Privacy Policy

Effective date: 3/30/2020

Overview

Opening Statement

Siempre does its best to make sure your data is safe and that your privacy is respected.

This starts with us internally acknowledging and understanding any incentives that we might have that might be misaligned with the health and interests of our users. We then try to minimize or counteract those incentives so that we can systematically be trusted to make the right choices as often as possible. This approach applies not just to our incentives as an organization or as a company, but also as a team and as individuals.

This attention to our alignment with our users shows up both in our choice of what ideas to pursue and also in the implementation of those ideas. We design our services to use the minimum amount of data needed for us to provide those services and to minimize how much of that data has to pass through our own servers or stay in storage. We also strive to use and design technologies and user interfaces that make it really clear to our users how our systems work.

Implementing all of this is a never-ending process and we have a lot of work left to do just to reach our current targets for user safety and privacy.

In the meantime, this page will describe or provide links to the data practices for this website and any of the services that we offer.

Product-specific Policies

The following sections describe policies and practices specific to each of Siempre’s services.

Website

Here are some of the data practices used on our main website (everything under the “siempre.io” domain, but not including subdomains like “town.siempre.io” or “video.siempre.io”):

We made this list of practices in an effort to be informative beyond the typical legal requirements, so that you get a better picture of how your data is being used. It is not completely exhaustive. Refer to later sections in this document for a more general policy.

If you'd like to disable Google Analytics on "siempre.io" and all its subdomains ("town.siempre.io", "video.siempre.io"), just click here:
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Online Town

Here are some of our data practices that we use for Online Town, specifically:

We made this list of practices in an effort to be informative beyond the typical legal requirements, so that you get a better picture of how your data is being used. It might not be completely exhaustive. Refer to later sections in this document for a more general policy.

Siempre Video

In “Siempre Video” (“video.siempre.io” and its corresponding desktop and mobile apps) we DO NOT store or have access to any video/audio streams from our users: these connections are established peer-to-peer and not through a central server. From a technical standpoint, each app instance communicates to a central server that helps establish direct connections between the devices through which all video/audio streams go through.

However, we DO have access to video/audio messages sent between users. These messages are stored on our central server and not peer-to-peer because the sender needs to be able to send a message even if the recipient’s device is not online to receive it. For a similar reason, we also store profile pictures in our central server.

We log some information in the providing of the service. We use this information to understand the usage of and improve our apps. This includes:

Additionally, our database contains other information that isn’t logged anywhere. That is, there is no record of this information beyond its current state. However, this does mean that any of the developers of Siempre Video can go into the database and see what this information is at that point in time. This information is used to provide core functionality to our service. These include:

We made this list of practices in an effort to be informative beyond the typical legal requirements, so that you get a better picture of how your data is being used. It is not completely exhaustive. Refer to later sections in this document for a more general policy.

General Policies

The following sections apply to all of Siempre's services.

Types of Data Collected

Personal Data

While using our services, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:

Usage Data

We may also collect information that your browser sends whenever you visit our services or when you access our services by or through a mobile device (“Usage Data”).

This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our services that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access our services with a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

Cookies

We use cookies and similar technologies to track the activity on our services and hold certain information.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies may also be used to collect and track information and to improve and analyze our services.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our services.

Examples of Cookies we use:

We do not use advertising cookies.

Uses of Data

We use the data we collect for various purposes. These uses include, but may not be limited to:

Retention of Data

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our service, or we are legally obligated to retain this data for longer time periods.

Transfer of Data

Your information, including Personal Data, may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United States and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

We will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.

Disclosure of Data

We will not sell your personal information.

In the case of a merger, acquisition or asset sale, your Personal Data will not be transferred.

We only disclose your information to other affiliates:

Security of Data

The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

Analytics

We may use a third-party service to monitor and analyze the use of our services.

Your Rights under the General Data Privacy Regulation (GDPR)

If you are a resident of the European Union (EU) and European Economic Area (EEA), GDPR affords you certain rights. These include:

To exercise any of the above rights, please send a request to hello@siempre.io.

Please note that we may ask you to verify your identity before responding to such requests.

Additionally, you have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

Your Rights under the California Online Privacy Protection Act (CalOPPA)

In accordance with CalOPPA, we agree to the following:

We do not honor Do Not Track signals.

Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

Your Rights under the California Consumer Privacy Act (CCPA)

If you are a California resident, you are entitled to learn what data we collect about you, ask to delete your data and ask us not to sell it. You can make the following requests to us:

Please note, if you ask us to delete your data, it may impact your experience with us, and you may not be able to participate in certain programs or membership services which require the usage of your personal information to function.

We will not, however, in any circumstance discriminate against you for exercising your rights. To exercise your California data protection rights described above, please send a request to hello@siempre.io.

Children’s Privacy

Our services do not address anyone under the age of 18. If you are a parent or guardian, and you are aware that your child under the age of 18 has provided us with Personal Data, please email us immediately at hello@siempre.io. If we become aware that we have collected Personal Data from children without verification of parental consent, we will take steps to remove that information from our systems.

Changes to our Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Limitation Of Liability

In no event shall Siempre, nor its directors, employees, partners, agents, suppliers, or affiliates, be liable for any indirect, incidental, special, consequential or punitive damages, including without limitation, loss of profits, data, use, goodwill, or other intangible losses, resulting from (a) your access to or use of or inability to access or use the service; (b) any conduct or content of any third party on the service; (c) any content obtained from the service; and (d) unauthorized access, use or alteration of your transmissions or content, whether based on warranty, contract, tort (including negligence) or any other legal theory, whether or not we have been informed of the possibility of such damage, and even if a remedy set forth herein is found to have failed of its essential purpose.

Disclaimer

Your use of the service is at your sole risk. The service is provided on an "as is" and "as available" basis. The service is provided without warranties of any kind, whether express or implied, including, but not limited to, implied warranties of merchantability, fitness for a particular purpose, non-infringement or course of performance.

Siempre its subsidiaries, its affiliates, and its licensors do not warrant that (a) the service will function uninterrupted, secure or available at any particular time or location; (b) any errors or defects will be corrected; (c) the service is free of viruses or other harmful components; or (d) the results of using the service will meet your requirements.