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Privacy Policy

Last modified: November 19, 2023

Welcome to privacy at amo.

We care about your privacy and want to be upfront about how we treat your data when using the services (“Services”) that amo (“amo”) offers: what we collect, why we collect it, where it all goes, for how long, your rights, and what you can ask us to do with it. So we wrote this policy (“Privacy Policy”) to explain it to you in the clearest and simplest way we know.

Caring about your privacy means that you don’t have to worry that your data is being misused,  or misappropriated. Sometimes we’ll make decisions relating to your data on your behalf, but please know that these decisions are made in the best interests of you and other amo users.

Your use of our Services is subject to our Terms of Service. Please read it – it’s important that you understand and agree to what you’re signing up for before using any of our Services.

As always, feel free to reach out to us at privacy@amo.co should you ever have any questions related to this policy.

amo is your data controller

amo is the “controller” of your data as described in this Privacy Policy. By your “data”, we mean any piece of data that identifies you directly (such as your photo, your name, or your phone number) or indirectly (such as your user ID, your location, or the technical data related to your device). We are a French company, and our head office is at 71 Boulevard de Clichy 75009, Paris, France. Being a French company means we need to apply GDPR regulations for everyone, regardless of which country you’re from. This in short means that law requires us to take your privacy very seriously. We’re not just saying we do… we really do.

As "controller", we process some of your data to power our Services. Processing your data, however, does not mean we can do what we want with it. We follow all the rules and create even more ourselves. We provide a lot of Services – most of which can’t work without your data, and therefore we use your data according to this Policy and our Terms.

What kind of data do we collect?

There are three categories of data we collect: data you provide us; data we collect through the use of our Services; data we collect from third parties.

Data you provide us

  • Account data. When you register for the Services you provide us with your first name, last name, age, and phone number. We cannot provide the Services without these. We’ll then send you a verification code via text message to enable us to verify your account. We find it easier and more secure than remembering a password, and it also helps us minimize bots and maximize real humans on amo.
  • Profile picture. If you want, you may also add a profile picture to make it easier and more fun to interact with your friends. Of course, you're free to change your photo anytime you’d like: just go to Settings in the app. Profile pictures on amo use Apple’s TrueDepth API in order to generate the video of your face. We do not collect, store, or share TrueDepth data.
  • Contacts. We also ask you to share your contacts to let you easily find friends that are already active on our Services. Sharing your contacts also makes it easy to invite friends. When you provide access to your contacts we also get access to your own contact information
  • Location. amo is always evolving. We create many features built around your experience of the world and the people in it. In order for our Services to fully function we need access to your location and history while on amo. You provide this to us through the permission settings on your phone. We collect your location using methods that include GPS, wireless networks, cell towers, Wi-Fi access points, and other sensors, such as gyroscopes, accelerometers, and compasses. We use this range of data sources to give the friends you choose the most accurate picture of where you are or were.
  • Communications. You also provide us with any other data you send through our Services, such as comments, images, videos, and other media to your friends. We also keep track of communication metadata, such as the time and date of correspondence.
  • Media. You provide media created during your time using amo such as pictures, videos, photos and more.
  • Support. Data you provide to our support (@amoamoamo on Instagram). This includes the content of our communications, photos, copies of government issued identification, and identifiers like the method you used to contact us.
  • Exercising your rights. When exercising your data protection rights (privacy@amo.co), we receive data from you that is necessary to identify and respond to you.
  • Transaction data. If you purchase paid features, we retain your purchase and subscription history. However, we will not be processing your payment data, it will be collected and processed via the store (App Store, Google Play Store).

Data we get from your usage of the services

  • Usage data. We collect data with regards to your activity on any of the Services. For example, how you communicate with your friends, how much content you create in a day, search results when you look for friends and so on. This helps us understand what you like and how we can improve.
  • Friendship data. Your friends, the number of friends, friend invitations, comments you leave on content shared by others, the friends with whom you interact the most, and functional data related to comments or messages.
  • Location data. We collect location data and location history so we can build useful and fun services and features for you, like giving your friends more context about the content you created by sharing where it was made.
  • Device data. We collect a variety of device-specific data, the BSSIDs of Wi-Fi terminals, as well as the SSIDs (the address of any WiFi routers you’re connected to) but only in a temporary manner and for statistical purposes. We also collect whether or not headphones are connected, your phone name, phone hardware model, operating system version, unique device identifiers, phone language, wireless network names, IP addresses, and general mobile network data. This helps us protect your security, fix bugs, and improve the precision of your location, for example.

Data we collect from third parties

We may obtain data from other companies that are owned or operated by us — or any other third party sources — and combine that with the data we normally collect through our services:

  • Other users. We may receive data from other users, especially in user generated content, support requests and user reports.
  • Business partners. We may receive data from trusted business partners, such as app stores or operating system providers and analytics providers.
  • Law enforcement and NGOs. We may receive data from non governmental or law enforcement organizations for safety purposes, investigations, or legal proceedings.

How do we use your data?

We use your data to:

  • Develop, operate, improve, deliver, maintain, and protect our Services.
  • Send you communications, including by email. For example, we may use email to respond to direct support inquiries.
  • Create statistical studies and analyze trends:
    • Statistical studies. Creating statistical studies on an anonymous basis. For example, we may look for groups of users with similar usage patterns or habits to see if we can improve the user experience of the Services.
    • Registration statistics. Determining which groups like country, users of different phone types, operating systems, etc. are statistically relevant to the different studies that we conduct on an aggregate basis.
    • Movements over time. We may measure and analyze the movements of users over time. This can enable us to add useful features like how long your commute may be.
  • Enhance the safety and security of our products and services. For example by detecting and preventing excessive friend requests.
  • Assess the success rate of our marketing campaigns.
  • Send you push notifications to get updates when friends accept your requests, comments, updates on your friends’ whereabouts, and some other important news.
  • Verify your identity to prevent fraud or other unauthorized or illegal activity.
  • Enforce our Terms of Service and other usage policies.
  • Respond to your exercise of rights requests.
  • Store data locally on your phone, so that you can open the app and view content faster.

You can find an up-to-date recap chart at the end of this policy that shows what data we collect, what we use it for, the legal basis for that use, and how long we keep it for.

What are our bases for using your data?

As an EU based company, we are only allowed to use your data when certain conditions apply. These conditions are called “legal bases” and, at amo, we typically rely on one of four:

  • Contract. We may use your data should it be needed to be able to provide our services to you as described in our Terms of Service. Because amo's Services may use your camera and location, we need to access and store said data in order to offer our Services to you. This data is needed to provide you with the full amo experience.
  • Legitimate interest. We may need to use your data to provide and improve our services, including protecting your account, delivering our Services, providing customer support, helping you find friends, or to detect fraudulent activity. We only rely on legitimate interest when we believe that the way we use your data doesn’t significantly impact your privacy.
  • Consent. In some cases, we may ask for consent to use your data for specific purposes. If we do, we’ll make sure you can revoke your consent to our Services or through your device permissions. Even when we do not rely on consent to use your data, we may ask you for permission to access it via your device permissions.
  • Legal obligation. We may be required to use your data to comply with the law, like when we respond to valid legal processes or need to take action to protect our users.

Who can have access to your data?

A lot of good people are involved with providing you with our Services. Here’s who they are and how we may share your data with them:

  • amo employees. As our Services can’t run themselves for now, authorized amo employees may access your data to provide our Services or a required support. Such access is only granted within the scope of their responsibilities and only for the data which they need to access in order to carry out these responsibilities.
  • Other users who use our Services.
    • Data you share when using our Services features, such as your name, friend list, number of friends and profile picture. When you create your profile, keep in mind that it’s public and can be viewed by others.
    • The content shared on the feed to your friends.
    • Your location may be included as part of content shared through iterations of the Services, though it would only be shown to users you’ve accepted as friends. We would also like to draw your attention to the fact that your friends may have access to your location regardless of if they’ve provided you access to their location as well. Remember that you can always limit the sharing of your location through the settings at any time.
    • Information about how you have interacted with the Services such as the day you joined.
    • When sending a friend request, your profile name, friends you have in common, and in some cases your education or your job if you chose to share them, so the receiver can make a better decision on whether or not to accept the friend request.
    • If you let us access and share your device’s contacts, we may share data about you with other users who have your name and phone number in their device’s contacts.
  • Our affiliates. That means that we may share data with entities within amo.
  • Third parties.
    • Service providers and partners. We may share data about you with service providers who perform Services on our behalf and business partners that provide services and functionality, including partners who may show ads for the Services on their platforms.
    • Third parties for legal reasons. We may share data about you if we reasonably believe that disclosing the data is needed to:
      • Comply with any valid legal process, governmental request, or applicable law, rule, or regulation.
      • Investigate, remedy, or enforce potential Terms of Service violations.
      • Protect the rights, property, and safety of us, our users, or others.
      • Detect and resolve any fraud or security concerns.
    • Other third parties. We may also share aggregated, non-personally identifiable or non-identifiable data.
  • Third parties as part of a merger or acquisition. If amo gets involved in a merger, asset sale, stock sale, share sale, financing, liquidation or bankruptcy, or acquisition of all or some portion of our business to another company, we may share your data with that company before and after the transaction closes. Sharing just in case although we have no plans of going anywhere!

How long do we keep your data?

We store your data as long as you’re a user of our Services and have different retention protocols in place for different types of data. You can find details on said retention protocols in our data processing recap chart, but in any case, we’ll always delete or anonymize your data at the end of the periods indicated.

If you haven’t opened or used the Services for more than 36 months, we will delete your account and its associated data. We of course won’t delete your data as long as you remain a user of the Services.

The following data is stored as long as you are actively using the Services:

  • Your name and phone number;
  • Your age and profile picture;
  • Your contacts;
  • Friend requests and friend list;
  • Your written messages and images;
  • Location history;
  • Your device and usage data.

Should you not feel comfortable sharing your data you may delete your account at any time. The following section provides more information on how you may do so.

Your control over your data

  • Access. We let you access and update most of the data that we have about you. Most of this can be done in the profile section of the app. If you need to access, update, or delete any other data that we may have, you can contact us on Instagram. Note that we may ask you to verify your identity or provide additional information before we can provide access to your data.
  • Location. You can change which friends can see your location at any time in the settings.
  • Contact data. You can change your contacts sharing setting at any time in the settings or through your device permissions.
  • Object. You have the right to object to our use of your data. For data without which we cannot provide the Services, you can delete your account to stop us from processing your data.
  • Correct. You can also correct your data should you find information incorrect.
  • Delete. You can easily delete data in app such as any messages sent (including media like images and videos) or friends you’ve added. If you want to delete your location history, you can do this by deleting your account. As some services rely on location history, it is not possible to reset your location data.
  • Account deletion. We don’t like seeing you go, but if for some reason you want to delete your account you can always reach out on Instagram to request your account’s deletion.
  • Account un-deletion. If you’ve asked us to delete your account and then changed your mind and want it back, you have up to 30 days to restore your account before we delete your data from our servers. During this period, your account will not be visible to other users.
  • Data portability. You have the right to obtain, in a structured and machine-readable form (something that your computer can decipher), the data that you provide us directly on the basis of your consent or on the basis of the contract.
  • Define handling of your data after your death. You have the right to give instructions regarding whether amo should communicate this data (or not) to a previously designated third party.
  • Lodge a complaint. If you believe the processing of your data infringes on your rights or data protection regulation, you have the right to file a complaint with the CNIL or your local supervisory authority.

Please reach out at any time. We’ll try our best to get back to you fast, but we’re only human, so if your request is complex or if you make too many, we may need some time to answer.

Data transfers outside of the European Union

Similar to our transfer of your data to third parties, your data can be transferred and be accessible to third parties and users outside of the European Union. This can include countries that may not have the same level of protection of your data as those within the EU. Whenever we share your data outside the EU with third parties we make sure adequate mechanisms are in place to protect your data.

Any transfers of data originating from within the European Economic Area, the United Kingdom, and Switzerland to countries outside the EEA, UK, or Switzerland will normally be made on the basis of:

  • The data privacy framework when the providers are located in the United States and appear on the department of commerce’s list.
  • The model clauses approved by the European Commission for transfers from EU controllers to non-EU controllers, which may be found at the Commission’s website. We do not retain the data we collect longer than is reasonably necessary to fulfill the purposes for which we collect the data in line with our legal obligations.

We’re always happy to answer any questions you may have about data sharing to countries outside the EU, so feel free to reach out on Instagram should you ever have any questions.

Future revisions

Times change, and so will this Privacy Policy. We’ll update it to take into account any technical, economic, regulatory, or legal developments in order to comply with any changes in applicable laws and regulations, or data practices. When we do, we’ll make sure to let you know.

That’s it for now

Always feel free to reach out on Instagram or to our data team at privacy@amo.co  – we love reading emails so don’t be shy.

Data processing Chart

Purpose of the processingData processedLegal ground for the processingRetention period
Creating a single account for all Services and identifying you when you log in. Mandatory profile data (name, age, phone number). Performance of the contract between you and amo.Duration of your use of the services or until you request the deletion of your account.
Creating a single account for all Services and identifying you when you log in.Optional profile data (email address).Performance of the contract between you and amo. Duration of your use of the services or until you request the deletion of your account.
Providing you with the Services (allowing you to publish content, including by specifying your location). Content related data.Performance of the contract between you and amo. Duration of your use of the services or until you request the deletion of your account or data.
• Measure your use of our Services, which features you like the most, which you like the least, calculate statistics on the use of the Service and analyze them.
• Design and develop new features for amo and carry out tests before launching them.
• Understand and solve any technical problems you may encounter.
• Manage our internal communication and marketing activities, such as animating the amo community, or carrying out internal statistical studies.
• Measure the quality of the answers we give you when you contact our support team. 
• Improve the user experience, the technical operation of the Services and the way users can communicate on the Services.
• Usage data, Communications with amo
• Data related to devices and equipment used.
Legitimate interest to provide functional Services.2 years from collection date.
Addressing complaints and reports from users and moderation of content in accordance with our Terms of Service. • Content data
• Communication with amo.
Legitimate interest to provide safe Services.Duration of the use of the services augmented by 5 years.
Allowing you to publish content on the Services, viewable through the feed. • Data sent by your phone’s camera
• Photos stored on your phone
• Content creations
• Location data.
Performance of the contract between you and amo. Duration of the use of the services or until you request the deletion of the data.
Moderation of content in accordance with the law (prevention of illegal activities, fraud, cyber harassment, ...) and our Terms of Service. • Content Data, 
• Data about your activity on amo.
Compliance with our legal obligations. 1 year from collection for metadata. Up to 5 years (statutory limitation) for data retained for dispute prevention purposes.
Connecting you with your friends.Contacts data.Performance of the contract between You and amo.Duration of use of the Services.
Allowing you to make purchases.Transaction data transmitted by the Store.Performance of our contract with you. Time required to complete the transaction augmented by 10 years for accountancy obligations.

List of data processors

Amplitude
AppsFlyer
GCP
GitHub
Instagram
Intercom
PhotoRoom
Salesforce (Tableau)
Typeform

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