period necessary to fulfill the purposes outlined in this Mobile Privacy Policy, unless a longer retention period is required by law and/or regulations.

Information required for registration

If you are registering an account on either of our apps, we require the following pieces of personal information from all users (including Children):

  • First and last name
    1. Purpose: To identify you to users to whom you send friend requests
    2. Disclosed to: Users to whom you send a friend request will see your real name if they are 13 or older OR if they are a Child and their parent has not denied the submission of your friend request. Parents of Child users will be able to see your real name if they have opted to review all friend requests sent to their Child for pre-approval. Real names are never made public, and are never displayed to the friends of your friends.
  • Unique username and password of your choice
    1. Purpose: To personalize, log into, and secure your account
    2. Disclosed to: Like your real name, your username is not made public. Your username is only visible to those with whom you are friends, and, in some instances, the friends of your friends. Users to whom you send a friend request will see your username if they are 13 or older OR if they are a Child and their parent has not denied the submission of your friend request. Parents of Child users will be able to see your username, as they are also classified as the Child’s friend and have access to their Child’s list of friends. If you comment on your friends’ posts, please note that the friends of your friends will be able to see your username. Your username is only searchable by other Jet users if that user has your exact username, as we do not allow partial username searches. For example, the username “queen15” would not be returned in a username search for the word “queen.” Your password is never disclosed to anyone, and you should never share it with anyone else.
  • Email address (only collected and stored from users 13+ on Jet and users who are 18+ on Jet Parent)
    1. Purpose: To contact you regarding your account (registration confirmation, password reset, etc.)
    2. Disclosed to: Your email address is not made public and not sold to any third parties for their direct marketing purposes. Additionally, your friends and friends of your friends will not be able to view your email address.
  • Parent’s email address (only collected from Children on Jet)
    1. Purpose: To notify a parent of a Child’s registration and obtain parental consent for registration completion, as well as to contact a parent about their Child’s account (registration confirmation, password reset, etc.)
    2. Disclosed to: Your email address is not made public and not sold to any third parties for their direct marketing purposes. Additionally, your friends and friends of your friends will not be able to view your email address.

Please note that the parent of a Child sending a friend request will see the request recipient’s username, gender (as provided), and age. The parent of a Child who receives a friend request will see the request sender’s first and last name, username, profile picture, and age if the sender is also under 13.

Once registered, you have the option of uploading photos and/or videos to your account. You also have the option of sending and receiving private messages to and from your friends on Jet, as well as inviting others to join Jet. More details are explained in the sub-section regarding “Uploading and sharing posts, photos, and videos” below.

Additionally, we will collect your device ID for the support of internal operations or to send you external push notifications about your account. You will not receive external push notifications unless you affirmatively opt-in or give us your explicit consent to allow this feature. Users under the age of 13 will not receive external push notifications unless a parent affirmatively opts in for their Child to receive them via Jet Parent. You may opt-out of having your Child receive push notifications at any time by accessing preferences on Jet Parent. All users can elect to turn off push notifications at any time through their device settings.

If you are registering an account to use the Jet Parent app (for users 18 and older), you will be required to provide payment information in addition to the personal information previously specified above. Although we do not currently offer any in-app purchases, please note that Jet Parent is a fee-based app which can be purchased at the mobile app storefront. The third-party storefront provider (e.g., Apple) collects your payment information on our behalf, so we encourage you to also review their privacy policy.

Uploading and sharing posts, photos, and videos
All users have the option of uploading photos and/or videos from their phone to be (1) displayed as their profile picture, (2) posted in their live activity stream, and (3) sent privately to friends on Jet. Profile pictures can be seen by your friends, friends of your friends (if you comment on a friend’s activity stream post), as well as parents of Children to whom you send friend requests (if that parent has opted to review all of their Child’s incoming friend requests). Pictures that you post in your live activity stream can only be seen by your friends. Please note, if you are a parent providing consent for your Child to use Jet, you are allowing him or her to upload photos and videos as a part of the app’s core functionality. If you decide not to approve, or do not respond to the notification email we send you, your Child will not be able to use Jet and all personal information (including your email address) will be deleted after 14 days.

Adding and removing friends
You should only send friend requests to other Jet users whom you know and trust. By adding a Jet user as a friend, keep in mind that you are allowing him or her to view your first and last name as well as any posts, photos, and videos that you may share in your live activity stream. If you decide that you no longer wish to be friends with someone, you may “un-friend” them by accessing your list of friends and swiping left over the specific Jet user you wish to remove from your list. Once you un-friend a Jet user, they will no longer be able to view any content that you share in your live activity stream or message you on Jet. Children may not remove their parent as friends.

 

Removing previously posted content
Again, posts, photos, and videos that you may share in your live activity stream are viewable by Jet users that you have chosen to add as your friends on Jet. If you would like to remove a post that you have previously created, you may do so by accessing the individual post when logged into your Jet account. If you wish to delete all activity associated with your account, you should access your account settings and choose “DELETE ACCOUNT”. Once you delete your account, we will not be able to recover it for you. If you decide that you want to use Jet again after having deleted your account, you will have to create a new one.

Please note that removal of this content or information does not guarantee complete or comprehensive removal. After your removal request has been honored, we may retain copies of the content or information you have previously posted on our servers. We are not required to remove your posted content or information if it has been rendered anonymous or if we are required by law to retain it. Additionally, we do not have control over other users who may have copied or reposted this information.

Demographic information collected
We collect demographic information such as gender, date of birth, and zip code, which is anonymous information that cannot be used alone to directly identify and contact you. If demographic information is collected at the same time as your personal information, we combine the demographic information with your personal information. Demographic information is not considered personal information unless it is linked to personal information about a specific user. If you choose not to provide certain demographic information, you will not be able to successfully register an account.

 

Disclosures to help protect the security and safety of our apps
We do not sell or rent personal information to third parties. We share personal information with third-party service providers who help us perform various internal functions necessary to operate our business. We disclose personal information (a) in the good faith belief that we are required to do so by law; (b) if doing so is reasonably necessary to comply with legal process; (c) to respond to any claims; (d) to enforce the terms and conditions of our apps; (e) to protect the rights, property, or personal safety of Jet, its users, or the public; or (f) in the event of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets, or stock. Any vendors or partners with whom we share personal information are permitted to obtain only the personal information they need to deliver the services requested. They are required to maintain the confidentiality of the information and are prohibited from using it for any other purpose.

 

  1. Children’s privacy

In order to accept users under the age of 13, Jet must comply with the Children’s Online Privacy Protection Act (COPPA), a federal law designed to protect Children online. Under COPPA, Jet is required to obtain parental consent before providing a Child access to the Jet app.

If you have not done so already, please review the section of our Privacy Policy covering “Information collected, used, and disclosed” to learn what information we collect from your Child, as well as how we use it and how it is disclosed. Without parental consent, provided through the purchase of Jet Parent, a Child is unable to use Jet. If we have not received parental consent within 14 days of receipt of the initial parental notification email, all personal information collected from the Child, including a parent’s email address, will be deleted.

It is important to note that, as aforementioned, you are allowing your Child to upload photos and videos to the Jet app as a part of the app’s core functionality if you approve him or her to use Jet. If you decide that you no longer wish to allow your Child to have this capability anytime after you have already provided consent, you must adjust device settings or delete your Child’s account. You may delete your Child’s account by logging into your Child’s account and choosing “DELETE ACCOUNT” within the settings menu. If you choose to delete your own account, note that your Child’s Jet account will not automatically be deleted. Alternatively, you may contact us using the information provided at the end of this section.

After you have approved your Child to use Jet by purchasing the Jet Parent app, creating a Jet Parent account, and activating your Child’s account via a special code we send to you in your parental notification email, you will be provided with the opportunity to directly manage certain preferences related to your Child’s account. These preferences include:

  • Approving all friend requests your Child sends and receives
    1. If your Child sends a friend request to another Jet user, that user will not be able to see the friend request until you have approved it. If you approve it, the user will be able to decide whether or not he or she would like to accept or deny your Child’s friend request. If you deny it, your Child’s friend request is never sent to the Jet user.
    2. If your Child receives a Jet request from another Jet user, your Child will not be able to see the friend request until you have approved it. If you approve it, your Child will be able to decide whether or not he or she would like to accept or deny the Jet user’s friend request. If you deny it, the Jet user’s friend request is never sent to your Child.
  • Being notified when your Child has a new friend request
    1. This preference will allow Jet to send you a notification whenever your Child receives a new friend request, regardless of whether or not you choose to approve the friend requests that are sent to your Child.
  • Being notified of when your Child logs into Jet
    1. This preference will allow Jet to send you a notification whenever your Child logs into Jet.
  • Allowing your Child to receive push notifications
    1. This preference will allow your Child to receive push notifications, outside of the app, about app-related activity such as new messages or friend requests.

The username and password that parents create on the Jet Parent app can be used interchangeably with the Jet app as well. As a parent on Jet, you will automatically be listed as one of your Child’s friends and your Child will not be able to remove you as a friend. As a friend, you will be able to see your Child’s activity, including posts that your Child shares via the Stream (you will not have access to messages shared privately with individual friends).

We take Children’s privacy seriously, and encourage parents to take an active role in protecting their Children’s privacy and online experience at all times. If you have questions, concerns, requests, or wish to send us comments about either your Child’s privacy or this Privacy Policy, please contact us at:

Jet Networks, Inc.
Attn: Privacy Policy Administrator
675 VFW Parkway, Suite 110
Chestnut Hill, MA 02467
privacy@jet.me

 

  1. Tracking technologies used to collect information

We use tracking technologies that are useful in order to assess the performance of our apps, including as part of our analytic practices, to send push notifications, or to otherwise improve the content and services on our apps. We use Localytics and Apple as third-party providers to assist us in collecting and analyzing usage behavior on our apps. For this purpose only, these providers may collect the following pieces of information: (1) device ID, (2) device state information, (3) device type, and (4) operating system information. Apple may also collect device location depending on your device settings.

If you wish to contact Localytics with any questions you have about their privacy practices, you may email them at privacy@localytics.com. In order to learn more about App Analytics provided by Apple, please visit the privacy settings on your device.

  1. Your California Privacy Rights

Since 2005, California Civil Code Section 1798.83 permits users of who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. However, as previously stated, we do not share information with third parties for their direct marketing purposes, unless you affirmatively agree to such disclosure. For inquiries regarding our disclosure policy, please send us an email or write us:

Jet Networks, Inc.
Attn: Privacy Policy Administrator
675 VFW Parkway, Suite 110
Chestnut Hill, MA 02467
privacy@jet.me

  1. Security measures we take to safeguard your personally identifiable information

The security and confidentiality of your information is extremely important to us. We use robust security measures to protect user information from loss, misuse, and alteration. We use industry-standard practices such as encrypted communications, physically secured rooms, firewalls and password protection systems to safeguard the confidentiality of your personal information. We will notify users of a data breach involving unencrypted personal information by email or by posting a notice on the affected app. We also strive to limit access to personal information to employees performing a legitimate business function. We review our security procedures regularly to consider appropriate new technology and updated methods. However, despite our best efforts, no security measure is ever perfect or impenetrable.

  1. Review, update, or delete your (or your Child’s) personal information

You can review, update, or delete your personal information at any time by signing into your Jet or Jet Parent account and editing your profile. You may also choose “DELETE ACCOUNT” within your account settings to permanently erase your account and its contents. If you are a parent who chooses to delete your account, the Child associated with your account will continue to have access to Jet.

You can request to review, update, or delete only your Child’s personal information by signing in to his or her account and choosing “DELETE ACCOUNT” within his or her account settings, or by reaching out to us with your inquiry using our contact information in the next section.

  1. Ask questions or send us comments about this Mobile Privacy Policy

If you have questions or wish to send us comments about this MPP, please contact us at:

Jet Networks, Inc.
Attn: Privacy Policy Administrator
675 VFW Parkway, Suite 110
Chestnut Hill, MA 02467
privacy@jet.me

As aforementioned, Jet is a licensee of the ESRB’s Privacy Certified Program. If you believe that we have not responded to your privacy-related inquiry or your inquiry has not been satisfactorily addressed, please contact ESRB at https://www.esrb.org/privacy/contact.jsp, or:

ESRB
Attn: Privacy Certified Program
420 Lexington Avenue, Suite 2024
New York, NY 10170
privacy@esrb.org

  1. Changes to this Mobile Privacy Policy

We may amend this Mobile Privacy Policy at any time. If we make any material changes in the way we collect, use, or share your personal information, we will notify you by sending you an email at the last email address that you provided us, or by prominently posting notice of the changes on the apps covered by this MPP. You can always verify the date that the MPP was last updated via the “Last Updated” date at the top of the MPP.