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Privacy Policy

updated at January 3, 2023
Effective date: January 3, 2023
Welcome to Scatter Lab, Inc. (“Company,” “we,” “us” or “our”), a technology company specializing in products related deep learning AI, including our Zetty Chat Analyzer, a tool to help you analyze your mobile messenger chat.
We recognize that your privacy is important and appreciate the trust you place when you send us your information. We have developed this Privacy Policy (“Privacy Policy”) to explain our technologies and to describe how and why we collect, use, and share information that all users or others (“Users”, “you” or “your”, as applicable) may provide while downloading, installing, registering with, accessing, or otherwise using (“Use”) our mobile application: Zetty (“Zetty” or “application”).
If you have any questions or concerns after reviewing this Privacy Policy, or our practices with regards to your Personal Data, please contact us at hello@zetty.app.
This Privacy Policy describes:
Our practices for collecting, using, maintaining, protecting, disclosing, and otherwise processing (“processing”) User information in connection with the Use of Zetty.
The choices you have for managing your Personal Data.
This Privacy Policy applies only to information we collect in Zetty and via email, text, and other electronic communications sent through or in connection with Zetty. Please note that this Privacy Policy DOES NOT apply to our processing of information about job applicants, employees or contractors, nor does it cover the processing of information we collect offline or through or in connection with our other products and services.
Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. By submitting information through or otherwise Using Zetty, you acknowledge that we may process information in accordance with this Privacy Policy, the privacy preferences you have made known to us, and as permitted or required by law. If you do not want us to process your Personal Data as it is described in this Privacy Policy, please do not Use Zetty.

1. INFORMATION WE COLLECT AND HOW WE COLLECT IT

We may collect information, including but not limited to Personal Data, from and about you in several ways, including:
Directly from you when you provide it to us.
Automatically when you Use Zetty.
From other users and third parties.
When we use the term “Personal Data” in this Privacy Policy, we mean information that (i) identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual or household or (ii) is protected as “personal data,” “personal information” or another similar terms under applicable data protection laws. It does not include aggregated or deidentified information that is maintained in a form that is not capable of being associated with or reasonably linked to an individual or household.

2. INFORMATION YOU PROVIDE TO US DIRECTLY

When you Use Zetty, you usually provide to us certain information, including your Personal Data. We collect the following Personal Data you provide to us directly.
Messenger Chat History. When you provide the chat histories from messenger chat providers (e.g. WhatsApp, Facebook Messenger, Telegram) that you export and upload to Zetty, we collect any communications between you and other users of the messenger chat provider (“Chat Partners”) found in your chat history and information about you and your Chat Partners use of the messenger chat provider, including account names, profile information, profile pictures and contact information, and all content and multimedia included in the chat, including text, images and video clips. Please note the following before you upload messenger chat history information to Zetty:
Sensitive Data: Chat histories can include information that reveal a wide variety of sensitive information about a person, including you and your Chat Partners. By uploading your chat histories, you are agreeing to our processing of the content of your chat histories for the purposes set out in this Privacy Policy (the “disclosed purposes”), including to the extent they contain information that may reveal racial or ethnic origin, religious beliefs, union membership, sexual orientation, citizenship or immigration status, account access credentials (e.g., username and password), medical history, mental/physical health condition, medical treatment or diagnosis by a health care professional, financial account and payment card information, and government identifiers (e.g., tax IDs, driver’s license numbers) (collectively “Sensitive Data”). If you or your Chat Partners do not agree to this processing of Sensitive Data for the disclosed purposes, please do not upload your chat histories.
You are expressly prohibited from uploading conversations with a child under the age of 13 and agree that the chat histories you upload to Zetty will not include any conversation with a child under the age of 13.
Chat Partner Authorization: You are solely responsible for ensuring that you have the consent and permission of your Chat Partners to share their chat data with us for the Disclosed Purposes.
Contact and Profile Information. When you download, create an account, and Use Zetty or otherwise communicate with us, we collect your name, email address, postal address, user ID, password, telephone number, birthday, gender, and employment information to create and store in your profile.
Chat Analysis. When you use our chat analyze feature in the application on your chat history with a Chat Partner, we ask you some questions your relationship status with your Chat Partner. The information is used by the AI algorithm to better inform the chat analysis and tailor the output based on this information.
Communications. If you communicate with us through any paper or electronic form or report technical issues through the application, email, mail, or chat, we may collect your name, postal address, email address, user ID, telephone number, and any other personal information you choose to provide to us. We use this information to investigate and respond to your inquiries, and to communicate with you, to enhance the services we offer to our Users and to manage and grow our organization. If you are enrolled in our emails or other promotional messages, we will communicate with you by email, text message or push notification. We may also send you service-related emails or messages (e.g., user account verification, change or updates to features of the application, technical and security notices) and communications from or about Zetty.

3. INFORMATION WE COLLECT THROUGH AUTOMATIC DATA COLLECTION TECHNOLOGIES

When you Use Zetty, we use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:
Usage Details. Details of your Use of Zetty, including automatically recorded log files containing the pages you visit on the website and application, the time and date of your visit history, the links you click, whether you open emails or click the links contained in emails, whether you access the application from multiple devices, and the other actions you take resources you use through Zetty. Log file information is automatically reported to Zetty each time you Use Zetty.
Device Information. Information about your mobile device and internet connection, including your IP address, the device’s unique device identifier (including, for example, a persistent device identifier or an Ad ID), device type, model and specifications, operating system and version, application version, language, region, country and time zone, the other apps installed on your device and your mobile network information
Analytics Data. We use third-party analytics tools, such as Mixpanel, Google Firebase and Sentry to help us measure traffic, errors, User demographics, and usage trends for Zetty. These tools collect information sent by your device or Zetty, which includes your pseudonymised user ID and the information about Zetty web and application pages you visit when following the links available to you on Zetty, and your actions in the Zetty application. To learn more about the use of data collection technologies by Google for analytics and to exercise choice regarding those technologies, please visit the Google Analytics Opt-Out page.

4. INFORMATION WE COLLECT FROM THIRD PARTIES

In addition to the Personal Data collected above, we may also collect Personal Data from the following third-party sources:
Users: If you are the Chat Partner of a User, we may collect Personal Data about you in providing the Zetty Chat Analyzer service to the User, which could include any communications between you and the User and your use of the messenger chat provider, including account names, profile information, profile pictures and contact information, and all content and multimedia included in the chat, including text, images and video clips. If you would like to request the erasure of your Personal Data, please email hello@zetty.app with sufficient information to identify you and the User in our systems. We will honor your request in accordance with the terms of this Privacy Policy.
Social Media: If you choose to interact with us on social media, we may collect Personal data about you from the social media accounts that you make public. We use Personal Data collected in connection with your social media account to communicate with you, better understand your interests and preferences, and better understand our User base more broadly.
Service Providers: Our service providers, such as app store partners and marketing providers, collect Personal Data and often share it with us. For example, we receive Personal Data from the app store providers about the downloads of the application and to confirm a User’s subscription. We also receive information about the success of our email campaigns, including information about who has opened our marketing communications and when.
Information Providers: We may, from time to time, obtain information from third-party information providers to correct or supplement Personal Data we collect. For example, we may enrich the data we use with third-party information, such as demographic information or licensed chat data to better develop our services, including Zetty.
Publicly Available Information: We may collect Personal Data, including chat data from publicly available data sources, such as public websites, to help improve our business and services.

5. HOW WE USE COLLECTED INFORMATION

Messenger Chat History. We use messenger chat histories uploaded to Zetty to provide an analysis about the interaction and the sentiments expressed between Users and their Chat Partners. Please note that analyzing your chat history requires sophisticated computing resources to be performed, and as a result we may upload such data to the cloud providers we use (Google Cloud Platform and Amazon Web Services).
We will use messenger chat histories as part of the training set used to improve the deep learning model used in Zetty and the Company’s other services, including our chat bots. IF YOU ARE NOT COMFORTABLE OR DO NOT AGREE WITH THIS USE, OR YOU HAVE NOT OBTAINED THE CONSENT, AGREEMENT OR AUTHORIZATION FROM YOUR CHAT PARTNERS, PLEASE DO NOT UPLOAD MESSENGER CHAT HISTORIES TO ZETTY.
You can also always request that we delete your messenger chat histories by contacting us at hello@zetty.app.
Notwithstanding anything to the contrary elsewhere in this Privacy Policy:
We do not use your messenger chat histories for authentication, , or marketing purposes, or to otherwise target a user in a similar manner.
We do not use your messenger chat histories to attempt, facilitate, or encourage third parties to identify anonymous users or reconstruct user profiles based on your messenger chat histories.
We do not transfer, share, sell, or otherwise provide your messenger chat histories to advertising platforms, analytics providers, data brokers, information resellers or other such parties.
Other Information. We may use your Personal Data other than your messenger chat history for the following purposes:
To process your Zetty account registration and to remember you next time you visit the application. We do so to provide you with the services, in accordance with our contractual arrangement with you.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us in relation to Zetty, including our Terms of Use. We process your personal data as part of our contractual obligations.
To provide you with support and to respond to your inquiries. If you share your Personal Data (including your name and contact information) to ask a question about Zetty, we will use that Personal Data to investigate your concerns, respond to your inquiries and to monitor and improve our responses to your and other Users inquiries in relation to Zetty. It is our legitimate interest to provide you with high-quality support.
To notify you about changes to Zetty or any products or services we offer or provide through Zetty, including by sending you technical notices, notices about your account, including updates, security alerts and support and administrative messages, which we may send through an in-app or push notificationIt is our legitimate interest to keep you updated on your use of Zetty.
To help maintain the safety, security, and integrity of our service, technology assets, and business, and to diagnose or fix technology problems in relation to Zetty. It is our legitimate interest to maintain high security standards and good quality of the application.
To operate, maintain, and present to you and others with Zetty and its contents and any other information, products or services that you request from us. We do so to provide you with the services, in accordance with our contractual arrangement with you.
To automatically update Zetty on your device. We do so to provide you with up-to-date version of our application, which is our legitimate interest.
To monitor metrics such as total number of Users, traffic, and demographic patterns (including via Service Providers as specified in Section 7). It is our legitimate interest to analyze our audience as it helps us understand our business metrics and improve our product.
To provide, operate, improve, manage, test, and monitor the effectiveness of Zetty and our buisness. It is our legitimate interest to operate and grow our business.
To administer and manage or vendors and business partners, including the information technology and marketing vendors used in providing Zetty. It is our legitimate interest to ensure our vendors are supporting the smooth operation of our services.
To provide personalized content and information to you and others in relation to Zetty, which could include online ads or other forms of marketing (including via email). It is in our legitimate interest to promote our services.
To respond to law enforcement requests and as permitted by applicable law, court order, or governmental regulations or to comply with applicable laws and regulations. Doing so may be in our legitimate interests to protect our rights and rights and safety of others, or may be to comply with our legal obligations.
In any other way we may describe in this Privacy Policy.
We may also use aggregate or deidentified Personal Data in any manner such that we do not uniquely identify you or any other Zetty User.
In some cases, we may provide additional privacy disclosures where the scope of our processing of Personal Data falls outside the scope of this Privacy Policy. In that case, the additional privacy disclosures will govern how we may process the information you provide at that time.

6. YOUR ONLINE CHOICES

Online Advertising. We permit our trusted business partners and third-party advertising companies (including ad servers, ad agencies, or ad technology vendors, collectively “ad partners”) to collect your usage and device information to provide ads on our behalf that are tailored to your interests. These ads may appear on our website, and on other third-party websites. Using data collection technologies, our ad partners collect data from a particular browser or device about a User’s web viewing behaviors over time, across unrelated websites, and in some cases combine such data with data collected from other browsers or devices associated with the same User or household, and use such data to predict user preferences and to deliver advertisements to that user which are calculated to target that user’s predicted preferences across devices. If you take steps to block advertising technologies or opt out of interest-based advertising, note that this does not mean that you will no longer receive ads from Scatter Lab or Zetty, as these ads are only one form of digital advertising. Throughout our online advertising practices we support the self-regulatory principles of the Digital Advertising Alliance (“DAA”).
Your mobile device may include a feature ("Limit Ad Tracking" on iOS or "Opt Out of Ads Personalization" on Android) that allows you to opt out of having certain information collected through mobile apps used for behavioral advertising purposes. To further opt out of the use of your information by third party ad partners, you may download the DAA’s App-based Opt-Out Tool, which opts out of data processing by third parties enrolled in the DAA’s program. Please note that this opt-out is device-specific and will not be effective on your visits to the application from other devices.
Access, modification, correction and erasure. You can send us an email at hello@zetty.app to request access to, modification, correction, update, erasure or deletion of any Personal Data that you have provided to us and that we have about you. 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 not be able to provide, change or erase your information in all circumstances. Please keep in mind that in case of a vague access, erasure, objection request or any other request in exercise of the mentioned rights we may engage you in a dialogue to better understand the motivation for the request and to locate responsive information. In case this is impossible, we reserve the right to refuse granting your request.
Communications Preferences. If required by law, we will ask for your consent to send you promotional and marketing emails.
Email. If you wish to opt out of our promotional and marketing emails, you can opt out from our promotional and marketing email list by using any of the following methods:
by following the unsubscribe links in any marketing email sent to you; or
through Zetty settings on your mobile device; or
by contacting us at any time using the contact details in How to Contact Us Section.
Push Notifications. If you wish to opt out or limit the push notifications on your device, please go to the settings options on your device and amend the selections for Zetty under the ‘Notifications’ menu.

7. SHARING OF COLLECTED INFORMATION

We do not rent or sell your messenger chat history to any third parties outside the Company or its Affiliates (as defined below). Otherwise, we disclose Personal Data in the following ways:
Within the Company. We may share your Personal Data as well as other collected information (including but not limited to, information from cookies, log files, device identifiers and Usage data) with businesses that are legally part of the same group of companies that we are part of, including our subsidiaries, affiliates and those companies that become part of that group (“Affiliates”). Affiliates may use this information to help provide, understand, and improve Zetty (including by providing analytics). Such Affiliates are bound by the rules of this Privacy Policy.
Service Providers. We share your Personal Data and other collected information with third-party organizations such as contractors and service providers that we use to support our business and who are bound by confidentiality and data protection terms (consistent with this Privacy Policy) to keep your Personal Data confidential and use it only for the purposes for which we disclose it to them (and as directed and authorized by us) (“Service Providers”).
Such Service Providers include (i) cloud infrastructure and web hosting providers like Google Cloud Platform and Amazon Web Services, that we use to apply the chat analysis features of Zetty to your data and to store and delete such data, as described in this Privacy Policy, (ii) third-party analytics, as specified in this Privacy Policy, (iii) those that assist with fraud prevention, security and IT operational services, (iv) email and marketing delivery services and (v) professional advisors, such as lawyers, tax and accounting services, auditors and insurers, in the course of the professional services that they render to us.
Ad Partners. We share information with advertising networks or permit these partners to collect information from you directly on our application to facilitate online advertising, such as through search engines and social networks to serve targeted ads to you or to groups of other users who share similar traits, such as likely commercial interests and demographics, on third-party platforms. For more information of our ad partners, including how to opt out of interest-based advertising, please the Your Online Choices section above.
At Your Request. You may choose to share your activities on the applications with friends or publicly on various social media networks, which we may be able to send at your direction.
Business Transaction or Reorganization. If we sell or otherwise transfer part or the whole of the Company or our assets to another organization (e.g., in the course of a transaction like a merger, divestiture, restructuring, reorganization, acquisition, bankruptcy, receivership, dissolution, liquidation), your Personal Data and any other collected information may be disclosed to a third-party during negotiation of, in connection with or as an asset in such a corporate business transaction.
Responding to legal requests and preventing harm. We may access, preserve and share your information in response to a legal request (like a search warrant, court order or subpoena), or a government or regulatory request if we have a good faith belief that the law requires us to do so. This may include responding to legal, government or regulatory requests from jurisdictions outside of the United States where we have a good faith belief that the response is required by law in that jurisdiction, affects Users in that jurisdiction, and is consistent with internationally recognized standards. We may also access, preserve and share information when we have a good faith belief it is necessary to: (i) detect, prevent and address fraud and other illegal activity; (ii) protect the rights, interests health, safety and property of us, you and others, including as part of investigations or to enforce our Terms of Use; and (iii) prevent death or imminent bodily harm.
We may disclose aggregated information about our Users and information that does not identify any individual without any restriction. We may remove parts of data that can identify you and share deidentified data with any persons.

8. DATA RETENTION

We retain your Personal Data for as long as we need it for the purposes for which it was obtained or until you ask us to delete it.
Normally, the retention term would be the term of your account existence. It means that we will normally retain your Personal Data until you delete your account or request us to delete your data (by contacting us at hello@zetty.app). Please note that deletion of Zetty application does not mean deletion of your account!
We also may retain your Personal Data in connection with your privacy-related requests and communications with us, if any, as necessary to comply with our legal obligations, to defend against and resolve disputes, and to enforce our agreements. Even if we delete some or all of your Personal Data, we may continue to retain and use aggregate and deidentified data previously collected that can no longer be used for personal identification.

9. CROSS-BORDER TRANSFERS

The Company is based in the Republic of Korea. Accordingly, your Personal Data may be transferred to and stored in the Republic of Korea, United States or in other countries.
As to the location of our servers, we use Google Cloud Platform and Amazon Web Services servers located in the USA, while our analytics operations are processed both on the servers provided by Amazon Web Services (located in the USA) and by Google LLC (located in the Republic of Ireland).
For further information please contact hello@zetty.app.

10. CHILDREN PRIVACY

General age limitation. Zetty is not intended for or directed at children under 13, and we do not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons to Use Zetty. If you are under 13, do not: (i) Use or provide any information in Zetty or through any of its features, or (ii) provide any information about yourself to us, including your name, address, telephone number or email address. In the event that we learn that we have collected or received any Personal Data from a child under 13, we will delete that information as quickly as possible. If you believe we might have any information from or about a child under 13, please contact us (for contact information, please, see How to Contact Us Section).

11. THIRD PARTY WEBSITES AND SERVICES

Our website and application may include links to third-party websites, services, integrations, and applications. We are not responsible for the practices employed by any websites or services linked to or from Zetty, including the information or content contained within them. Where we have a link to a website or service, linked to or from Zetty, we encourage you to read the privacy policy stated on that website or service before providing information on or through it.

12. HOW TO CONTACT US

General contact details. If you have any questions about this Privacy Policy or Zetty, please contact us via email at hello@zetty.app or our mailing address:
Scatter Lab, Inc.
#901, #902
KD Tower 125, Wangsimni-ro
Seongdong-gu, Seoul
Republic of Korea

13. CHANGES TO OUR PRIVACY POLICY

The Company may modify or update this Privacy Policy from time to time. The date this Privacy Policy was last revised is indicated on the top of the page. Any changes or modifications will be effective immediately upon posting of the changes or modifications, and, to the extent permitted by law, retroactively to all Personal Data we have already collected. Your continued access to or use of the services after this Privacy Policy has been modified signifies your acknowledgement of the updated Privacy Policy. As a result, you should frequently review this Privacy Policy to ensure you are comfortable with our privacy practices.