Privacy Policy

IRIAM Inc. and its affiliates ("we," "our," and/or "us") value the privacy of individuals who use the IRIAM app and related websites and services provided by us (collectively, the "IRIAM Service"). This privacy policy (our "Privacy Policy") explains how we collect, use, and disclose information from users of the IRIAM Service ("Users") or their devices. By using or accessing the IRIAM Service, you agree to the collection, use, disclosure, and procedures our Privacy Policy describes. Beyond our Privacy Policy, your use of the IRIAM Service is also subject to our Terms of Service for User. All capitalized and undefined terms used herein, will have the meaning given to those terms in the Terms of Service for User.

If you are a California resident, please see our California Resident Privacy Notice for supplemental information and disclosures regarding rights of California residents.

If you choose to Broadcast content as a Broadcaster, please see our Biometric Privacy Notice for specific information about how we collect, use, disclose, retain, and destroy information regarding the movements of your facial features when you Broadcast as your avatar. Depending on your location, applicable laws might define the data used for facial animations as a biometric identifier or biometric information.

Information We Collect

We collect a variety of information from or about you or your devices from various sources, as described below.
If you do not provide your information when requested, you may not be able to use the IRIAM Service if that information is necessary to provide the IRIAM Service or if we are legally required to collect it.

1. Information You Provide to Us
   

Registration and Profile Information. To sign up for an IRIAM Account and use the IRIAM Service, we ask you for either (i) your log-in information for a third-party account, such as your X ID, Google ID, LINE ID or Apple ID (collectively “Social Media ID”) or (ii) your email address and a password. Please note that if you log in with an X ID, we will automatically collect and use your X profile information, such as your public profile image, username, access token and access token secret, and self-introductory statement, as your profile information on the IRIAM Service. We also ask you for your date of birth, location, and any associated Agency. When setting up your profile, you also may choose to provide a self-introduction, username, profile photo, header image, tags, TikTok ID, Twitch ID, YouTube ID, and other information. When you create an account as an employee on behalf of an Agency, we ask you for your name, company name, signature, company address, company email address, company phone number, company payment information and other information.

Broadcaster Information. If you choose to Broadcast content as a Broadcaster, in order to cash out any Diamonds that you receive during a Broadcast, we ask you for your payment information, such as your billing and bank account information as well as other information that we need to complete the transaction, such as your name, date of birth, address, and postal code. If you cash out Diamonds in excess of a certain dollar amount per day, we also may require certain government identification documents from you, such as a driver's license, state identification card, passport card, US military card (front and back), tax identification number, social security number, and/or Military dependent’s ID card (front and back).

As a Broadcaster, you must upload a static illustration to be used as your avatar when you Broadcast content. Using auto modeling technologies, we convert your facial expressions, like when you close your eyes, wink, open your mouth, or smile, into the expressions of your avatar. During this process, we collect your facial measurement data for the purposes described in our Biometric Privacy Notice. Depending on your location, applicable laws might define the data used for facial animations as a biometric identifier or biometric information.

Payment Information. To redeem Effects, purchase Points, or otherwise make payments through the IRIAM Service, a third-party service provider that handles payments for us will receive your payment information.

Communications Information. We receive information about you when you contact us and provide us with information directly. For example, when you contact us for customer support, we may receive your name, username, email address, the contents of a message or attachments that you may send to us, and other information you choose to provide. When you send us messages via the in-app messaging function of the IRIAM Service, we collect and store any messages you send. If you contact us regarding a billing issue, we may require you to provide additional information, such as a screenshot of your receipt, which contains the last four digits of your phone number, an order and/or document number, your phone carrier, address and postal code, and Apple ID.

Contests and Surveys Information. If you choose to participate in contests or sweepstakes, and if you subsequently win prizes, we may collect information about you, such as your name, username, address and postal code, phone number, information from your X account, and information from your IRIAM Account. If you choose to participate in our surveys, we may collect additional information about you, such as your name, age, occupation, gender, location (at the country level), information from your X account, information from your Discord account, username, User ID, mailing address, email address, username, survey responses, and other information you choose to provide.

2. Information We Collect When You Use the IRIAM Service

Device Information. We receive information about the device and software you use to download or access the IRIAM Service, such as User ID, unique device identifier, device model, locale, app version, carrier name, language/region settings, operating system name and version, mac Hash, internet protocol ("IP") address (from which we may infer your general location information), time zone and time zone offset, network type, mobile advertising identifiers, including IDFA, AdID, AAID, Android ID, IDFV, SSAID, Mobile ad ID, Widevine ID, and other online identifiers.

Usage Information. To help us understand how you use the IRIAM Service and to help us improve the IRIAM Service, when you use the IRIAM Service, we automatically receive information about your interactions with the IRIAM Service. Such information includes, but are not limited to, Broadcasts and content you watch, amount of time spent watching Broadcasts, your acts of supporting Broadcasters (such as a Star you send), hashtags and Effects used while watching Broadcasts, the number of Points and/or Diamonds in your possession, your level, follow and follower details, number of fan badges, mute and block details, in-app activity information during contests, in-app purchase information such as the dates, times, and amounts of your purchases, logs of your comments during Broadcasts, crash logs, the pages you request or search for, the pages and profiles you visit, and other information concerning usage.

If you are a Broadcaster, when you use the IRIAM Service, we automatically receive your Broadcasts, the times, dates, and durations of your use of the IRIAM Service, information about the number of Diamonds you hold, including the dates and times when the Diamonds were acquired and updated, Broadcaster rank and ranking history, the number of Users you are following and number of your followers, number of comments and likes you received, the number of Viewers who sent comments and likes to you, and the number of times Viewers have watched your Broadcasts, and other related information. In order for you to Broadcast as your avatar, we use tools provided by ARKit and OpenCV that run scans and collect facial measurement information. The information from these scans is used to make your avatar respond to your facial movements. Please refer to our Biometric Privacy Notice for additional information about how we collect, use, disclose, retain, and destroy your facial measurement information when you Broadcast on the IRIAM Service.

Information from Cookies and Similar Technologies. We and third-party partners collect information using cookies, pixel tags, or similar technologies. Our third-party partners, such as analytics and advertising partners, may use these technologies to collect information about your online activities over time and across different services. Cookies are small text files containing a string of alphanumeric characters. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the IRIAM Service.

Except for cookies strictly necessary for enabling us to provide the IRIAM Service, you have the option to disable cookies stored on your browser by changing the options in your browser to stop accepting cookies or to prompt you before accepting a cookie from the content you visit. Please note that if you delete or choose not to accept cookies from the IRIAM Service, you may not be able to utilize the features of the IRIAM Service to their fullest potential.

3. Information We Receive from Third Parties

Information from Third-Party Services. When you link the IRIAM Service to a third-party account, we receive information about you, including your username, screen name, profile information and your photo. We may receive additional information about you from third parties such as analytics providers or marketing partners and combine it with other information we have about you.

Information from Other Users. We may receive additional information about you from other Users of the IRIAM Service, including through customer support inquiries and from Broadcasters whose feeds you view.

How We Use the Information We Collect
We use the information we collect in accordance with the specific business and commercial purposes below:

• Providing the IRIAM Service: Provision of the IRIAM Service, a mobile application, and related websites and services, that allows Users to Broadcast through a virtual avatar and to watch and interact with other Broadcasters. We may use any of the categories of information described above for this purpose.

• Improving the IRIAM Service: Undertaking activities to verify or maintain the quality or safety of the IRIAM Service, and to improve, upgrade, or enhance the IRIAM Service, including undertaking internal research for technological development and demonstration. We may use any of the categories of information described above for this purpose.

• Personalization: Personalizing your experience on the IRIAM Service such as presenting tailored content. We may use your Registration and Profile Information, Communications Information, Device Information, Usage Information, Contests and Surveys Information, and Information from Cookies and Similar Technologies for this purpose.

• Debugging: Debugging to identify and repair errors that impair existing intended functionality. We may use your Registration and Profile Information, Communications Information, Device Information, and Usage Information for this purpose.

• Fraud and Incident Prevention, Safety Issues, and Compliance: Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, prosecuting those responsible for that activity, and responding to trust and safety issues that may arise. For compliance purposes, including determining whether Users have violated our Terms of Service for User or any of our other terms, enforcing our Terms of Service for User or any of our other terms or legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency. We may use your Registration and Profile Information, Communications Information, Device Information, Payment Information, and Usage Information for this purpose.

• Marketing: Marketing purposes, such as developing and providing promotional and advertising materials that may be useful, relevant, valuable or otherwise of interest to you. We may use your Registration and Profile Information, Information from Cookies and Similar Technologies, Contests and Surveys Information, Communications Information, Device Information, and Usage Information for this purpose.

• Communicating and Sending Messages: Communicating with you, sending you push notifications, providing you with updates and other information relating to the IRIAM Service, providing information that you request, responding to comments and questions, and otherwise providing customer support. We may use your Registration and Profile Information and Communications Information for this purpose.

• Providing Prizes to Contest Winners: Providing you with any prizes, if you choose to participate in our contests and win. We may use your Registration and Profile Information, Communications Information, and Contests and Surveys Information for this purpose.

• Facilitating Payments: Redeeming Effects, purchasing Points, converting Diamonds into payments in accordance with our Broadcaster Program Terms, or otherwise making payments. We may use your Registration and Profile Information, Broadcaster Information, and Profile Information and Payment Information for this purpose.

• Accounting Operations: Recording the amount of sales and other accounting related operations. We may use your Registration and Profile Information, Broadcaster Information, and Payment Information for this purpose.

• De-identification and Aggregation: De-identifying and aggregating information collected through the IRIAM Service and using it for any lawful purpose. We may use your Registration and Profile Information, Device Information, and Usage Information for this purpose.

• Contracting Vendors: Contracting with service providers to perform services on our behalf or on their behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling requests, verifying User information, processing payments or remittance, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services. We may use Registration and Profile Information, Broadcaster Information, Payment information, Communications Information, and Contests and Surveys Information, Device Information, Usage Information, Information from Cookies and Similar Technologies, Information from Third-Party Services, and Information from Other Users for this purpose.

• Enabling Transactions: Otherwise enabling or effecting, directly or indirectly, a commercial transaction. We may use Registration and Profile Information, Communications Information, and Payment Information for this purpose.

• Notified Purpose: For other purposes for which we provide specific notice at the time the information is collected.

We do not use profiling to make decisions that would significantly affect you.

How We Disclose the Information We Collect
We may disclose information we collect from or about you as described below or as otherwise disclosed to you at the time of collection.

Affiliates. We may disclose any information we receive to our parent company and other affiliates for any of the purposes described in our Privacy Policy. This information may include Registration and Profile Information, Broadcaster Information, Payment Information, Communications Information, and Contests and Surveys Information, Device Information, Usage Information, Information from Cookies and Similar Technologies, Information from Third-Party Services, Information from Other Users.

Vendors and Service Providers. We may disclose any information we receive with contractors, vendors, service providers, and other parties retained in connection with the provision of the IRIAM Service. This information may include Registration and Profile Information, Broadcaster Information, Payment Information, Communications, and Contests and Surveys, Device Information, Usage Information, Information from Cookies and Similar Technologies, Third-Party Services, Information from Other Users.

Other Users. The IRIAM Service is a social service in which you can find, enjoy, and share content. Registration and Profile Information, such as your username, profile picture, region, and self-introduction will always be viewable and searchable by other Users. If you Broadcast a performance, the performance will be viewable by Users who are watching the stream. If you post comments to a Broadcaster’s stream, your username and comments will be viewable by others, including other Users who are watching the same stream and that Broadcaster. We are not responsible for how Broadcasters or other Users use or disclose available information, so you should carefully consider whether and what to post or how you identify yourself on the IRIAM Service.

Analytics Partners. We use analytics services such as Google Analytics to collect and process certain analytics data. Our analytics partners collect information about you and your device, including your Registration and Profile Information, Device Information and Usage Information. These services may also collect information about your use of other websites, apps, and online resources. You can learn about Google’s practices by going to https://www.google.com/policies/privacy/partners/, and opt-out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

Advertising Partners. We work with third-party advertising partners to show you ads that we think may interest you. These advertising partners may set and access their own cookies, pixel tags and similar technologies on the IRIAM Service and they may otherwise collect or have access to information about you that they may collect over time and across different online services. For this targeted advertising purpose, we may disclose Device Information, Usage Information, and Information from Cookies and Similar Technologies.

Our third-party advertising partners may collect information about you and your device, including your: Device Information, such as your mobile advertising identifier (IDFA, AdID, AAID, etc.), internet protocol (“IP”) address, and similar information about the device and software you use to download or access the IRIAM Service; and Usage Information, such as information about your activity on the IRIAM Service. Some of our advertising partners are members of the Network Advertising Initiative (http://optout.networkadvertising.org/) or Digital Advertising Alliance (http://optout.aboutads.info/). If you do not wish to receive personalized ads, please visit their opt-out pages to learn about how you may opt out of receiving web-based personalized ads from member companies.

Agencies. If you are a Broadcaster represented by an Agency, we disclose your information to such Agency for the purposes of managing your relationship with them. This information may include Registration and Profile Information, Usage Information and Broadcaster Information.

Third Parties as Required by Law and Similar Disclosures. We may access, preserve, and disclose any information about you to third parties if we believe doing so is required or appropriate to: (a) comply with law enforcement requests and legal process, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, or safety. This information may include Registration and Profile Information, Broadcaster Information, Payment Information, Communications Information, and Contests and Surveys Information, Device Information, Usage Information, Information from Cookies and Similar Technologies, Information from Third-Party Services, and Information from Other Users.

Third Parties in Merger, Sale, or Other Asset Transfers. We may disclose and transfer any information about you to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our business or assets. This information may include Registration and Profile Information, Broadcaster Information, Payment Information, Communications Information, and Contests and Surveys Information, Device Information, Usage Information, Information from Cookies and Similar Technologies, Information from Third-Party Services, and Information from Other Users.

Consent. We may also disclose any information from or about you or your devices with your permission.

Privacy Rights
Depending on your U.S. state residency, you may, at any time, exercise certain rights, as described below:

California Residents. If you are a California resident, subject to certain exceptions, you may exercise certain rights by submitting requests to know and access the personal information (as defined by the California Consumer Privacy Act) that we have collected about you, to delete personal information, to opt out of the sale of personal information and/or sharing of personal information for cross-context behavioral advertising purposes (please click here for our Notice of Right to Opt-out of Sale/Sharing), to correct inaccurate personal information about you, and to limit the use or disclosure of your sensitive personal information. You have the right to not be discriminated against for exercising these rights, subject to certain exceptions. Please visit our California ResidentPrivacy Notice for supplemental information and disclosures regarding rights of California residents.

Colorado, Connecticut, Virginia, and Utah Residents. If you are a Colorado, Connecticut, Virginia, or Utah resident, you may exercise the following rights via IRIAM application by going to "My Page", tapping on "Settings" -> tapping on "Feedback and Inquiries” to send your request or by contacting us using the details provided in the “Contact Information” section below. You may make a request to exercise the following rights with respect to your personal data (as defined in the privacy law applicable to your state of residence):

• To confirm whether or not IRIAM processes your personal data and request access to such data;
• To delete personal data you have provided to IRIAM;
• To opt out of the processing of your personal data for purposes of: (i) targeted advertising; and (ii) the sale of personal data. You may exercise your right to opt out of the processing of personal data for targeted advertising and sale of your personal data by clicking here. Please note that if you are using iOS version 14.5 or later and have chosen to not allow App Tracking Transparency, your IDFA will not be shared with advertising partners, even if you do not opt out of the processing of personal data for targeted advertising and sale of your personal data; and
• To obtain a copy of your personal data in a portable and, to the extent technically feasible, readily usable format.

Residents of Virginia, Colorado, and Connecticut may additionally:

• Request to delete personal data obtained about you from sources other than IRIAM;
• Request to exercise your right to correct inaccuracies in your personal data;
• Opt out of the processing of your personal data for certain types of profiling in furtherance of decisions that produce legal or similarly significant effects. Please note that we do not engage in such profiling; and
• Appeal any decision with regard to your privacy request by contacting us using the details provided in the “Contact Information” section below.

If you are acting as an authorized agent to make a request on behalf of a user, please contact us via the Contact Information section and attach a written authorization signed by the user.

Please note that there are exceptions and limitations to each of the rights listed above. Also, while any changes to your personal data in our active user databases will be reflected within a reasonable period of time, we may retain certain information for backups, archiving, prevention of fraud and abuse, analytics, legal and compliance obligations, or as otherwise permitted under applicable law.

Biometric Privacy Notice

This Biometric Privacy Notice explains how we collect, use, disclose, retain, and destroy Biometric Data when you Broadcast on the IRIAM Service.

"Biometric Data" includes: (i) "Biometric Identifiers," which are data generated by measurements of your biological characteristics, such as your retina or iris scan, fingerprint, voiceprint, or a scan of your hand or face geometry; and (ii) "Biometric Information," which is information based on a Biometric Identifier that can be used to identify you.

Please review this Biometric Privacy Notice carefully. Before you Broadcast on our IRIAM Service, you must check the box in the pop-up to provide your consent for the collection, use, disclosure, retention, and destruction of your Biometric Data as described in this Biometric Privacy Notice. If you do not agree to the practices in this Biometric Privacy Notice, do not Broadcast on the IRIAM Service.

What type of Biometric Data do we collect?
Facial measurement information.

How do we collect, use, and disclose it?
In order for you to Broadcast as your avatar, we use tools provided by ARKit and/or in-camera functions of your device that run scans and collect your Biometric Data (e.g., measurements of your facial features, such as the degree to which your eyes open or your mouth closes). The information from these scans is used to make your avatar respond to your facial movements and expressions, like when you close your eyes, wink, open your mouth, or smile so that the avatar’s face moves just like yours. In addition, we use this Biometric Data to verify or maintain the quality of the IRIAM Service, to verify any potential malfunctions, and to otherwise improve the IRIAM Service.

We do not use the Biometric Data to identify you personally. We may disclose Biometric Data to our cloud database providers, such as Google for purposes of storing such data, to our parent company or affiliates, to any acquirer, successor or assignee, or where required by applicable law.

How long do we retain your Biometric Data?
We do not retain your facial measurement data longer than necessary to fulfill the purpose described above, unless there are legal requirements to delete it earlier or to keep it for a longer period (such as pursuant to a warrant or subpoena).

What happens to your Biometric Data at the end of the retention period?
When the retention period ends, your Biometric Data is permanently destroyed.

Data Retention

We take measures to delete your information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it, unless we are required by law to keep this information for a longer period. When determining the retention period, we take into account various criteria, such as the type of products and services requested by or provided to you, the nature and length of our relationship with you, the impact on the IRIAM Service we provide to you if we delete some information from or about you, mandatory retention periods provided by law, and any relevant statute of limitations.

Third Parties

The IRIAM Service may contain links to other websites, products, or services that we do not own or operate. We are not responsible for the privacy practices of these third parties. Please be aware that our Privacy Policy does not apply to your activities on these third-party services or any information you disclose to these third parties. We are not responsible for the privacy practices or the content of such sites. If you have any questions about how these other sites use information from or about you, you should contact them directly. We encourage you to read their privacy policies before providing any information to them.

Security

We make reasonable efforts to protect information from or about you by using technical and organizational safeguards designed to improve the security of the information we maintain. However, as the IRIAM Service is hosted electronically, we can make no guarantees as to the security or privacy of your information.

Children’s Privacy

We do not knowingly collect, maintain, or use personal information from children under 18 years of age, and no part of the IRIAM Service is directed to children. If you learn that a child has provided us with personal information in violation of our Privacy Policy, please refer here and alert us.

International Visitors

The IRIAM Service data is hosted in Japan and the United States. If you choose to use the IRIAM Service from the European Union or other regions of the world, then please note that you are transferring information from or about you or your devices outside of those regions to Japan and the United States for storage and processing. Also, we may transfer your data from Japan and/or the United States to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the IRIAM Service and your data may be accessible to law enforcement and national security authorities outside of your country of residence. By providing any information, including information from or about you or your devices, on or to the IRIAM Service, you consent to such transfer, storage, and processing.

Changes to Our Privacy Policy

Our Privacy Policy may be revised from time to time. We will post any adjustments to our Privacy Policy on this page, and the revised version will be effective as of the last updated date. If we materially change the ways in which we use or disclose information from or about you or your devices previously collected from you through the IRIAM Service, we will make reasonable efforts to notify you of the changes by sending a notice to the primary email address that we have to contact you and/or by placing a notice on the IRIAM Service.

Contact Information
If you have any questions, comments, or concerns about our processing activities, please refer here and contact us at support@iriam.com.