Colkie Technology, S.L. company located at C / General Asensio Cabanillas 27, 28003, Madrid, Spain; with N.I.F. B05387345 (hereinafter, "Sesh") is a platform for communities to interact in a unique way. At Sesh we believe there is a better, more exciting and more meaningful way to belong to a community. Leveraging technology, we bring communities closer together. This Privacy Policy applies to all users of our platform, and is part of our Terms of Use.

Colkie Technology, S.L. is a global company. By using our platform ("Sesh"), you agree that personal information you provide to us directly or that we collect through your use of the platform may be transferred, stored and handled as described in this Policy.

Privacy is a very important issue for us. Our commitment is to create spaces where people can gather and where everyone finds their place. To that end, respecting users' privacy is essential. We collect certain information when you use Sesh. This includes information you provide to us, information we collect automatically, and information we receive from other sources.

Information you provide

Account Information

This is information you provide to us through text fields, such as your user phone number:

Phone Number
Username verification
Username
First and last name
Date of birth
Location
Email address

You also have the option to add more information to your public profile, such as links to your social networks and a description section, which we store along with any comments or messages you post on Sesh.

Content you create

This includes any content you upload to the service. For example, you can write text messages, send voice messages, upload or share videos, and more. It also includes your profile data and the information you provide when you create a community.

Information about your actions

We collect information about your use of Sesh and your activities on the services. This includes the users you interact with, the communities you join or leave, your roles in the communities, the decisions you make about content moderation and other related actions.

Other information you provide directly to us

You may have the option to provide us with additional information when using Sesh. For example, you may choose to verify your community, for which you must provide us with more information about yourself or your company. You can also participate in surveys where you can tell us what you think of our services or provide information to Sesh's technical support teams.

Subprocessors

We are using the following sub-processors to process Personal Data that we collect:

Google Ads conversion tracking (Google Inc.) Google Ads conversion tracking is an analytics service provided by Google LLC or by Google Ireland Limited, depending on the location short.io is accessed from, that connects data from the Google Ads advertising network with actions performed on short.io. Personal Data processed: Technical information, Usage Data. Place of processing: US – Privacy Policy - Data processing agreement

Amplitude Analytics (Amplitude Inc.) Amplitude Analytics is an analytics service provided by Amplitude Inc. Personal Data processed: Technical information; Usage Data. Place of processing: United States – Privacy Policy - Data processing agreement. https://amplitude.com/privacy; https://amplitude.com/wp-content/uploads/Amplitude-DPA-for-Terms-of-Service.pdf

Information Collected Automatically

We collect information automatically as you browse our site, when you participate in a community or through our third-party analytics providers. We may store usage information, such as the type of device you use to access Sesh, your operating system, browser type, IP address and device ID, the communities you visit or join, the comments you make, we record how many times users visit, activity on the site, where users have responded, who they have communicated with, the links you click, referring sites, user interactions, your search terms and more. We also collect your location, age, gender and IP address.

Information Collected by Third Parties

We may receive information from cookies (small text files placed on your computer or device) and similar technologies. We (and our third-party service providers) place first-party cookies that enable you to use the services and help us analyze and improve your experience and services.

We use cookies on our website that collect information to enable us and third parties to understand your use of Sesh.

Social networking features and widgets

We use social media features that run on Sesh. If you provide us with your social media information, we may use it to interact with you on these social media sites. These features may collect your IP address and other personal information, including the page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either stored by a third party or stored directly by Sesh. Your interactions with these features are governed by the Privacy Policy of the company providing them. For more information about the technologies used by these social networks, please refer to their specific privacy notices.

How we use your information

We process your information to:

Fulfill our legal obligations
Verify your identity to comply with the law
Provide you with Sesh services
Provide you with customer service
Provide you with enhanced and personalized services related to your Sesh account
Understand how you use the service and create better tools
Conduct research and development to improve Sesh and develop new features
Protect our services
Prevent fraud and abuse on Sesh
Make Sesh a safe place

Information we share with community managers.

By becoming a member of a community, you agree to the following information being shared with the administrators of that community:

Your name and other information you have provided in your profile.
Any messages you send to the community through Sesh.
Your physical address, city, state and country.
Some aggregated and anonymized data about how you use Sesh.

The community managers promise to protect the privacy of community members during and beyond their relationship.

Information we share with third parties

We can share your data with the community owners of the communities you are part of. We will only share data with third parties, other than community owners, in the following circumstances:

With your consent to provide benefits. You should read the privacy policies of these service providers to see how they use and share your data.
With our service providers, which are companies that are contractually bound to us to provide services to us, such as email management, data trend analysis, increasing our brand awareness and user engagement with marketing initiatives, and fraud detection and prevention, etc. These companies may have access to your data to perform their services and are contractually obligated to safeguard any of the data they receive from us to the same extent that Sesh protects it
To protect the security or integrity of Sesh, and to protect the rights, property or safety of Sesh, its employees, users or others, if we believe disclosure is reasonably necessary to comply with the law, regulation or other legal process (for example, subpoenas or court orders served on Sesh). If we are going to disclose your information, we will use reasonable efforts to notify you promptly by email, unless we are prohibited by law from doing so
In an emergency. We may share information if we believe it is necessary to prevent a serious personal injury
In connection with the sale, merger, bankruptcy, asset sale or reorganization of our business. We will notify you if a different company receives your information. The promises in this privacy policy apply to any data transferred to a new entity
With third-party applications used by community owners of the communities you are part of to help run their programs
With partners, who may have access to your data to perform their services and who are contractually obligated to safeguard the data they receive from us to the same extent that Sesh protects it

We retain personal information until we believe it is no longer needed for the purposes for which it was collected or retained, or if we are no longer required by law to do so.

Information Sesh collects from other applications

When you create a Sesh account, you can select to connect your other social network(s) (e.g. Spotify, Facebook, Instagram, TikTok, YouTube, Twitch, ...) with Sesh, and we will collect and store certain information from those platforms, such as:

Number of followers and users you follow
Number of posts
Number of views, likes, and comments

This information allows us to provide you with a better experience and also helps guide the future development of Sesh. We use this data to:

Help users find communities of interest on Sesh
Evaluate how to make communities more successful on Sesh
Analyze and improve the platform

Information we share with the public

The following information will be accessible to the public (or part of the public):

Your profile and that information you put on your profile and choose to make public
Your followers and people you follow
Any postings or comments you make in a community
Your aggregated or anonymized usage data in publications, press releases or in other ways to share information about your use of Sesh. Aggregated or anonymized data cannot be linked to any individual Sesh user

Your preferences and data rights

Choosing your preferences

The Settings link is found by clicking on your profile at the top right of your screen, after logging into your Sesh account. Settings allows you to view and modify your account preferences.

Marketing Activities

By agreeing to our terms of use, you expressly agree that Sesh may:

Send you information about its service, service improvements or new features, while you are on our website or using our applications
Send you messages about our existing services, or enhancements related to them, when you are away from our platform by email or text message, if you have agreed to receive notifications from us
Send you messages related to the services we offer by email and you may opt out and stop receiving them
Market Sesh to you and audiences similar to you based on your tastes, unless you opt out of receiving them
Send you marketing emails or text messages if you do not have a Sesh account but have consented to receive such messages and you may opt out of receiving them
Request demographic information to highlight and recommend you to communities
Promote your account to give you greater visibility
Send you physical items in the mail as part of a promotional activity

Access, update or export your account information.

You can access and update certain information associated with your account on the settings pages. In addition, you can delete your account or export your personal information by emailing us at info@joinsesh.app

Deleting your account

You can automatically initiate the deletion of your account directly by emailing us at info@joinsesh.app. Please note that this is a final act and cannot be reversed.

Managing your content and/or community

You can edit or delete certain data in the services:

You can edit or delete any message you have sent or content you have posted if you still have access to the space where you posted it
You can edit or delete a community if you have the necessary permissions to do so

Sesh may retain content for use as described elsewhere in this policy. In addition, in certain circumstances, we may have a legal obligation to retain certain data even if you delete your account information.

Disabling mobile notifications

If you download the Sesh app, you may also receive notifications on your mobile device. These can be disabled in the app's settings.

Verification request

Users maintain OTP-protected accounts on Sesh. If you submit a request to exercise your privacy rights, you will be asked to verify the request by logging into your Sesh account.

If we are unable to verify your request, then, for your security, we reserve the right to reject the request.

Compliance with privacy laws

Sesh is an international company that complies with the General Data Protection Regulation (GDPR). We act as a Data Controller, as defined in the GDPR, and process personal data based on our legitimate interests and contractual necessity to provide you with the Service as described in "How we use your information". We also process and share personal information based on user notification and consent, which our users may revoke at any time. Sesh relies on several legal bases to lawfully execute international transfers of personal information.

Sesh complies with the EU-U.S. Privacy Shield Framework and Switzerland-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. If there is any conflict between the terms of this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles will prevail. For more information about the Privacy Shield program and to view our certification, please visit https://www.privacyshield.gov/.

In limited circumstances, you may invoke binding arbitration before the Privacy Shield Panel. You can find more information about this arbitration process at https://www.privacyshield.gov/article?id=G-Arbitration-Procedures.

Sesh is responsible for the processing of personal information it receives or subsequently transfers to a third party acting as an agent on Sesh's behalf. Sesh complies with the Privacy Shield Principles for all onward transfers of personal information, including the onward transfer liability provisions.

Exercising Your Data Rights

Users in certain locations may have certain rights under the General Data Protection Regulation (GDPR) with respect to data controlled by Sesh as a data controller as defined in the GDPR, which include:

The right to access your personal data
The right to correct or rectify any inaccurate personal data
The right to restrict or object to the processing of personal data
The right to erase or delete your personal data
The right to portability of personal data
The right to opt out of the sale of personal information
The right to withdraw consent (withdrawal of consent does not affect the lawfulness of processing based on previously granted consents)

You can exercise rights over your data at Sesh by emailing us at info@joinsesh.app

Account Holders with Disabilities

Sesh is committed to accessibility for account holders with disabilities. If you are having difficulty accessing your account, please email us at info@joinsesh.app to provide assistance.

Contacting our data protection officers

If you have any questions about this privacy policy, you can contact our Data Protection Officers (DPOs) by email at info@joinsesh.app

Establishing an authorized agent

You may designate an authorized agent to make a request on your behalf. To designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requestor's valid government ID, and the authorized agent's valid government ID. Contact info@joinsesh.app with your request. To protect your information from account takeover, we may refuse access to or retrieval of your account at our discretion.

Prohibition Against Discrimination

We do not discriminate against users who exercise their privacy rights.

Security

The security of your personal information is important to us and we follow industry standards to protect it.

Children

Sesh is not directed to children under the age of 13, who may not create an account on Sesh.

Changes to Privacy Policy

From time to time we may make changes to this policy. If we make material changes that adversely affect your rights under this policy, we will let you know by posting a notice on our website or sending you an email before the changes take effect. Your continued use of Sesh following a change to this policy means that you accept the new policy. If you have any questions, please email info@joinsesh.app

Effective immediately for existing users and users joining Sesh on or after May 12, 2023.