PRIVACY STATEMENT
Last modified: Feb 21st 2023
Verified Mobile, Inc. (“Verified Mobile,” “us,” “our,” or “we”) respects your privacy and is committed to protecting it through our compliance with this Privacy Statement. This Privacy Statement describes the types of information we may collect when you visit or use the ConsentFirst™ mobile application (“Application”) and services provided to you by Verified Mobile, and our practices for collecting, using, maintaining, disclosing, and protecting that information. The Application and all Verified Mobile services available through the Application are collectively referred to in this Privacy Statement as the “Services.”
The ConsentFirst Application allows registered users of the Services (each, an “App User”) to signify explicit consent before engaging in sexual activity with another App User. The Application makes it easy to confirm that both partners have consented by requiring each partner to state and record their name and safe word before engaging in sexual activity (each, a “Consent Agreement”) and allows either partner to change their mind or report violations. Each Consent Agreement you enter into consists of three components: (1) a voice recording by each partner stating their name and a safe word that can be used by either partner to stop the activity (“Voice Signature”); (2) an audio-only recording of the interlude between each partner providing their Voice Signature (to confirm there is no cohesion) (“Interlude Recording”); and (3) an audio-only recording of the sexual activity session (“Session Recording”).
California Residents
Verified Mobile’s Supplemental Privacy Statement for California Residents supplements the information contained in this Privacy Statement and applies solely to visitors, users, and others who reside in the State of California.
Information Collection, Use, and Sharing
The only personal information about you that we collect is information you voluntarily give us or information that is generated through or in connection with your use of the Services. This information may include:
Information you provide when you register with our Services, such as your name, physical address and email address, date of birth, gender, and driver’s license or state identification number.
Information regarding your Services-related purchases and transactions, such as purchases made and transaction dates.
Information generated through your use of our Services, such as the terms of your Consent Agreements, Voice Signature, consent IDs, consent dates, and consent histories and recordings.
Information provided to us by our third party partners, such as our background check and identification verification partners and mobile app stores.
Records and copies of your correspondence, including email address, if you contact us.
Details of any other transactions or activities you carry out through our Services.
When you download, access, and use our Application, it may use technology to automatically collect:
Usage Details. When you access and use the Application, we may automatically collect certain details of your access to and use of the app, including traffic data, location data, logs, and other communication data and the resources that you access and use on or through the Application.
Device Information. We may collect information about your mobile device and internet connection, including the device’s unique device identifier, mobile device advertising identifier, operating system, browser type, and mobile network information.
Stored Information and Files. The Application also may access metadata and other information associated with other files stored on your device. This may include, for example, photographs, audio and video clips, personal contacts, and address book information.
Location Information. Our Application may collect real-time information about the location of your device, subject to your consent.
If you do not want us to collect this information do not download our Application or delete it from your device.
We will only use your personal information (i) for the purpose you provided it, such as to present the Services and its content to you, to administer and maintain your account and consents, and to verify your identity; (ii) to notify you about Verified Mobile products and services; (iii) for security or fraud prevention purposes; (iv) to improve the content, functionality, and usability of our Services; (v) to comply with any court order, law or legal process, including to respond to any government or regulatory request; and (vi) for the purpose of aggregated statistical analysis regarding how you and others use our Services. For any other use, we will first obtain your explicit consent. We will not sell or rent your personal information to anyone.
We will not disclose your personal information to any third party outside of our organization, other than:
To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it 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 Verified Mobile’s assets, whether as a going concern or as part of a bankruptcy, liquidation or similar proceeding, in which personal information held by Verified Mobile about our users is among the assets transferred.
To App Users that are parties to your Consent Agreements, provided that we will only share Interlude Recordings and Session Recordings pursuant to a warrant or subpoena.
To enforce or apply our Terms of Use and other agreements, as well as your Consent Agreements entered into using the Services.
To fulfill the purpose for which you provide it or for any other purpose disclosed by us when you provide the information.
To comply with any court order, law or legal process, including to respond to any government or regulatory request.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of our Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection.
With your consent.
Accessing and Correcting Your Information
You can review and change your profile information by logging into the Application and visiting your account profile page.
You may also send us an email at info@ConsentFirst.app to request access to, correct, or delete any personal information that you have provided to us. We may not be able to delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement, cause the information to be incorrect, or violate the rights of other parties (including other App Users with whom you enter into a Consent Agreement).
If you delete your Consent Agreements from the Services, copies of your Consent Agreements may remain viewable in cached and archived pages, or might have been copied or stored by or accessible to other users of our Services with whom you enter into Consent Agreements. Proper access and use of information provided through the Services is governed by our Terms of Use https://ConsentFirst.app/eula.
California residents may have additional rights and choices. Please see our Supplemental Privacy Statement for California Residents for more information.
Security
We have implemented reasonable measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewall.
The safety and security of your information also depends on you. Where you have chosen a password for access to our Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services.
Data Retention
We retain your account information, including email address, password, and consent histories for as long as you maintain your account with us. Your consent histories include your name (unless you purchase anonymity services through the Application), consent IDs, Consent Agreement dates, and the name of the other App User(s) party to your respective Consent Agreements (unless they purchase anonymity services through the Application).
We retain each Consent Agreement (including Voice Signatures, Interlude Recordings, and Session Recordings) for 24 hours following the recording of the respective Session Recordings, unless a longer retention period is purchased through the Application (e.g., 90 days or 1 year).
We do not store or maintain information collected specifically for identify verification purposes, including your physical address, date of birth, gender, and driver’s license or state identification number. Instead, this information is immediately sent to our identity verification service provider(s) in order to verify your identity and create your account.
Individuals Under the Age of 18
Our Services are not intended for children or other individuals under 18 years of age. No one under age 18 may provide any information to or on the Services. We do not knowingly collect personal information from individuals under 18. If you are under 18, do not use or provide any information on our Application or through any of its features, register through the Application, make any purchases through the Application, attempt to enter into any Consent Agreements using our Services, or provide any information about yourself to us, including your name, address, telephone number, email address, or driver’s license or state identification number.
Changes to Our Privacy Statement
It is our policy to post any changes we make to our Privacy Statement on this page with a notice that the Privacy Statement has been updated on the Services application home page. If we make material changes to how we treat our users’ personal information, we will notify you by email to the primary email address specified in your account and/or through a notice on the Services application home page. The date the Privacy Statement was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Services and this Privacy Statement to check for any changes.
Contact Us
To ask questions or comment about this Privacy Statement and our privacy practices, contact us at:
US Mail:
Verified Mobile, Inc.
Attn: Legal Department
15774 S LaGrange Rd
Orland Park, IL 60467
Email: info@ConsentFirst.app
SUPPLEMENTAL PRIVACY STATEMENT FOR CALIFORNIA RESIDENTS
Last modified: May 15th 2023
This Supplemental Privacy Statement for California Residents (“California Privacy Statement”) provides additional information required under the California Consumer Privacy Protection Act (CCPA) regarding the personal information we collect from and about California residents, and describes the rights granted to California residents under the CCPA.
This California Privacy Statement applies to information collected from or about California residents only. This California Privacy Statement applies to any and all personal information about California residents collected by Verified Mobile, including personal information collected in connection with our Services, as well as personal information collected offline.
Definitions Specific to California Privacy Statement
The CCPA includes definitions for terms specific to this California Privacy Statement that do not apply to Verified Mobile’s other privacy notices, including the following terms:
“Personal information” (regardless of whether such term is capitalized or not) means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal information does not include publicly available information obtained from government records or deidentified or aggregated consumer information.
“Sell,” “selling,” “sale,” or “sold” (regardless of whether such terms are capitalized or not) means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer‘s personal information by the business to another business or a Third Party for monetary or other valuable consideration.
“Service Provider” means certain for-profit legal entities that process information on behalf of Verified Mobile and to which we disclose your personal information for a defined business purpose pursuant to a written contract that prohibits this service provider from retaining, using, or disclosing your personal information for any purpose other than for the specific purpose of performing the services specified in the contract with us.
“Third Party” means another business that collects or receives your personal information, other than a Service Provider.
All other capitalized terms used but not defined in this California Privacy Statement shall have the meanings ascribed in our Privacy Statements.
Personal Information Collection and Use
Verified Mobile has collected the following categories of personal information about California consumers in the preceding twelve (12) months:
Identifiers and contact information, including full name, postal address, telephone number, email address, date of birth, and driver’s license or state identification card number.
Commercial information, including in-app purchases and other products and services purchased, and Consent Agreement terms and histories.
Financial information, including credit or debit card number and payment amounts.
Characteristics of protected classifications under state or federal law, such as age, gender, and sexual orientation.
Audio, electronic, visual, thermal, olfactory, or similar information, such as customer service call recordings, Voice Signatures, Interlude Recordings, and Session Recordings.
Internet activity information, such as browsing history, search history, cookie data, referring/exiting URL, clickstream data, time spent on a webpage or advertisement, and/or other information regarding a California consumer’s interaction with an internet website, application, email, or advertisement.
Geolocation data, including approximate or precise device location.
Verified Mobile collects the categories of personal information identified above from the following categories of sources:
Directly from users of our Services.
Your computer and mobile device (automatically) when you visit or interact with our Services.
Payment processors and other financial institutions.
Vendors who assist with identity verification and fraud prevention, detection and mitigation.
Mobile app store/marketplace providers (e.g., Apple, Google).
Vendors who assist with our information technology and security programs.
Internet service providers.
Verified Mobile collects the categories of personal information identified above (i) for the purpose you provided it, such as to present the Services and its content to you, to administer and maintain your account and consents, and to verify your identity; (ii) to notify you about Verified Mobile products and services; (iii) for security or fraud prevention purposes; (iv) to improve the content, functionality, and usability of our Services; (v) to comply with any court order, law or legal process, including to respond to any government or regulatory request; and (vi) for the purpose of aggregated statistical analysis regarding how you and others use our Services. For any other use, we will first obtain your explicit consent.
Personal Information Disclosures
In the preceding twelve (12) months, Verified Mobile has disclosed for a business purpose the categories of personal information identified below to the associated categories of Third Parties listed.
| CATEGORIES OF PERSONAL INFORMATION DISCLOSED TO THIRD PARTIES IN PRECEDING 12 MONTHS | CATEGORIES OF THIRD PARTIES TO WHOM PERSONAL INFORMATION IS DISCLOSED |
|---|---|
| Identifiers and Contact Information | Other parties to your Consent Agreements entered into through the Services. Third Parties who assist with our information technology and security programs. Third Parties who assist with fraud prevention, detection, and mitigation. Payment processors and other financial institutions. Mobile app store/marketplace providers (e.g., Apple, Google). Third Parties who deliver our communications, such as the postal service and couriers. Our lawyers, auditors, and consultants. Legal and regulatory bodies, law enforcement bodies, and other Third Parties as required by law |
| Commercial Information | Other parties to your Consent Agreements entered into through the Services. Third Parties who assist with our information technology and security programs. Third Parties who assist with fraud prevention, detection, and mitigation. Payment processors and other financial institutions. Mobile app store/marketplace providers (e.g., Apple, Google). Third Parties who deliver our communications, such as the postal service and couriers. Our lawyers, auditors, and consultants. Legal and regulatory bodies, law enforcement bodies, and other Third Parties as required by law. |
| Financial Information | Other parties to your Consent Agreements entered into through the Services. Third Parties who assist with our information technology and security programs. Third Parties who assist with fraud prevention, detection, and mitigation. Payment processors and other financial institutions. Mobile app store/marketplace providers (e.g., Apple, Google). Third Parties who deliver our communications, such as the postal service and couriers. Our lawyers, auditors, and consultants. Legal and regulatory bodies, law enforcement bodies, and other Third Parties as required by law. |
| Characteristics of protected classifications under state or federal law | Other parties to your Consent Agreements entered into through the Services. Third Parties who assist with our information technology and security programs. Third Parties who assist with fraud prevention, detection, and mitigation. Payment processors and other financial institutions. Mobile app store/marketplace providers (e.g., Apple, Google). Third Parties who deliver our communications, such as the postal service and couriers. Our lawyers, auditors, and consultants. Legal and regulatory bodies, law enforcement bodies, and other Third Parties as required by law. |
| Audio, electronic, visual, thermal, olfactory, or similar information | Other parties to your Consent Agreements entered into through the Services. Third Parties who assist with our information technology and security programs. Third Parties who assist with fraud prevention, detection, and mitigation. Payment processors and other financial institutions. Mobile app store/marketplace providers (e.g., Apple, Google). Third Parties who deliver our communications, such as the postal service and couriers. Our lawyers, auditors, and consultants. Legal and regulatory bodies, law enforcement bodies, and other Third Parties as required by law. |
| Internet Activity Information | Other parties to your Consent Agreements entered into through the Services. Third Parties who assist with our information technology and security programs. Third Parties who assist with fraud prevention, detection, and mitigation. Payment processors and other financial institutions. Mobile app store/marketplace providers (e.g., Apple, Google). Third Parties who deliver our communications, such as the postal service and couriers. Our lawyers, auditors, and consultants. Legal and regulatory bodies, law enforcement bodies, and other Third Parties as required by law. |
| Geolocation Data | Other parties to your Consent Agreements entered into through the Services. Third Parties who assist with our information technology and security programs. Third Parties who assist with fraud prevention, detection, and mitigation. Payment processors and other financial institutions. Mobile app store/marketplace providers (e.g., Apple, Google). Third Parties who deliver our communications, such as the postal service and couriers. Our lawyers, auditors, and consultants. Legal and regulatory bodies, law enforcement bodies, and other Third Parties as required by law. |
Verified Mobile does not sell personal information about California consumers. Without limiting the foregoing, Verified Mobile has no actual knowledge that it sells the personal information of minors under 16 years of age.
Your California Rights
If you are a California resident, you have the following rights under the CCPA with respect to your personal information:
Right to Notice. Before or at the time we collect personal information from you, you have the right to receive notice of the personal information to be collected and the purposes for which we use it.
Right of Access (“Request to Know”). You have the right to request that we disclose to you the categories of personal information we have collected about you in the preceding 12 months, along with the categories of sources from which the personal information was collected, the purpose for collecting or selling the personal information, the categories of personal information disclosed or sold, and the categories of third parties with whom we shared or sold the personal information. You also have the right to request that we disclose or provide you with access to the specific pieces of personal information we have collected about you in the preceding 12 months.
Right to Deletion (“Request to Delete”). You have the right to request that we delete the personal information we collect from you. However, in certain situations we are not required to delete your personal information, such as when the information is necessary in order to complete the transaction for which the personal information was collected, to provide a good or service requested by you, to comply with a legal obligation, to engage in research, to secure our websites or other online services, or to otherwise use your personal information internally in a lawful manner that is compatible with the context in which you provided the information.
Right to Opt-Out of the Sale of Personal Information. Verified Mobile does not sell your personal information as the term is defined based on our understanding of the CCPA. We have not sold any personal information to third parties for business or commercial purposes in the 12 months prior to the effective date of this California Privacy Statement.
Right Not to Be Subject to Discrimination. You have the right to be free from discrimination or retaliation for exercising any of your rights under the CCPA as described above.
You can exercise your rights by contacting Verified Mobile as described in the Contact Us section below.
Request Verification
We value the security and confidentiality of your personal information. Therefore, if you submit a Request to Know or Request to Delete, we must first verify your identify to make sure that you are the person about whom we have collected personal information. We verify every request carefully. Along with your request, we will ask that you provide us with certain information previously collected from you, such as your email address, postal address, and/or information regarding your consent history. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Authorized Agent
If you are making any of the requests above as an authorized agent, we will require notarized written authorization or a notarized Power of Attorney. Additionally, we will seek to verify your identify in the manners stated above (depending on the request type). To make a request using an authorized agent, please contact us as described in the Contact Us section below.
Additional Information
We will maintain records of requests that are made that include the date of request, nature of request, manner in which the request was made, the date of our response, the nature of our response, and the basis for any denial of the request if it is denied in whole or part.
You are not required to create an online account with us in order to exercise your rights.
California residents who are unable to review or access this California Privacy Statement due to a disability may call us at the telephone number listed in the Contact Us section below to access this California Privacy Statement in an alternative format.
Changes to Our California Privacy Statement
We reserve the right to amend this California Privacy Statement at our discretion and at any time. The date this California Privacy Statement was last updated is identified at the top of this page. You are responsible for periodically visiting our Services and this California Privacy Statement to check for any changes.
Contact Us
If you have any questions or concerns about Verified Mobile’s privacy policies and practices, please contact us at the contact information listed below:
US Mail:
Verified Mobile, Inc.
Attn: Legal Department
15774 S LaGrange Rd
Orland Park, IL 60467
Email: info@ConsentFirst.app