This policy describes the information we collect in order for The Ethos Network (“ETHOS”) to provide its services (“Services”) to you and what we do with that information. This document runs in line with our Terms of Service (the “Terms”) and Community Guidelines (“Community Guidelines”) documents (collectively referred to as the “Documents”).

Please do not hesitate to get in contact with us regarding any queries!

1. Who is responsible for processing your personal data?

It’s The Ethos Network Ltd. We are an English company and our head office is at 25 Finsbury Circus, EC2M 7EA, London, England.

The Ethos Network Ltd publishes the ETHOS App, a social network for Gen Z to connect with the content that they care about.

2. The data we collect

To provide our Services, we collect the information (i) which you provide to us directly, as well as (ii) data which we collect automatically, within the territory where we provide our services and where the user is located.

(i) Data you provide to us directly

Registration data: in order to be able to use the ETHOS App, you must create an account and provide us with the following personal details:

• Your mobile number (which is not shared with other users)
• Your name (visible to other users)
• Your profile picture or avatar (visible to other users)

All the foregoing information is mandatory in order for you to create your profile and to register on the ETHOS App. You may, if you so wish, complete other sections of your profile (bio, background picture…). This information is optional.

Data concerning your interaction with ETHOS : if you report a problem to us, request help or exercise your rights, we will process the information you provide to us. All content, communications, interactions and information sent directly to us via the Services, phone, email or postal services.  

Data concerning content: the content that you decide to upload to your profile will be visible to all users, unless you have a private profile. If you have a private profile the content you upload will only visible to the users you have accepted.

In the case of comments or reactions to other posts, those will be visible to everyone, regardless of wether you have a private profile or not. We collect the content related to User Submissions including the metadata of any photo or file that you decide to share. When applicable, the location we get is the one you associate to the post as part of the additional information related to the User Submission. We do not have access to your actual location, we can only see the one you have assigned.

Be careful what you share with others and don’t forget that all users can save the content you share and that we cannot do anything to stop this and therefore bear no liability for any loss or damage related to it.

Cameras and photos: in order to be able to send and upload your photos from your camera, you must give us permission to access them. Camera access will be limited to the time you use the camera as an ETHOS App functionality. Photo gallery access is limited to the pictures/videos you decide to post, when you choose to do a post that includes multimedia.

ii) Data we collect automatically

Data concerning your activity on the Services: when you use the Services, we can collect and process information such as the date you register, the date you last logged in, your interactions with other users and your posts. These data points are used by us to make features of the app better for the user, and also to help us market the app to the right user. For example, we use the time between registration and making your first post to target the most engaged users correctly.

Data concerning devices and hardware: we collect information from and on the devices and hardware you use to access the Services such as your IP address, your device type, advertising identifier (e.g., Google’s AAID and Apple’s IDFA, both of which are randomly generated numbers that you can reset by going to your device settings), application bugs, version and language, operating system, etc. The traffic sources that brought you to the app are also collected to help us optimise our user acquisition.  Authentication, SSL and exception management measures – these would be used for security purposes only.

3. What are the legal reasons why we collect data?

We will only use your personal data when the law allows us to. The General Data Protection Regulation (GDPR) imposes strict rules for the collection and the processing of personal data, in particular the principles of lawfulness/fairness/transparency, purpose limitation, data minimisation, accuracy, storage limitation, integrity/confidentiality and accountability. Most commonly we will use collect or share your personal data in the following circumstances:

• In order to fulfil our Terms.
• Legitimate interest: means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience.
• Consistently with your consent – at any time you have the right and ability to revoke this through the settings on the app or by getting in touch with us.
• To protect your vital interests, those of others, or the public’s interest.
• To comply with a legal obligation and as necessary for our (or others’) legitimate interests.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. This stands unless those interests are overridden by your interests or fundamental rights and freedoms that require the protection of personal data.

4. How we use the data

The data we collect as specified in section 2 is used and analysed only in order for us to develop and improve our Services (subject to any choices you make) as describe below:

Access to the ETHOS App and Communications:

• To create and manage your user account (including access to ETHOS services and Help).
• To send information messages concerning the Services and your interactions with other users (Notifications) and inform you of different ways to use the Services.
• To get in touch with news on any updates to the Services. We will also use it if you get in touch with us, in order to reply.

 Providing, Personalising and Making the Services better:

• Information related to your devices and to your usage patterns will be used by us anonymously in analysing our Services and helping us to improve our services. It will give us a direction on how to research more into our Services, test them and improve them.
• Use the data to enforce our Terms, Community Guidelines, and policies. This may include removing content or suspending or banning your account if we determine that you are violating our Terms or Community Guidelines.

Security and fulfilment of legal and contractual obligations;

• To respond to requests from and fulfil the requirements of applicable laws, administrative and judicial authorities, law enforcement officials and legal officers, and to abide by court decisions;
• To identify and prevent fraudulent activity and threats to the security of the Services pursuant to and in accordance with the law;
• To analyse reports concerning users who have breached our Terms of Service and/or our legal rights;
• To improve the safety and security of our services;
• To enforce or defend our legal rights, including our rights under our Terms of Service and this Privacy Policy;
• To counter fraud and fight against any use of the Services that is illegal or contrary to our Terms. We take measures to detect inappropriate content. Posting such content is a violation of our Terms of Service, and we may remove it and suspend or ban users who post it.

5. How long do we keep your data for?

You can delete your account at any time by clicking on the relevant button in ‘Settings’. When you delete your account, you will no longer be able to use the Services, and your profile will no longer be accessible.

We will only keep your data for the period of time required to fulfil the purposes for which we collected it, unless we are permitted or required by law to keep it for a longer period of time. Information other users have shared about you will not be erased. Please keep in mind too that search engines and other third parties may still retain copies of your public information, even if you have deleted your account.

Generally, we will delete your data as soon as you delete your account, unless:

• We are required to retain it as proof that we comply with the legislation in force (e.g. recordings of consent to our Terms of Service, Privacy Policy, and other similar consents are retained for five years);
• We need the information to resolve a dispute or exercise or defend our legal rights;
• We must retain the data consistent with our legitimate commercial interests, for example in order to prevent fraud and improve users’ safety and security. For example, we may be required to retain data in order to prevent a user who has been banned from opening a new account due to their illegal or dangerous conduct or a security incident.

Our use of your information at all times will remain in line with this Privacy Policy. To exercise your rights, please get in contact with us and we will get back to your enquiry within 28 days.

6. Who has access to the data we collect?

Integrations in analytics services:We use secure analytics to analyse the information we collect (as mentioned in the first section of this Privacy Policy) to see how you interact with our Services.

Service Providers: We may share any of the categories of Personal Data described in Section 2 of this Privacy Policy with service providers to help us operate and improve the Services. For example, we may use service providers to host Personal Data and/or the Services; study or analyse the use and/or operation of the Services; detect and mitigate fraud or abuse of the Services; and provide assistance requested by users.

Researchers and academics: We retain the right use the information we state we collect to give to researchers or academics. In the case that this situation should arise, we would seek to inform all our users of this 30 days prior to it taking place and allow the option to opt out. The purpose of this would be to improve our policies and make studied decisions with regards to moderation on the platform and ensure that whilst a safe environment is being created individual freedoms are optimised.

Legal entities and public safety: We retain the right to share selected pieces of data that we state we collect with law enforcement for as long as this remains in a closed confidential loop to comply with legal obligations; in response to lawful orders or requests; to protect the safety of any person; to preserve the security and integrity of the Services or to protect the rights or property of us or other users of the Service.

Change of Ownership:  If we are involved in a bankruptcy, merger, acquisition, reorganisation, or sale of assets, we may sell or transfer your Personal Data as part of that transaction. This Privacy Policy will continue to apply to Personal Data transferred to the new entity.

7. How is your data protected?

The Ethos Network Ltd uses technical and organisational measures to protect data loss, misuse, alteration and erasure.

8. Your Rights

Under the General Data Protection Regulation (GDPR), you have the right to request access to, rectify, object to, transfer and delete your data. If you wish to exercise any of the rights set out above, please contact us at the details below. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.

Alternatively, we could refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights).

This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

9. Children and our Services

Our Services are not directed to children under the age of 13. If you are between the ages of 13 and 17, we may require your parent or legal guardian to consent to your use of the Services.

10. Changes to This Policy

We keep this Privacy Policy under regular review and will publish any updates we perform on our website. We will do our best to notify the users 30 days prior to the change and you they have the opportunity to review the revised policy before choosing to continue using our Services.

11. Contact

Should you wish to contact us about anything in relation to this privacy policy, please email us at team@theethosnetwork.com or by post to:

The Ethos Network Ltd

25 Finsbury Circus
EC2M 7EA
London, England