Privacy Policy Have a good reading Effective: May 23, 2018

Threader is a freemium Service provided by MANY SAS (“we” or “us” or “our”). This privacy policy (this “Privacy Policy”) governs and describes how Threader may collect, use, and disclose personal information that we obtain through or from: Our iOS app available through the App Store, our website.

If you choose to use our Service, then you agree to the collection and use of information in relation to this policy. The Personal Information that we collect is used for providing and improving the Service. We will not use or share your information with anyone except as described in this Privacy Policy.

The terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, which is accessible at Threader unless otherwise defined in this Privacy Policy.

1. Data Controller and Owner
Threader by Many SAS, 3 boulevard de Sébastopol, 75001 Paris, France Contact email: contact@threader.app

2. Types of Data collected
We may collect information about you in a variety of ways. These information may include: data from your social networks, cookies, usage data and email address. Other Personal Data collected may be described in other sections of this privacy policy or by dedicated explanation text contextually with the Data collection.

The types of personal information we collect depend on which of our Services you use (iOS application and/or website). The Personal Data may be freely provided by the User, or collected automatically when using this Application.

Any use of Cookies - or of other tracking tools - by this Application or by the owners of third party services used by this Application, unless stated otherwise, serves to identify Users and remember their preferences, for the sole purpose of providing the service required by the User.

Unless specified otherwise, all the information requested by the Service is mandatory and failure to provide this information may make it impossible for the Service to provide its services. In cases where the Service specifically states that some information is not mandatory, you are free not to communicate this information without consequences to the availability or the functioning of the Service.

Users who are uncertain about which Personal Data is mandatory are welcome to contact Threader.

Users are responsible for any third-party Personal Data obtained, published or shared through the Service and confirm that they have the third party's consent to provide the Data to the Owner.

3. The use of the collected Data
The Data concerning the User is collected to allow the Owner to provide its services, as well as for the following purposes: - Registration and authentication.
- Manage the User access to its services.
- Access to third-party services’ accounts.
- Analytics.
- Hosting and backend infrastructure.
- Sending messages to the user (notifications, emails).
- Social features.
- Improve its services.
- Carry out obligations and enforce our rights that arise from any contracts entered into between the User and the Owner, including billing.
- Notify the User about changes to its services.
- Provide the User with information requested from us.
- Send promotion information and other communications regarding its services.
- Assemble statistics regarding the use of its services.
- Prevent fraud or abuse.
- For any other reason with the User consent.

4. Mode and place of processing the Data
Methods of processing
The Data Controller processes the Data of Users in a proper manner and shall take appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.

The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Data Controller, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of the site (administration, sales, marketing, legal, system administration) or external parties (such as third party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Data Controller at any time.

Place
The Data is processed at the Data Controller's operating offices and in any other places where the parties involved with the processing are located. For further information, please contact the Data Controller.

Retention time
The Data is kept for the time necessary to provide the service requested by the User, or stated by the purposes outlined in this document, and the User can always request that the Data Controller suspend or remove the data.

5. Disclosure of the Data collected
Threader may share the User personal information with certain third-parties. This sharing is based on the Owner relationship with those third-parties, the User consent, or legal or contractual obligations that require the Owner to share such information. Threader may share the User personal information that we collect or the User provides as follows:
- To contractors, service providers such as Stripe, and other third-parties we use to support our business. These entities are bound by contractual obligations to keep personal information confidential and can use it only for the purposes for which we disclose the information to them.
- 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 Threader’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by Threader about our Service users is among the assets transferred. The User will be notified via email and/or a prominent notice on our Websites of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information. To enforce or apply our Terms of Service and other subscription agreements, including for billing and collection purposes. If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Threader, our subscribers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction. For any other purpose disclosed by us when you provide the information. With your consent. We may also disclose aggregated information about our users, and information that does not identify any individual, without restriction.

6. Detailed information on the processing of Personal Data

The Personal Data used for each purpose is outlined in the specific sections of this document.

Access to third-party accounts for registration
The User can create an account on Threader using its Twitter account or its Facebook account. Both services allow Threader to:
- Access some of its account information. Threader only stores its name, username, email address and url of its profile picture.
- Perform actions with it. With the User consent, Threader can share content on both platforms and follow a Twitter user.
These services are not activated automatically and require explicit authorization by the User.

Facebook
This Application may ask for some Facebook permissions allowing it to perform actions with the User's Facebook account and to retrieve information, including Personal Data, from it. The permissions asked are the following:
- Email: gives access to the User’s contact email address.
- Public profile: gives access to basic information like the name and the profile picture of the User.
For more information, see their Privacy Policy - Privacy Shield participant.

Twitter
This application may ask for some Twitter permissions allowing it to perform actions with the User’s Twitter account and to retrieve information, including Personal Data, from it. The permissions asked are the following:
- Read and write access to Twitter resources: includes the ability to read a user’s Tweets, home timeline, and profile information; and to post Tweets, follow users, or update elements of a user’s profile information. It does not allow access to read or send Direct Messages.
- Request email address: when authorizing an application, the user will also be informed that the application may request visibility of any email address associated with the account.
For more information, see their Privacy Policy - Privacy Shield participant.

Financial information
We use Stripe, a third-party processor, to process payments made to us. Threader does not store any personally identifiable information or any financial information such as credit card numbers. For more information, see their Privacy Policy - Privacy Shield participant.

Analytics Cookies and usage data: Threader uses different third-party services to monitor and analyze the traffic and the behavior of the users. Threader uses:
- Simple Analytics on the website. - Firebase and Crashlytics on the iOS app.
We don’t store any personal information.

a) Simple Analytics
Simple Analytics is a privacy-friendly analytics. For more information, see their Privacy Policy - Privacy Shield participant.

b) Firebase Services

Firebase Services is Google’s mobile platform.
Firebase Analytics for Firebase
Firebase Analytics is a cost-free app measurement solution that provides insight into app usage and user engagement.
For more information, see their Privacy Policy - Privacy Shield participant.

Firebase Cloud Messaging for Firebase
Firebase Cloud Messaging is a cross-platform solution for messages and notifications for Android, iOS, and web applications.
For more information, see their Privacy Policy - Privacy Shield participant.

Crashlytics
Crashlytics, a business division of Google Inc., offers a suite of services to provide mobile application developers with information about the functioning of publicly released and beta versions of their mobile applications. Threader uses Crashlytics to get information about the crashes occurring on its Services and be able to fix them. For more information, see their Privacy Policy - Privacy Shield participant.

Answers
Crashlytics’ products and services include “Answers,” which is a software development kit and associated services focused on analysis and computation of the behavior and usage of mobile applications, including app analytics, event tracking, and conversion tracking. For more information, see their Privacy Policy - Privacy Shield participant.

Notifications
We may request to send you push notifications with your consent. Threader uses Firebase Cloud Messaging to deliver them. If the user wish to opt-out, the User may turn them off its profile on our iOS app or on its phone settings.

Firebase Cloud Messaging
Firebase Cloud Messaging, part of Google API Services, is a messaging solution that lets you reliably deliver notification messages. For more information, see their Privacy Policy - Privacy Shield participant.

Mailing list
By subscribing to Threader or to our mailing list, the User email address may be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning Threader.

SendGrid
We use MailChimp, a marketing platform, to handle our email campaigns and our subscribers lists. For more information, see their Privacy Policy - Privacy Shield participant.

Displaying content from external platforms
This type of service allows the User to view content hosted on external platforms directly from the pages of Threader and interact with them. This type of service might collect web traffic data for the pages where the service is installed, even when Users do not use it.

YouTube video widget (Google Inc.)
YouTube is a video content visualization service provided by Google Inc. that allows Threader to incorporate content of this kind on its website. They may collect Personal Data. For more information, see their Privacy Policy - Privacy Shield participant.

AWS
AWS is a subsidiary of Amazon.com, Inc. It is a cloud storage service that allows the Service to store and display all types of media, including images. They may collect Personal Data. For more information, see their Privacy Policy - Privacy Shield participant. Application deployment

Heroku
Heroku is a platform as a service (PaaS) that enables developers to build, run and operate applications entirely in the cloud. They may collect Personal Data. For more information, see their Privacy Policy - Privacy Shield participant.

7. Additional information about Data collection and processing

Legal action
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of the Service or the related Services. The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data
In addition to the information contained in this privacy policy, the Service may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance
For operation and maintenance purposes, the Service and any third-party services may collect files that record interaction with the Service (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from Threader at any time. Please see the contact information at the beginning of this document.

The rights of users
Users have the right, at any time, to know whether their Personal Data has been stored and can consult the Data Controller to learn about their contents and origin, to verify their accuracy or to ask for them to be supplemented, cancelled, updated or corrected, or for their transformation into anonymous format or to block any data held in violation of the law, as well as to oppose their treatment for any and all legitimate reasons. Requests should be sent to the Data Controller at the contact information set out above.

How “Do Not Track” requests are handled
The Service does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy
We reserve the right to make changes to this Privacy Policy at any time and for any reason. We will alert you about any changes by updating the “Revised” date of this Privacy Policy. Any changes or modifications will be effective immediately upon posting the updated Privacy Policy on the Site. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the Service after the date such revised Privacy Policy is posted.

Children’s Privacy
Users declare themselves to be adult according to their applicable legislation. Minors may use the Service only with the assistance of a parent or guardian. Under no circumstance persons under the age of 13 may use the Service.

In the case we discover that a child under 13 has provided us with personal information, we immediately delete this from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we will be able to do necessary actions.

Links to Other Sites
This Service may contain links to other sites. If you click on a third-party link, you will be directed to that site. Note that these external sites are not operated by us. Therefore, we strongly advise you to review the Privacy Policy of these websites. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

Legal information
This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation). This privacy policy relates solely to this Service, if not stated otherwise within this document. Latest update: May 25, 2018

8. Definitions and legal references
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

Usage Data
Information collected automatically through the Service (or third-party services employed in the Service), which can include: the IP addresses or domain names of the computers utilized by the Users who use the Service, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.

User
The individual using the Service who, unless otherwise specified, coincides with the Data Subject.

Data Subject
The natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of the Service. The Data Controller, unless otherwise specified, is the Owner of the Service. the Service The means by which the Personal Data of the User is collected and processed.

Service
The service provided by the Service as described in the relative terms (if available) and on this site/application.

European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Cookies
Small sets of data stored in the User's device.