Privacy Policy

About Caspar

Caspar is a new type of social network based on voice — where people around the world come together to talkand learn from each other in real-time. It’s a place to meet with friends around the world and with new people to tell discussion, ask questions, debate, learn, and have impromptu conversations.

With no camera on, you don’t have to worry about eye contact, what you’re wearing, or where you are. You can talk on Caspar while you’re folding laundry, taking a walk, commuting, or working on your couch in the basement. Instead of typing something and hitting Send, you’re engaged in a back-and-forth dialogue with others. The intonation, inflection, and emotion conveyed through voice allows you to pick up on nuance and form uniquely human connections with others.

The thing we love most is how voice can bring people together. To protect that, we take your privacy seriously and only use personal information to make Caspar work well for you.

Our Privacy Principles

If you decide not to read this entire Privacy Policy, we want you to walk away with a few key points about Caspar’s privacy practices:

• Our App is designed to allow you and others to use your voices to interact with each other in real time.
• We use personal information to provide our services, to communicate about existing and new Caspar features with you, and to comply with our terms and applicable laws.
• We do not sell personal information.
• To create a safe environment on the App, we may record conversations and use the recordings to investigate violations .We generally prohibit the recording of conversations in our rooms without speakers’ and participants’ explicit authorization.

Personal Information We May Collect

Here’s a description of the categories of information we collect when you interact with our App, and examples of how we use the specific types of information. We may collect:

• Account data, such as your first and last name, organization name, email addresses, phone number, profile picture, preferred language, user name, and other information you may choose to include in your profile/bio.
• Your contacts’ phone numbers (if you choose to authorize this). To help users connect with people they know, we offer them the option to invite friends to join them on Caspar. To take advantage of this feature, users can opt in to share phone numbers from their address book or add phone numbers manually.
• Names of friends you choose to invite to join you on the App.
• Conversations that moderators and speakers have in Caspar rooms.We temporarily record the audio in all rooms and only retain it (along with a transcript) if a user or our automated systems flag a potential Trust and Safety violation. We also retain the recordings that our users create and share using our optional recording features. We never record audio data from muted speakers/moderators or listeners/audience members.
• Messagesyou send to and receive from other users on the App, including payment thank you notes and direct messages. We review the contents of these messages only if there are user reports or automated systems flags indicating a Trust and Safety violation.
• Interests, usage, and connections, including information about your interests (if you choose to add them) and how you use the App, such as the types of Caspar conversations you engage in, content you share, features you use, actions you take, people or accounts you interact and connect with, and the time, frequency, and duration of your use.
• Communications that we exchange with users when they contact us with questions or feedback, including feedback about interacting with other users.
• Payment and transactional data including name, payment card information, bank account number, billing information, and your transaction history. This information is collected by our payment provider, Stripe, and Caspar does not have access to payment card numbers. In addition to this Privacy Policy and ourterm of services related to your payments or purchases is also processed according to Stripe’s services agreement and privacy policy.
• Information provided by social media companies, if you interact with our pages on their services or connect your social media accounts. Connecting your social media accounts allows the App to authenticate your identity and access limited information about those accounts, including the number of connections you have. The information that social networking accounts provide to Caspar may depend on the privacy settings you have with each company, so please consult their privacy and data practices.
• Device datasuch as device IP address (and derived location), device name and operating system, browser type and settings, telecommunications provider, operating system, the date and time of App use, interactions with the App, and the time, frequency, and duration of the interactions. You may also opt-in to allow us to access your device’s call log data to verify your phone number (as an alternative to text message-based verification) when you join Caspar. We will access the call log data once – when you join Caspar.

How We Use Personal Information

We use personal information to:

Provide our services, including to:

• Invite you to our App;
• Operate the App and our business;
• Maintain, improve, and develop the App and the App’s features;
• Create and maintain your account;
• Facilitate network connections;
• Recommend rooms, users to follow and clubs that might be of interest to you;
• Notify you when one of your contacts has joined the App;
• Engage Stripe to process your transactions with other users or with us;
• Communicate with you about the App by sending you push notifications with announcements, updates, security alerts, and support and administrative messages, if you have enabled that functionality; and
• Provide support for the App, and respond to your requests, questions and feedback.
• Allow moderators to share and promote their rooms

Direct marketing: We may send you direct marketing communications as permitted by law, including, but not limited to, notifying you of feature releases and special events. You may opt out of our email marketing communications as described in the section below. Please note that we may periodically send you transactional emails even after you opt out of direct marketing.

Research and Development: We may create and use de-identified information for our business purposes, including to analyze the effectiveness of our App, to improve and add features to our App, and to analyze the general behavior and characteristics of users of our App.

Support and Maintenance: We use third party analytics services to automatically log certain information about your mobile device and how you interact with the App. The information collected is used to troubleshoot and prevent errors, perform data analysis, and develop new features.

Compliance and protection: We may use personal information to:

• Protect our, your, or others’ rights, privacy, safety or property (including by making and defending legal claims);
• Enforce the that govern the App;
• Enforce by investigating potential Trust and Safety violations using the audio recorded collected as described in the Personal Information We May Collect section;
• Audit our internal processes for compliance with legal and contractual requirements and internal policies;
• Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft; and
• Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

How We Share Personal Information

We do not sell personal information. In the ordinary course of business, we may share personal information with:

Service providers: Companies and individuals that provide services on our behalf or help us operate the App or our business (such as hosting, analytics, customer support, email and SMS delivery).

Professional advisors: Professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others: Law enforcement, government authorities, and private parties as we believe necessary to: (a) protect our, your, or others’ rights, privacy, safety, or property (including by making and defending legal claims); (b) enforce the term of condition that govern the App; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical, or illegal activity.

Business transferees: Acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale, or other disposition of all or any portion of the business or assets of, or equity interests in, Caspar or our affiliates (including, in connection with a bankruptcy or similar proceedings).

How You Share Information on Caspar

Public: When you establish an account on Caspar, you share certain of your profile information with the Caspar community on our App and on the web. This information includes your profile picture, bio, name, username, the handles of social media accounts you connect to Caspar, the list of users you follow and those that follow you, the date you joined Caspar, the friend who nominated you, Caspar events to which you have RSVPd, and the clubs in which you participate. Additionally, you may use certain Caspar features to share or store recordings of conversations among moderators and speakers. If you do share these recordings then you choose the audience for what you share, and such sharing will be carried out for your own purposes and not Caspar’s.

Caspar users: Caspar users with whom you have some affiliation on the App or other social media accounts may receive notifications about actions you take on the platform, such as joining clubs or rooms. You may also choose to authorize other users to record your Caspar conversations.

Instagram, Twitter and other social media companies: If you connect your social media accounts (e.g., Instagram or Twitter) with Caspar, Caspar will also inform those companies that you have authorized its access to your profile information and connections associated with your accounts with those companies. You may choose to share recordings on other social media platforms. Such sharing will be carried out for your own purposes and not Caspar’s, and such recordings will be subject to the social media platform’s policies.

Your Choices

Update, correct, or delete: You can contact us to ask us to update or correct your information. You may also delete your account or request that we delete the contact phone numbers you previously shared with Caspar. Please note that we will need to verify that you have the authority to update, correct, or delete the account and certain activity generated prior to deletion may remain stored by us and may be shared with third parties as detailed in this Privacy Policy.

Disconnect social media accounts: When you connect your social media accounts to Caspar, we notify those platforms. You may disconnect your social media accounts directly on the App at any time.

Opt out of marketing communications: You may opt out of marketing-related emails by following the opt out or unsubscribe instructions contained in the communications we send you.

Opt out of push notifications: If you opt-in to receive push notifications within the App, we may send push notifications or alerts to your mobile device from time to time. You can deactivate push notifications and alerts at any time by changing your device settings, changing the push notification settings within the app, or deleting the App.

Disable optional recording features: Creators of a room or moderators may disable optional audio recording features, such as Clips.

Other Sites and Apps

The App may contain links to websites and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites or online services operated by third parties, and we are not responsible for their actions.

Processing of Personal Information in the United States

Caspar has users located across the globe. We are headquartered in the United States with services providers that operate in other countries. We may transfer your personal information to the United States and other countries which may not have the same data protection laws as your home country or territory, but we will protect your personal information in accordance with this Privacy Policy, or as otherwise disclosed to you.

Data Security

You use the App at your own risk. We implement commercially reasonable technical, administrative, and organizational measures to protect personal information both online and offline from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the Internet. Please keep this in mind when disclosing any personal information to us via the Internet. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the App, or third party websites. Finally, we cannot control the actions of users on the platform, who may seek to use third party apps or devices to record, store, or share content or communication without other users’ prior consent. Please keep this in mind when using the App.

Children

The App is not intended for use by children under 18 years of age. If we learn that we have collected personal information through the App from a child under 18 without the consent of the child’s parent or guardian as required by law, we will delete it.

Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the App. If required by law, we will also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via email or another manner through the App. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the App after the effective date of any modified Privacy Policy indicates your acknowledgment of the modified Privacy Policy.

The CCPA limits these rights. For example, companies may not provide users in response to access requests certain sensitive information and other consumers’ personal information, and may exclude information that would compromise the confidentiality of trade secrets. The CCPA also places limits on when companies must comply with a deletion request.

In accordance with the CCPA, Caspar will not provide the following information in response to access requests for the reasons described:

• Account data such as account passwords and identity verification codes, unmasked phone numbers, or email addresses, because of the sensitive nature of this information.
• Other users’ and employees’ personal information, including the names and account information of individuals who may have invited you to the App, other users’ feedback, and employees’ comments because it is information that belongs to another natural person and disclosing it may impact their rights.
• Internal proprietary attributes that enable us to provide various aspects of our App, including channel and room customization, suspension decisions, and content suggestions, because it is protected by federal and state trade secret law.
• Server logs that are older than 30 days because we use these to ensure the security and integrity of our App.

You are entitled to exercise the rights described above free from discrimination.

Here is how you can submit requests:

• To request access to or deletion of personal information collected, please email us at support@Casparapp.com or submit a request.
• To verify your identity prior to responding to your requests, we may ask you to provide us with your phone number so we can send you a verification code, or with other details that we may need to verify your identity.
• Authorized agents. California residents can empower an “authorized agent” to submit requests on their behalf. We will require authorized agents to confirm their identity and authority, in accordance with the CCPA.

Notice to European and Brazilian Data Subjects

We are providing this supplemental privacy notice to European data subjects, pursuant to European data protection laws (“GDPR”) and Brazilian data subjects, pursuant to Brazilian data protection laws (“LGPD”).

Controller and Representative. Caspar is responsible for how your personal data is handled. This means we are the controller of your personal data under the GDPR. You can find our contact information in the “section above.

Our representatives in Europe:

• EEA and Switzerland: VeraSafe Ireland Ltd., Unit 3D North Point House, North Point Business Park, New Mallow Road, Cork, T23AT2P, Ireland.
• UK: VeraSafe United Kingdom Ltd., 37 Albert Embankment, London SE1 7TL, United Kingdom.

section above

Justification for Data Processing. European and Brazilian data protection law sets out a list of justifications on which companies may rely to process personal data, and requires companies to explain to consumers the specific justifications for the company’s data processing activities. Caspar generally relies on one of the following justifications to process personal data:

• Contractual Necessity, to provide you with the App in accordance with our term of services.
• Legitimate Interests, where it is necessary for our legitimate business purposes, your interest or the interests of a third party.
• Consent, where required by law. Where we rely on your consent to process personal data about you, you have the right to later withdraw your consent in the manner indicated when you consent or by contacting us as described in this Privacy Policy.