Mobile App Privacy Policy

Last modified: 2021-02-09

INTRODUCTION

Eternal Vigil Software Inc. ("Company" or "We") respect your privacy and are committed to protecting it by complying with this policy.

This policy describes:

• The types of information we may collect or that app users ("you") may provide when you download, install, access, or use Obscurity Messenger (the "App").
• Our practices for collecting, using, maintaining, protecting, and disclosing that information.

We will only use your personal information in accordance with this policy unless otherwise required by applicable law. We take steps to ensure that the personal information that we collect about you is adequate, relevant, not excessive, and used for limited purposes.

This policy applies only to information we collect in this App, and other electronic communications sent through, or in connection with this App, and any other sources.

This policy DOES NOT apply to information that:

• We collect offline or on any other Company apps or websites, including websites you may access through this App.
• You provide to, or is collected by, any third party (see Third-Party Information ).

These third parties may have their own privacy policies, which we encourage you to read before providing information on or through them.

Please read this policy carefully to understand our policies and practices for collecting, processing, and storing your information. If you do not agree with our policies and practices, do not download or use this App. By downloading or using this App, you indicate that you understand, accept, and consent to the practices described in this privacy policy. We will notify you before we make changes to this Privacy Policy and give you the opportunity to review the revised Privacy Policy before you choose to continue using our App.

INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT

We receive from Google Play (the "App Distributor") some information, which is anonymized, to operate, provide, improve, understand, customize, support, and market our App, including information related to total installations of the App and how many users of the App are active (however we cannot identify any individual user from the information). Additionally, we collect information about you through:

• Direct interactions with you, when facilitated by you. For example, by filling in forms or corresponding with us.
• Subscription information. The App Distributor shows us information about user subscriptions, including the order number, history, the order date and time, the country, province/state, city, and postal/zip code of the user's billing address, and the status of the order.

The types of information that we collect include:

• Personal information. The only personal information that we collect from you is information that you provide to us, or any personal information which you have provided to the App Distributor that they may then provide to us, which may include your name, mailing address, email address, telephone number, internet protocol (IP) address, user name or other similar identifier, billing and account information, and any other identifier we may use to contact you ("personal information").
• Technical information. We do not collect any technical information other than what may be provided to us by the App Distributor, which may include your device model, operating system, time zone setting, error logs, and usage details.

Information You Provide to Us

When you download or use this App, you provide, or we may ask you to provide:

• Information by filling in forms in the App. This includes any information you provide to the App. In the ordinary course of providing our services to you we do not have access to any of the information you provide to the App, including your list of contacts, your list of conversations, or any other information. All of the information you provide to the App is stored and encrypted on your own device.
• Records and copies of your correspondence. This includes any information you provide to us, such as email addresses and phone numbers, if you contact us to request further services or report a problem with the App.
• Your messages. In the ordinary course of providing our services to you we do not have access to your messages, including any metadata about those messages which includes the date and time a message is sent, the location it's sent from, the sender and recipient involved, how many times the message has retried sending and the IP address it is sent from or to. Your messages are stored and encrypted on your own device, and the recipient's device. If a message cannot be delivered immediately (for example, if you are offline), the sending device will retry every fifteen minutes, while it is online, until the message is delivered to the receiving device, or twelve hours have passed, at which point the message is flagged as having failed to send on the sender's device, after which time the sender may manually retry. Our messages are all sent using end-to-end encryption. End-to-end encryption means that your messages are encrypted to protect against us and third parties reading them. We cannot guarantee that your messages cannot, or will not, be intercepted or decrypted by third parties. Please consider this risk prior to utilizing the App and only proceed to use the App if you are comfortable with this risk.
• Stored information and files. In order to send files, such as photographs, files, audio, and video clips, stored on your device through the App you must provide the App with the permission to access files stored on your device. The App will only ever access metadata and other information associated with files stored on your device upon your direction, and only for the purpose of sending a message (i.e. when you choose to send a file through the App). The Company does not ever have access to the files you choose to send through the App.

Automatic Information Collection and Tracking Technologies

When you download, access, and use the App, it or the App Distributor may automatically collect:

• Usage details. When you access and use the App, the App Distributor may automatically collect, and may provide to us, in anonymized form, certain details of your access to and use of the App, including traffic data, location data, logs, and other communication data, and the resources that you access and use on or through the App.
• Device information. The App Distributor may automatically collect, and may provide to us, in anonymized form, information about your mobile device, including the device model and operating system.

The App Distributor may collect statistical information, which may include personal information, automatically and provide it to us, in anonymized form. This usage information helps us to improve our App and to deliver a more personalized service, including by assisting us in estimating our audience size and usage patterns, and storing information about your preferences and customizing our App according to your individual interests.

If you do not want us, or the App Distributor, to collect this information, either do not download the App, or delete it from your device as the case may be.

Third-Party Information Collection

When you use the App or its content, certain third parties collect information about you or your device. These third parties may include:

• Advertisers, ad networks, and ad servers.
• Your mobile device manufacturer.
• Your mobile or internet service provider.
• The Tor Network.
• The App Distributor.

These third parties may use cookies alone or in conjunction with other tracking technologies to collect information about you when you use the App. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps and other online services. They may use this information to provide you with behavioural advertising or other targeted content.

You can opt-out of several third party ad servers' and networks' cookies simultaneously by using an opt-out tool created by the Digital Advertising Alliance of Canada or an opt-out tool created by the Network Advertising Initiative. You can also access these websites to learn more about online behavioural advertising and how to stop websites from placing cookies on your device. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.

We do not control these third parties' tracking technologies or how they use them. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For more information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

HOW WE USE YOUR INFORMATION

We use information that we collect about you or that you provide to us, including any personal information:

• To provide you with the App and its contents.
• To provide you with information, products, or services that you request from us.
• To fulfill the purposes for which you provided it or that were described when it was collected, or any other purpose for which you provide it.
• To carry out our obligations and enforce our rights in any contracts with you, including to comply with legal requirements.
• To notify you when App updates are available, and of changes to any products or services we offer or provide through it.
• To improve our App, products or services, or customer relationships, and experiences.
• For any other purpose with your consent.

DISCLOSURE OF YOUR INFORMATION

We may disclose personal information that we collect or you provide as described in this privacy policy:

• To our subsidiaries and affiliates.
• According to applicable law, to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Eternal Vigil Software Inc.'s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Eternal Vigil Software Inc. about our customers and users is among the assets transferred.
• To fulfill the purpose for which you provide it.
• For any other purpose we disclose when you provide the information.
• With your consent.
• To our various representatives and professionals, including but not limited to, lawyers and accountants.
• To comply with any court order, law, or legal process, including responding to any government or regulatory request, according to applicable law.
• To enforce our rights arising from any contracts between you and us, including the App Terms and Conditions of Use.
• To our accountants for all use in all corporate financial needs, including but not limited to, bookkeeping, accounting, and tax purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Eternal Vigil Software Inc, our customers, or others.

TRANSFERRING YOUR PERSONAL INFORMATION

We may transfer personal information that we collect or that you provide us to contractors, service providers, and other third parties we use to support the App and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.

We may process, store, and transfer your personal information in and to other countries with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information. Whenever we engage a service provider, we require that its privacy and security standards comply with this policy and applicable Canadian laws.

By submitting your personal information or engaging with the App, you consent to this transfer, storage, or processing.

CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• App Permissions. When you use the App, it requests permission to access files on your device. The App does this to allow you to send those files, such as pictures, to your intended recipients. If you do not grant this permission, the App will be unable to see those files to send them. Further, the App may be unable to receive files sent to you by your contacts, though will otherwise function normally. You may revoke this permission at any time after granting it by turning off this permission for the App in the system settings app.
• Promotional Offers from the Company. If you have opted in to receive certain emails from us but no longer wish for us to use your contact information to promote our own or third parties' products or services, you can opt-out by clicking the unsubscribe link we have included in the email.
• We do not control how any third parties who have access to any of your information, either through the App or through collection outside of the App, use your information in how they choose to advertise to you. These third parties may provide you with additional choices about how they use your information or ways to choose not to have your information collected or used in this way. You can opt out of several third party ad servers' and networks' cookies simultaneously by using an opt-out tool created by the Digital Advertising Alliance of Canada. You can also access these websites to learn more about online behavioural advertising and how to stop websites from placing cookies on your device. Opting out of a network does not mean you will no longer receive advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to you based upon information they have collected or purchased based on your web preferences and usage patterns.

DATA SECURITY

The security of your personal information is very important to us. To protect it, we collect as little of your information as possible. Any messages or other information you enter into the App are encrypted and stored on your own device, or sent to only the intended recipient(s) and encrypted and stored on their device. We never have access to your messages or other information you have entered in to the App.

If you do provide us with your personal information outside of the App (for example, by emailing us) we will store that information on our secured and encrypted servers and workstations, retain it only for as long as absolutely necessary, and securely delete it when we have finished using it for whatever purpose you originally intended. Any information you provide to us will only be accessed by authorized company personnel, or as necessary by company contractors or service providers, such as lawyers or accountants, and only to fulfill the purpose you intended.

The safety and security of your information also depends on you. Where we have given you (or you have chosen) a password for access to certain parts of our App, you are responsible for keeping it confidential. We ask that you not share your password with anyone.

Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through the App. The App uses the Tor Network to send your messages, and we are not responsible for circumvention of any App privacy settings or security measures.

DATA RETENTION

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize or aggregate your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

CHILDREN UNDER THE AGE OF 16

Our App is not intended for children under 16 years of age. No one under age 16 may provide any information to the App. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this App or on or through any of its features/register on the App, make any purchases through the App, use any of the interactive or public comment features of this App, or provide any information about yourself to us, including your name, address, telephone number, email address, or any user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at privacy@eternalvigilsoftware.com.

ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION

If you want to review, verify, correct, or withdraw consent to the use of your personal information you may also send us an email at privacy@eternalvigilsoftware.com to request access to, correct, or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. We may charge you a fee to access your personal information, however, we will notify you of any fee in advance.

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

If you are concerned about our policy or would like to correct the information provided, you may contact our Privacy Officer at privacy@eternalvigilsoftware.com.

WITHDRAWING YOUR CONSENT

Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at privacy@eternalvigilsoftware.com. Please note that if you withdraw your consent we may not be able to provide you with a particular product or service. We will explain the impact to you at that time to help you make your decision.

CHANGES TO OUR PRIVACY POLICY

We may update our privacy policy from time to time. It is our policy to post any changes we make to our privacy policy on this page with a notice that we have updated the privacy policy. If we make material changes to how we treat our users' personal information, we will post the new privacy policy on this page with a notice that the privacy policy has been updated and notify you by an in-App alert the first time you use the App after we make the change.

We include the date the privacy policy was last revised at the top of the page. You are responsible for periodically visiting this privacy policy to check for any changes.

CONTACT INFORMATION AND CHALLENGING COMPLIANCE

We welcome your questions, comments, and requests regarding this privacy policy and our privacy practices. Please contact us at:

Privacy Officer - privacy@eternalvigilsoftware.com

We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information, our compliance with this policy, and with applicable privacy laws. To discuss our compliance with this policy please contact our Privacy Officer at privacy@eternalvigilsoftware.com using the contact information listed above.