This Privacy Policy (“Policy") sets out how we, Salo App Inc. and (or) its controlled subsidiaries and affiliates, if applicable (“Salo App, Inc.”, “Company”, “we”, or “us”), makers of the Salo video and audio messages sharing app (the “Salo App”) use and protect your personal information that you provide to us and the content you share and create via Salo App (“App”), or that is otherwise obtained or generated by us, in connection with your use of the App.

Privacy Principles

This Policy applies to anyone who accesses the App. By using the App, you acknowledge that the processing of your personal information and content you share and create will take place as described in the present Policy.

So, we are clear about the terminology we are using, when we use the phrase “Personal Information” in this Privacy Policy, we mean information that is capable of being associated with or could reasonably be linked with you, such as your name (nickname), mobile number, email, the date of your birthday and, if you choose, your photo.

Personal information may also include:
- Payment details, for example, in case of making transactions in relation to the purchase of some parts of the App, which are charged on a subscription basis (“Subscription Offerings”) as it is described in the Terms of Use;
- Your contacts, in case you will give us the access to your phone’s address book as described in the present Policy.
1. Types of information processed by Salo App Inc.

a. Basic Account Data

To create a Salo App account (“Account”), you provide your mobile number, your name (nickname), your email address, and the date of your birthday, and may choose to provide your photo. Only other registered Salo App users that:

• already have your phone number in their phone’s address book, or
• you invited to Salo App

may see your name (nickname), photo, mobile number, email, birth day and/or birth month.

Users who are in a group with you may see only your name (nickname) you provided to the App unless you appear in their phone’s address book or you change the settings and allow all users of the App see your account data.

Note that users who have you in their contacts will see you by the name they’ve saved and not by the name you provided to Salo App. If you chose to provide them, we collect your birth day and month so people you know get reminded when it’s your birthday.

Please also note that your name (nickname) and photo (if you decide to provide it) will be visible to all other users of the App who can search for you by name (nickname), if you do not disable this feature in the App settings.

We may also offer you as a possible contact to contact people you may know (without disclosing your phone number), if you do not disable this feature.

b. Video and audio messages

Salo App is a cloud service. We may collect and store, and transfer to the users you select the video and audio messages (or “Content”), you create and want to share with such selected users in chats, including group ones. We store the Content on our servers on the conditions described below so that you can access your Content during a particular period of time to review and (or) download from any of your devices that have the App without having to rely on third-party backups or use up your phone’s memory.

We hereby declare that we will never read, listen to or view the content of video and audio messages you share via the App. You can be sure that we will use the Content and personal information only in the manner described in the present Policy and our Terms of Use.

However, any user of the App has the possibility to complain to us about the unacceptability of the content that he or she received from another user, and therefore such content may be completely deleted at our discretion.

c. Contacts

You may choose to provide us with your friends' contact information (your phone’s address book) as stored on your phone. We store such mobile phone numbers on our servers and use them as unique identifiers so that it is easy for you to find and communicate with other people you know and who already use the App. We will ask your permission by sending you a push-notification before syncing your contacts, and you can still use the app without giving it access to your contacts (though you will have a harder time finding people you know who also use Salo App).

We store your contacts on our servers also in order to notify you as soon as one of your contacts creates a Salo App Account and to properly display their names. We only need the number and name for this to work and store no other data about your contacts.

You can always stop syncing contacts or delete them from our servers in Settings > Privacy & Security > Data Settings.

Our automatic algorithms also use this data to suggest which of your contacts you might like to communicate with on Salo App. We use this information to suggest people to invite to join Salo App but we do not contact anyone in your phone’s contact list without your permission.

We do not share your contacts with third parties unless required to do so in response to valid legal requests, such as through a court order or search warrant.

d. Information about actions.

When you use the App, we will track, and other users will be able to see information about your network status, information about receiving and viewing messages sent to you, the time and duration messages. If you don't want other users to know that you are online or have viewed certain messages, you can disable the corresponding options in the app settings. As for the data about the status of messages, we believe that they are important for other App users, so you cannot disable the provision of this data.

e. Information about the device and its location.

We may collect additional information if you access the application through a specific device (for example, the unique identifier of your mobile device; the IP address of the connection session; information about the operating system of your mobile device, about your browser, browser language or operating system; about your wireless network, etc.) to analyze usage and trends and personalize and improve the App.

3. User Support

If you contact Salo App support, any Personal Information you may share with us is used only for the purposes of researching the issue and contacting you about your request.

4. Third Party service providers.

In order to provide you with the best functioning of our App, we may sometimes, if necessary, share your Personal information with our affiliates, carriers, partner service providers and/or agents. For example, the third party banking organizations or other providers of payment, email delivery, analytical services, customer support, or hosting services.

We will always require these third parties to take appropriate organizational and technical measures to protect your Personal information and to observe the relevant legislation.

We use third-party analytics Service Providers to automatically log information about you and your mobile device, and how you interact with the App. For example, when you access the App, we may log your operating system type, browser type and language, the pages you viewed, how long you spent on a page, access times, Internet protocol (IP) address, your mobile device ID, mobile device serial number, unique user ID, wireless carrier, and information about your use of and actions on the App. Salo App collects this additional technical data to analyze usage trends and give us more information about how people use the App to better the user experience.

We also provide data about your mobile phone number to the server service Firebase Authentication provided to us by Google for the purpose of verification your identity when registering in Salo App Account.

To place ads within our App, we have the legal right to share with our partners a unique identifier that is not tied to the user's identity, but may contain some technical data about the user (application language, country, city, age, device data). This applies both directly to our partners who place ads within the App, and to their agents and other third parties who administer the placement of ads. A unique advertising identifier is generated by your mobile device.

5. Processing of Personal information and Content.

We use the information that we have about you to operate, provide, support, personalize, and make our App more relevant and useful to you and others.

a. We may process Personal information by the ways such as collection, recording, organization, structuring, storage, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction (hereinafter collectively referred to as “Processing”).

We process your Personal information on the ground that such processing is necessary to further our legitimate interests, including: (1) providing effective and innovative App to our users; and (2) to detect, prevent or otherwise address fraud or security issues in respect of our App), unless those interests are overridden by your interest or fundamental rights and freedoms that require protections of personal data.

Also, we may use the Personal Information we collect from and about you to:

• Register you in the App and create your User Account;
• Create your profile and ensure its functioning;
• Process your payments, if it is needed;
• Provide you with information about your account;
• Specify which of your contacts already uses the App, and notify about the connection to the App of new contacts from your phone’s address book;

• Display the name of the contact from your address book when receiving a message;
• Send individual messages about new offers and functions of the App that, in our opinion, may be of interest to you;

• Allow you to find and connect with your friends;
• Let your friends know about your activity on the App as described in paragraph 1(d);

• Analyze usage and trends and personalize and improve the App and your experience using the App;
• Respond to your comments and questions and provide customer service;
• Send information including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages;
• Send marketing emails that promote the use of Salo App from which you can opt-out as described below;

• Protect, investigate, and deter against fraudulent, unauthorized, or illegal activity; and
• Provide and deliver products and services that you request.
• Our marketing emails tell you how to opt-out or unsubscribe. If you opt-out of marketing emails, we may still send you non-marketing emails and notifications, which may include information about your account, our business dealings with you, and updates regarding our policies.

b. Sharing of personal information.

We may share your Personal Information we collect from and about you (1) with other App users, according to your account preferences and consistent with our Terms of Use; (2) for legal, protection, and safety purposes; (3) to comply with laws and in response to lawful requests and legal processes; (4) to protect the rights and property of Salo App Inc., our agents, customers, and others, including by enforcing our agreements, policies, and Terms of Use; and (5) with those who need it to do work for us (our Third Party service providers, as defined above).

We will not sell, rent, trade or otherwise transfer any Personal information and Content outside of Salo App Inc. and its controlled subsidiaries and affiliates, if applicable, without your explicit permission, unless it is obliged to do so under applicable laws or by order of the competent authorities.

We may disclose Personal information to respond to legal requirements, exercise our legal rights or defend against legal claims, to protect our interests, fight against fraud and to enforce our policies or to protect anyone's rights, property, or safety.

c. Storing of Personal Information and Content.

Unless otherwise specified, we retain Personal information for as long as it is necessary and relevant for us to achieve the above goals or to ensure compliance with our legal obligations to protect data. After terminating your Account, we will store the minimum amount of data about you that we are required to store in accordance with the law or other legal requirements. We may store activity data on the condition of anonymity in order to improve our App.

We store the Content on our servers after the moment you share the Content with the selected contact/user until this user is online in his/her Account. After the user to whom you have sent the Content appears online in his/her Account, such Content is delivered to such User, stored in the user device's memory and is marked for deleting from our server. After 1 (one) month from the moment of automatic saving of the video (audio) message in the operating memory on the user's device, such Content will be completely deleted from our servers. Please note that you will have only 1 (one) month from the moment of receiving the Content to download it to the gallery of your device.

If for some reason the Content was not delivered to the recipient (for example, the recipient does not use the app) within 1 month from sending, it will be deleted from our servers in any case.

Currently, our servers are located in the United States and Germany. Please note that information that is collected by or sent to the App may be stored and processed in the United States, Germany or any other country in which Salo App Inc. or its affiliates, subsidiaries, or service providers maintain facilities. In this regard, or for purposes of sharing or disclosing data in accordance with the present Policy, we reserve the right to transfer information outside of your country. By using App, you consent to any such transfer of information outside of your country. In any case, we will ensure the adequate level of protection of your

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Personal Information.

‍d. Other users of our App with whom you choose to communicate will be given some of your Personal Information as described in the present Policy. These other users may be located anywhere in the world. Note that by entering into the Terms of Use and choosing to communicate with such other users of the Apps, you are instructing us, as part of our contract with you, to transfer your Personal Information, on your behalf, to those users in accordance with this Privacy Policy. We employ all appropriate technical and organizational measures to ensure a level of security for your Personal Information that is appropriate to the risk. We are not responsible for the subsequent distribution (transfer) of your Personal Information by such users.

e. When registering your Account in the Salo App, we will send you a push-notifications asking for giving your consent to Process your Personal Information by us in the ways described in the present Policy.

f. If Salo App Inc. or substantially all of our assets are acquired by a third party, Personal Information held by us about our users will be one of the transferred assets. Such third party will be required to treat that Personal Information in a manner consistent with this Policy.

6. Managing your Personal information and Content.

a. You can manage your Personal Information in the Apps’ Settings.

b. You may make a request to download all Personal information from the App.

Please note, that the possibility to download this or that content is limited in time as described in paragraph 5 (c) of the present Policy.

Within the App, you can select the "Download everything" option. As a result of selecting this option, an appropriate signal will be sent to us, and we will create an archive of the Personal Information and all your Content that we have at the moment of receipt your request, that is, such of your Content that has not yet been deleted from our servers in connection with the expiration of the terms of storing. The generated archive of data, including information about the date of account registration, Personal information included in the Account, and the entire array of the existed Content will be sent to you to your email address provided while registration of Account.

c. You have the right to obtain from us the erasure of personal data concerning you without undue delay and we undertake to erase personal data without undue delay where one of the following grounds applies:

(a) Personal information is no longer necessary in relation to the purposes for which it was collected or otherwise processed;

(b) You withdraw consent on which the processing is based, and where there is no other legal ground for the processing;

(c) You object to the processing and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing;

(d) Personal Information has been unlawfully processed;
(e) Personal Information has to be erased for compliance with a legal obligation in EU or in accordance

with the applicable legislation.;

(f) the Personal information has been collected in relation to the offer of information society services.

Please note, that if you terminate your Account, your Personal information will be deleted plus you will be removed from any Salo App groups; your name, profile picture, messages and information you have

shared with other users through Salo App will remain accessible to them as described in the Terms of Service. If you terminate your Account and had earlier synced your phone’s contact list with Salo App, the contact data and names of any of your contacts who have not registered on Salo App will also be deleted from our servers.

You can also permanently delete any video and (or) audio message you create, and that is still available to you in the Salo App by pressing on the message tile, holding down, and then selecting and confirming “Delete”. Doing so will permanently remove it from our servers and the Salo App accounts of whomever you sent it to. Messages you have shared with other users through Salo App will remain accessible to them as described in the Terms of Service.

e. All the requests about your Personal information should be sent to contacts@salo.team. You can also request to change your contact choices, opt-out of our sharing with others, and update your Personal information.

7. Our Commitment towards Children's Privacy

We do not direct the App to, nor do we knowingly collect any Personal information from children under 13. Children under 13 are not eligible to use the App. If we learn that a user is under 13 years of age, we will take steps to remove that user's Personal information from our databases and to prevent that user from utilizing the App.

8. Notification Choices

By default, Salo App sends you emails and notifications regarding activities on the App, e.g., when you receive a message from one of your contacts.

We may also communicate with you via informational, transactional, or marketing emails and/or text messages.

You may choose to unsubscribe from marketing emails by clicking “Unsubscribe” from the email or in the App by going to Settings and selecting the “Send me fewer emails” option.

If you unsubscribe, we may still need to send you non-marketing emails about your account or our business dealings with you (e.g., emails regarding AppStore subscriptions you have with us).

9. Links to Other Sites

The App may contain links to other third-party websites or applications. Any information you provide on those sites is subject to that third party's privacy policy. Our Policy does not apply to such sites, and we are not responsible for the privacy and security practices and policies of those third-party sites or applications.

10. Security of your Personal Information

We are committed to protecting the security of your Personal information. We have taken certain physical, administrative, and technical steps to help safeguard the information we collect from and about you. While we take steps to help ensure the integrity and security of our network and systems, we cannot guarantee our security measures.

11. Applicable Law

The CCPA and GDPR provides rights to certain individuals located in California and the European Union. We apply these rights to our users. You can contact us about these rights at contacts@salo.team.

a. CCPA

We do not disclose Personal Information beyond what is described in this Policy. All our users, including those in California, have the following rights.

● Right to access: You have the right to know and see what data we have collected about you over the past 12 months including: - categories of personal information we have collected about you; - categories of sources from which the personal information is collected; - the business or commercial purpose for collecting your personal information; - the categories of third parties with whom we have shared your personal information; and - the specific pieces of personal information we have collected about you.

● Right to deletion: as described above you have the right to request that we delete in certain circumstances the personal information we have collected from you.
● Right not to be discriminated against: You have the right not to be discriminated against for exercising any of these rights.

To request access to or deletion of your personal information, or to exercise any other data rights under the CCPA, please contact us at contacts@salo.team.

b. General Data Protection Regulation (GDPR)

We, Salo App, are the data controller of your Personal Information. Our contact information can be found at the end of this Policy.

Information according to GDPR Article 27

All our users, including those in the European Economic Area (EEA), have the following rights, about which you can contact us at contacts@salo.team.

1. Right to access: the right to request certain information about, access to and copies of the Personal information about you that we are holding;
2. Right to request that we rectify, limit, cease processing or erase information we hold about you in certain circumstances;
3. Right to data portability: the right to request that we return any information you have provided in a structured, commonly used, and machine-readable format, or that we send it directly to another company, where technically feasible;
4. Right to object: the right to object to our use of your Personal information including where we use it for our legitimate interests or, if applicable, for marketing purposes; and
5. Right to lodge a complaint about us to a supervisory body in your country of work or residence.

12. Contact Information

We welcome your comments or questions about this Policy. You may contact us at contacts@salo.team.

13. Changes to Privacy Policy

We may modify this Policy from time to time. If we make any changes, we will change the Last Updated date below. We also may provide additional notice, as applicable, depending on the type of change. If you object to any changes, you may stop using the App. Your continued use of the App after we publish or otherwise provide notice about our changes to the Policy means that you have read and understood the updated Policy.

Last Updated on July 7 2021.