THE “GREEBLE SOFTWARE, LLC” PRIVACY POLICY

Last updated:  25 October 2021

 

 

Greeble Software, LLC operates the following websites:

·  InstantDashcam.com

·  GreebleSoftware.com

 

and provides the following software:

 

·  Instant Dashcam

 

This Privacy Policy describes how information (the “Data”) about You as a person or as a company (“You” or “Your”) is collected, used, and disclosed by Greeble when You use our Services. Our Privacy Policy explains:

 

·  What Data Greeble collects

·  Why Greeble collects Data

·  How Data is used

·  Your use of our Services

·  Other information collected by Greeble

·  How Data is protected

·  How to keep Your device secure

Greeble may change this Privacy Policy from time to time, as indicated by the date at the top of the Policy. In some cases, we may provide additional notice (such as adding a statement to our Sites, sending an email notification, or posting a message within the App(s)). We encourage You to review the Privacy Policy whenever You access the Services, to stay informed about Greeble’s information and Data practices, and in this way, You can help protect Your privacy. Your continued use of the Services after Greeble posts modifications to the Privacy Policy will constitute acknowledgment of the modifications and agreement to abide and be bound by the modified Privacy Policy.

Occasionally, at our discretion, we may include or offer third party products or services via our Services. These third party products or services have separate and independent privacy policies. This Privacy Policy does not apply to products or services offered by third parties which are not owned, controlled, or affiliated with Greeble. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our Services and welcome any feedback.

Capitalized terms not defined in this Privacy Policy will have the meaning set forth in our Terms and Conditions. For more specific terms related to Greeble products and services, please review the Terms and Conditions or End-User License Agreement as appropriate.

 

No Minors

Our Services are not directed to children. Use is strictly limited to persons 18 years of age or over. If You are under the age of 18, You are not permitted to use our Sites, Apps, or Services.

Greeble adheres to the Children’s Online Privacy Protection Act (“COPPA”) and will not knowingly collect Data from any child under the age of 13.

We ask that minors not use the Services. If a child under the age of 13 has provided us with Data, a parent or guardian of that child may request that such information be deleted from our records.

 

WHAT DATA GREEBLE COLLECTS, WHY IT IS COLLECTED, AND HOW IT IS USED

                Profile and Contact Data

In order to create and maintain a user account on the Services, You must provide an email address and username, and create a password. For Google sign-in, You must grant access to Your Google profile information; Greeble will only process Your email address and Google Account ID. We will assign You a unique user ID.

Greeble does not sell contact information to any third party, for any purpose.

Your account is used to securely store Data and provide You with access in Your use of the Properties. We will use Your email address to occasionally send information related to our products and services, or if there are updates You need to be aware of to ensure You can use our products and services in a safe, reliable way. For these reasons, Greeble advises You:

·  Use a secure password

·  Keep Your account details confidential

 

Your username and user ID is shared with other Users, as You share Your Content, according to the options You select.

 

Your “profile and contact Data” is deleted once your rights to use the Services have been terminated. There is an exception to this, however: if Your account has been terminated “for cause” (as described by the Terms and Conditions), we will retain Your email address indefinitely, in order to prevent any future access attempts You make to the Services.

Log Data

Like many site operators, Greeble collects information sent by Your device whenever You visit or connect to a Site, whether via an App, or via third-party browsing software.

This Log Data includes information such as Your device’s Internet Protocol ("IP") address, browser type, browser version, the pages of the Site that You visit, the HTTP “referrer” for each page You visit, the date and time of Your visit, records of the Media that You view, which search criteria You use, and other statistics.

Greeble uses this information to protect and improve our products and services.

IP addresses are anonymized after 14 months. There is an exception to this, however: If we determine that You have attempted to attack/disrupt our services, and/or Your account has been terminated “for cause” (as described by the Terms and Conditions), we will retain Your IP address indefinitely, to monitor & prevent any further access attempts You make to the Services.

Your Media

Your Media is shared online as provided by the particular App or Service You are using. Before using any of our Services, You should become familiar with its operation and settings (especially the sharing controls). In this way, You can gain an understanding of which Media is uploaded, at what times, and what other parties will have access Your Content. Each App describes the ways that it uses Media, both in the app store listing, and within the App itself.

Definitions

When used within the Services, these terms have the following meanings:

·  “Public”: Anyone visiting our Sites or using our Services has access to “Public” Content.

 

·  “Private”: Only You have access to “Private” Content*.

 

·  “Friends”: Friends are Users that You have added to Your “friends list”. Any non-Private Content You have elected to share is accessible to Your Friends*.

 

·  “Cloud”: Refers to our online Services (the “Sites”), and Media that is hosted online, regardless of whether or not the hosting is performed by an actual cloud service provider.

 

·  “Local”: Refers to storage on Your device (the device that runs the App).

 

*Our Site moderators, administrators, and maintenance personnel may access all Your Content, including Your Private Content, in the following circumstances:

·  They are investigating a complaint, or Content on Your Account that has been “flagged”, by a User, for moderator attention.

 

·  They are investigating possible fraud, abuse, or some other violation of the Terms & Conditions.

 

·  You have enabled the “Share with Maintenance” option on Your account settings (usually, when working with our support team to troubleshoot a technical issue).

Media Restriction and Availability

Note that, even though You may remove access from a User, or remove them from Your “Friends List”, they may still have copies of Your Media acquired during a time when they had access, or, for example, from an online cache. Furthermore, Users are free to copy or redistribute any of Your Content which they have rightful access to, subject to the limitations of the Terms & Conditions. Only choose Friends that You can trust with Your Content, and that You can trust to securely manage their account credentials.

Uploads based on user-select time limits

Whenever Media is uploaded based on User-selected time limits (for example, automatically uploading a video clip in response to a motion event), the range of Media uploaded and shared may, in practice, extend before and after the selected limits by a small amount (typically less than two seconds’ worth). This is to aid in the proper transmission and display of Your Content.

Managing Your Media

Your Media may be stored in a variety of different formats. On our servers, this includes individual “Videos”, and “CloudCaches”.

Videos

You can easily delete Your Videos at any time. Videos can go in different “Channels”; each of which has a different audience, which implies sharing this Content with different categories of Users.

CloudCaches

A CloudCache is a special format which supports features such as “on-demand streaming” and “automatic uploads”.

Generally, each App instance has a CloudCache. CloudCaches contain Media clips of various length, from different points in time, all from Your device. They also contain “protocol-level information” (see “Other Information Collected By Greeble”). If a User requests data, like a video stream, from Your device, and that request can be satisfied by the CloudCache, then the data doesn’t need to be re-sent (which saves mobile bandwidth).

There is no simple way to audit all the Content that is present in each CloudCache. Although CloudCaches automatically delete data to save space, You may choose to manually clear Your CloudCache at any time. Your App and Site account are equipped with a “Clear CloudCache” feature, where appropriate, for this purpose. “Clearing” a CloudCache just removes Media data, not necessarily “protocol-level information”.

Note that clearing Your CloudCache too often can result in increased mobile data usage.

Accounts with multiple registered Apps may have multiple CloudCaches. Clearing one CloudCache does not clear all of them; each CloudCache must be handled individually.

Precise Location Data

Your Media can include “Precise Location Data”. We will not sell Your Precise Location Data, or use it for marketing, under any circumstances.

Just as with Your other Media, we store, share, and publish Your Precise Location Data according to Your wishes, as described by the settings You have chosen, and by the Service features You use.

Google Maps

When You access a Site or App feature that includes a Google Map, Your device’s GPS location data and unique device identifiers (including Your Google advertising ID via the Google Maps API) are collected and used by Google according to its privacy policy.

Marketing Data

WE DON’T WANT TO SPAM YOU. If Your communication preferences allow, we may use Your email address to contact You with the occasional newsletter, marketing email or promotion. Much more likely, though, we will simply be contacting You to remind You of a routine account maintenance action. You may adjust Your communication preferences in the account settings for the appropriate Service.

Greeble collects IP addresses and mobile advertising IDs from App Users in order to facilitate targeted advertising. This information is anonymized or deleted after 14 months.

If You opt-in to the User Experience Program (“UXP”) for a given App, that App may collect the following additional information:

Occupation Identifiers

Greeble reviews user occupation (relating to commercial or professional driving, e.g., “Bus Driver”, “Truck Driver”) to facilitate ad targeting.

Details concerning how You use the App

For example, we may analyze how often You use the App, which features You use, and how frequently. This information helps us improve App quality and user experience, and assists us in ad targeting.

We use “Google Analytics for Firebase” to aid us in collecting this information. Detailed lists of specific items collected by Google LLC may be found here and here. To learn how Google uses data when You use their partners’ sites or apps, please reference the Google Privacy and Terms document.

Your UXP-related information is anonymized or deleted after 14 months. However, You may opt out of the UXP at any time by un-checking the “User Experience Program” checkbox in the App settings. You may delete previously collected Usage Data by using the “Manage UXP Data” feature in Settings->Misc (an internet connection is required). Furthermore, in the “general settings” for most devices, under Google->Ads, there are options (such as “Reset advertising ID” and “Opt out of Ads Personalization”) that You can use to control how this information affects You.

Account cookies

When You create an account on our Services, two random identifiers, known as the “obfuscated account ID”, and “obfuscated profile ID” (and collectively referred to as “account cookies”), are generated and associated with Your account. Each time You attempt to purchase a new subscription via the App, these account cookies are transmitted to Google LLC, in order to detect & discourage purchase fraud.

Web cookies and similar tracking technologies

We, along with third parties who assist us in operating the Site, may monitor Your use of the Site through cookies, web beacons and other data collection tools. Unless You have adjusted Your browser setting to refuse all cookies, some cookies are placed on Your browser immediately as soon as You visit our Site. We reserve the right to monitor use of this Site as described in this policy by the use of any automatic data collection tools at all times and You consent to the use of these tools when You use and access our Site.

First-Party Cookies. Those used by our Site.

Website Use: We use first-party cookies to maintain Your user session while You are signed in, to remember Your user ID, Your username (if You have so elected), to store Your Site settings, and to store other Site choices You have made. Your session cookie is a necessary cookie; the Site will not function properly without it. It is also a persistent cookie; it remains present on Your device even after You close your browser window.

Third-Party Cookies. Set by a third-party source.

Google NID cookie: Google’s NID cookie contains a unique ID Google uses to remember Your preferences and other information to help customize ads on Google properties. For more information on Google’s cookies, please refer to Google’s Privacy Terms. You can opt out of Google’s ads personalization for Your browser or Google account by visiting the following page: https://adssettings.google.com/.

How You can delete and block web cookies

You can block cookies by activating applicable settings on Your browser. However, if You use Your browser settings to block all cookies (including necessary cookies), You may not be able to use all or parts of the Site.

 

YOUR USE OF THE SITE OR APP

Users will typically act as the data controller for any Content they provide to Greeble via an App or a Site. Data controllers are responsible for implementing appropriate measures to comply with applicable privacy laws. As a result, You are responsible for the Data You may provide, including:

·  Audio/video (Media) recordings captured by an App, including any information contained therein;

·  Geolocation (GPS) information;

·  any Comments;

·  other Content.

Special Categories of Data

Media may inadvertently include special categories of personal Data about You and others. For example, sound or images which reveal an individual’s religious or philosophical beliefs, political beliefs, racial or ethnic origin, trade union membership, genetic data, biometric data, health data, sex life, or sexual orientation. It is Your responsibility to explain what information each App collects to, for example, any passengers in Your vehicle.

Greeble will only have access to special categories of personal data if such data is captured in Your device’s camera and/or microphone, and is then uploaded. Such access to these special categories of data is incidental to the use of the Services, and Greeble will not actively process this data for any reason.

 

OTHER INFORMATION COLLECTED BY GREEBLE

In the course of providing the Services, Greeble may collect additional information which does not relate to You as a person or as a company.

Your device’s make and model

We use Your device’s make and model information to properly label Your device on the Service user interface, and to understand how different devices work with the Service. This information is shared with Your Friends.

Your device nickname

Your device nickname (“Device name”) is also shared with Your Friends.

App version information

We collect App version information in order to verify software compatibility, track upgrades, and determine how different versions of an App work with the Service.

Locale information

Locale information, such as Your preferred language or dialect settings, is used to aid us in providing readable text in the form You can most easily understand.

Feedback submitted via the “Leave Feedback” feature

We want to hear Your feedback! We review and store feedback in the form of text comments. Please note, You are responsible for any data entered in text comments. Feedback text may be associated with Your device, IP address, or account. We will keep Your feedback confidential.

Order information

We retain records of Your App-related Google Play purchases in order to properly maintain the Service and account balance information.

Subscription status information

The subscription status of each of device You share with Your Friends is also shared. This is so that Friends can add You to their own subscription, if they desire.

Mobile data usage and connection status information

The estimated mobile data usage, and current connection (e.g., “WiFi”, “mobile”, “disconnected”) status of each of device You share with Your Friends is also shared. This is to help Your Friends avoid using up Your device’s mobile data (during streaming operations), and to understand if/when Your device is available for streaming.

Protocol-level information

Whenever You upload Media via an App, additional “protocol-level information” may be included. Protocol-level information includes, among other things, timestamps that indicate when each App recording session has started and stopped, information about the number of recordings that have been made, and information about which Media is currently present on Your device (regardless of what streams you have selected, or not selected, for upload). Protocol-level information is shared, in certain circumstances, in conjunction with the Media You share.

Google Fonts

The Site uses Google Fonts. When Your browser loads our Site, it may contact Google to download a font file. This transaction leaves a record on Google’s servers, but does not involve any cookies. Click here to learn more about Google’s privacy policies.

 

KEEPING YOUR DEVICE SECURE

The Apps You have on Your device contain authentication information in the form of account credentials and private keys. Anyone who possesses Your device can use this information to fraudulently access Your Content, or Your Friend’s Content, or make unauthorized changes to Your account.

In the event Your device is lost or stolen, You can disable individual App instances using the controls available on Your Site account:

·  If Your account is configured to use password authentication: We recommend changing Your password, via the account settings page, prior to accomplishing these next steps:

 

·  To mitigate the risk of fraudulent account access, select the “Log me out everywhere” option. You will then have to manually re-authenticate (log in) from each device You still possess, which will restore account access to those devices.

 

·  To prevent a lost or stolen device from generating & sharing new Content on Your behalf, simply delete it from Your account. This deletes the CloudCache, and makes it unavailable for further streaming. It does not destroy any data already stored Locally on Your device.

As a reminder: If a device is lost, You may wish to access Your Google Play account, in order to cancel any subscriptions You have purchased for that device.

 

HOW DATA IS PROTECTED

The security of Your Data is important to us. We use several different techniques to protect and maintain the integrity of Your data, including, but not limited to:

·  The encryption of App and Service connections, using TLS, when appropriate

·  Regular testing of server software, to ensure access controls operate as intended

·  On-disk hashing of passwords, secured using commonly accepted industry practices

·  The anonymization of IP addresses within 14 months

Please 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 Data, we cannot guarantee its absolute security.

Data and Information Retention

In order to limit the amount of unwanted or obsolete Data/information maintained by the Service, and to enhance user privacy, Greeble reserves the right to delete certain Data and other Content. At our option, we may choose to consult You prior to such a deletion, but we are not required or expected to do so. Under normal circumstances, we use the following disposition schedule:

·  CloudCaches are for temporary storage only, and may be cleared at any time.

 

·  Videos that do not meet the criteria laid out in the Content Policy may be deleted at any time.

 

·  Videos that are not visible to the general public, due to moderator intervention, User selection, corruption, or any other reason, may be deleted at any time.

 

·  Public Videos that are at least 6 months (183 days) old, which have not received any new votes in the preceding 6 months, may be deleted at any time.

 

·  Other, non-Public Content may be deleted beginning 6 months after creation.

 

·  User accounts that have not logged any activity in the past 6 months are subject to immediate deletion.

Greeble deletes unwanted or obsolete Data/information at its own convenience. In practice, such Data/information may be retained for a longer period than described in this schedule, according to any aforementioned Policy terms. Remember that You can easily delete any of Your uploaded Media, at any time, using controls provided by the Site.

In certain circumstances, deleted Data may continue to exist temporarily, in the form of a digital backup. Backups will be purged within 30 days.

 

Sharing Your Data

We may share Your personal Data with third parties for the purposes set out below:

1. Third-party data processors to assist with enumerated processing activities per the terms of associated data processing agreements, including IT and system administration services. This includes:

 

                                                                                     i. Google LLC

                                                                                   ii. Amazon Web Services (cloud hosting)

 

2. Our advisers including lawyers, bankers, auditors, and insurers, who provide professional services subject to applicable confidentiality agreements.

 

We do not allow third-party service providers to process Data for their own purposes and only permit them to process Data for specified purposes in accordance with the applicable terms and conditions.

 

International Transfers of Data

Greeble is headquartered in San Antonio, Texas. As a result, all Data is subject to transfer to the United States. In addition, Data provided to third parties may be processed at any location where they or their agents maintain facilities. By using any of the Services, You agree for Your Data to be transferred subject to the terms of this Policy and any applicable arrangements. Any Data collected, processed, and transferred to the U.S. as a part of App delivery and service is governed by the applicable EULA. Data collected, processed, and transferred as part of visiting or using the Site is governed by our Terms and Conditions.

 

GDPR For Individuals in the European Union or the United Kingdom

Users located in the European Union or United Kingdom may have additional rights regarding their personal data, subject to applicability of relevant laws. Those rights include:

1. The right to be informed about what personal data is being processed, for what purposes, and who else the data may be passed to.

2. The right to access personal data stored by a Data Controller.

3. The right to correct, amend, or rectify errors in personal data. 

4. The right to have personal data deleted under certain circumstances.

5. The right to restrict processing or otherwise temporarily halt processing, for example when there is a dispute over the data.

6. The right to “data portability” – that is, to have copies of any data supplied directly to the Data Controller provided in a structure, commonly used, and machine-readable format.

7. The right to object to further processing of personal data.

8. The right not to be subject to decisions based solely on automated processing.

You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here:  http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.  If You need further assistance regarding Your rights, please contact us using the contact information provided below and we will consider Your request in accordance with applicable law. In some cases our ability to uphold these rights for You may depend upon our obligations to process personal information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services You have requested. Where this is the case, we will inform You of specific details in response to Your request.

 

CONTACT US

If You have any questions about this Privacy Policy, please contact us: