Effective Date: 2023-03-23
1B. Why do I need to read and accept it?
1C. What company owns ASKfm?
Ask.fm Europe Limited is an Irish limited liability company with registration number 551873 and a registered office at 6th Floor, South Bank House, Barrow Street, Dublin 4, Ireland.
1D. What privacy law applies to ASKfm?
The personal information you provide to us that is collected through our Services is controlled by ASKfm in accordance with the laws of the country in which you live, meaning that not all parts of this policy will be relevant depending on where you live.
1E. How old do I have to be to consent to you using my data?
You can’t use ASKfm if you are younger than 13. In almost all countries, if you are 13 and over, you can allow us to use your data.
But, since the law changed in Europe, in some European countries, we need to ask for your parent’s or guardian’s consent before we let you create an account if you are between 13 and 16 years old.
This is called the “age of consent”, and it means that if you are under a certain age, we need to get a parental consent. The age varies across different European countries, so it depends on where you live.
If you live in the UK, Ireland, Latvia, Czech Republic, Denmark, Poland, Spain or Sweden, we won’t need to ask for that extra consent from grownups.
If you live in Slovakia, Germany, Hungary, Lithuania, Luxembourg or Netherlands and are aged under 16, you confirm that you have your parent’s consent to sign up to ASKfm and we will take all reasonable steps to verify this.
If you live in France and are aged under 15, you confirm that you have your parent’s consent to sign up to ASKfm and we will take all reasonable steps to verify this.
If you live in Austria and are aged under 14, you confirm that you have your parent’s consent to sign up to ASKfm and we will take all reasonable steps to verify this.
2. How do you collect my data?
How we collect, process and store information depends in part on how you use the Services. You may register to use the Services (“Registered User”). You can use some of the Services without creating an account (“Guest User”) or providing any information other than information that is automatically collected as explained below. The different categories of information we collect from you are described below.
3. What data do you collect about me?
We may collect information from you during your use of the Services, including your name, username, password, e-mail address, postal address, phone number, mobile phone number, payment information, gender, birth year, and other information you provide or post on our Services or allow us to access when you do certain things, such as:
- Sign up and complete our registration form;
- Create or edit your user profile;
- Login to the Services;
- Submit questions or answer questions;
- Contact our customer support team or use our reporting mechanisms;
- Enter a sweepstakes or contest or register for a promotion;
- Participate in voting or polling activities;
- Request certain features (e.g., newsletters, updates, or other products);
- Connect with the Services or otherwise allow us to access certain information about you via a social media service; or
- Post user-generated content to or on our Services.
4. What data do you collect about my friends?
You can choose to invite your friends to join ASKfm so that you can stay in touch with them on the Services. To allow you to use this feature, we will ask your permission to access your personal contact list, which we will only access to store for your own use, to assist you with inviting friends to join you on the Services and to notify you when someone you know joins the Services. To make it easier to search and find friends and people you know on ASKfm, users may search for other members using first and last name, e-mail address, and location.
5. Do you collect data about my computer/my phone?
We may automatically collect certain information about the computer or devices (including mobile devices) you use to access the Services, and about your use of the Services, even if you use the Services as a Guest User. We may collect information such as (a) IP addresses, unique device identifiers (e.g. IDFA or other device IDs on Apple devices like the iPhone, iPad and iPod Touch), and other information about your mobile phone or other mobile device(s) browser types, browser language, operating system, the state or country from which you accessed the Services; and (b) information related to the ways in which you interact with the Services, such as: referring and exit pages and URLs, platform type, the number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used the Services, error logs, and other similar information. As described further below, we may use third party analytics providers and technologies, including cookies and similar tools, to assist us in understanding how our Services are used. Such tools may collect and use your data, after we have depersonalized it, with other ASKfm users’ data.
6. Do you collect data about my location?
We may collect general information (e.g. IP address, zip code) about your location, and may use that information to customize the Services with location-based information, advertising, and features that need to know your location to work properly. By accessing and using the Services, you consent to this collection and processing of location information. If you choose to turn off location services on your device, some features may not be available to you.
7. I’ve heard about cookies, do you collect them too?
8. Do you collect data about me from anyone else, like social networks?
We may collect, process and store:
- We may also obtain information about you if it is contained in user-generated content that other users post to or on our Services. For example, one of your friends could post something about you in a question they ask you, or in an answer they post.
- We may obtain additional information about you from affiliates and may combine that information with information which we collect from or about you and information derived from any other product or service we or our affiliates provide.
9. Do you anonymize my data so no-one knows its mine?
10. If I ask a question anonymously, do you still know who I am?
The fact that you can send messages without other people knowing who you are is part of what makes ASKfm unique and so much fun. It means that you can ask things that you might be too embarrassed or shy to say if anyone knew it was you. People may often be more honest when they are anonymous, whether they’re asking a question anonymously, or answering a question where they don’t know who has asked it. You have the ability to decide whether to ask a question anonymously or on a named basis each time you submit a question to another user. However, this also means that when you receive questions or comments, you may not know who they come from either! Remember, as a Registered User, that even if you ask a question anonymously, our Service will still have a record of the fact that you asked the question (even if we keep this private). If you are a Guest User, we may not know who you are.
11. If I don’t register, do you still collect data on me?
12. How do I stop receiving anonymous questions or unregistered questions?
Some people don’t like receiving things from people if they don’t know who they are. So we provide all users with the ability to choose not to receive questions from anonymous users on the “Settings” page on the website and mobile application.
13. Can law enforcement get my data from you?
14. What do you use my information for?
We use the information we receive from and about you for the following purposes:
- To provide the Services including any special features;
- To process and respond to your inquiries;
- To send you information about your relationship or transactions with us;
- To contact you if you have filed a complaint or report, or if someone has made any claim or report against you;
- To make suggestions to you and other Registered Users, such as suggesting Registered Users’ profiles to follow;
- To notify you about new features of the Services, special events, or products, services, and special offers, or to send you questions of the day;
- To moderate content and to keep the Services safe and secure and address any security issues;
- To generate advertising and promotional materials for our Services;
- To understand and assess the effectiveness of advertisements on the Services;
- To process payment for virtual goods that may be available from time to time;
- To administer sweepstakes and contests;
- To generate and review reports and data about our user base and Service usage patterns;
- To analyze the accuracy, effectiveness, usability, or popularity of the Services;
- To improve the content and features of the Services;
- To allow us to personalize the content and advertising that you see on the Services;
- To safeguard ASKfm’s and others’ rights or property;
- To administer and troubleshoot the Services.
15. Does ASKfm share my information with other users?
15A. Sharing your profile information
If you are a Registered User, anyone who uses the Services is able to see your username and any information posted on your profile, including photos. Any questions that you receive in your inbox cannot be seen by anyone else until you reply to them. If you do reply, then the question and your answer will be posted on your profile, where they can be seen by anyone who uses the Services and views your profile. While you have the ability to delete posted questions and answers on your profile at any time by clicking the “x” next to the question/answer, you should be careful to only include information in your profile, including any questions and answers, that you would not mind making public. If a Registered User “likes” a question or answer on your profile, the fact that the Registered User “liked” the content will be automatically visible.
15B. Does my profile show up in search engine results?
Your profile information will also be searchable via public search engines (e.g., Google, Bing, Yahoo).
15C. Can other people see my location?
Your location data is used for some user features like Shoutouts, to target your questions to people within a geographic range but we do not disclose your exact location to any other user.
15D. How can I protect myself?
In general, please be careful and responsible whenever you are online. Should you choose to voluntarily disclose information through the Services, such as by submitting a question to another user or by answering a question to be posted on your profile, that information can be viewed publicly and people can copy content that is posted on the Internet. It could also be collected and used by third parties without our or your knowledge, which may result in unsolicited messages from other individuals or third parties. You should not share personal information that might allow others to contact or locate you or other users, and you should think before you post.
16. Does ASKfm share my information with third parties?
16A. When and why we share your information with third parties
- To assist in providing the Services;
- To provide you with services or products that you have requested;
- With companies that perform services on our behalf (including both third parties and our affiliates), such as advertising providers, advertising networks/advertising exchanges, payment processors, providers of technical infrastructure (such as servers) or engineering or other support, order fulfillment companies, moderation companies, technical services and features developers, research and analytical companies, and e-mail service providers;
- With our affiliates for the collective benefit of our affiliates’ businesses and for operational purposes;
- In order to respond to the claims of violation of the rights of third parties and/or to protect the rights, property, and safety of ASKfm, our employees, Registered and Guest Users, or the public. This may involve the sharing of your information with law enforcement, government agencies, courts, and/or other organizations;
- As we continue to develop our business, we may sell, buy, merge or partner with other companies or businesses, or sell some or all of our assets. In such transactions, user information may be among the transferred assets;
- We may share your information in any other circumstances where we have your consent or are otherwise permitted to share it by law.
16B. Do you use any other companies to help ASKfm provide the services to me?
For some elements of the Service we get technical assistance from other companies, and we may need to share your information with them so that we can provide those Services to you.
We might use third parties to provide technical functionality for some of the Features of the Services (like stickers and multimedia posts). We call those Feature Tools. If you choose to use the Feature Tools, we may collect and store non-personally identifiable anonymous statistical data if you use that feature tool, where such tool is operated by a third party. We do not cooperate with Feature Tool providers that sell or otherwise transfer any of your data to third parties without your consent. You should review the privacy policies of the Feature Tools, and in order that you can do that we provide a list here of the Feature Tool Providers we currently work with.
16C. Do you use my questions and answers for research?
We or third parties we use may analyze your questions and answers for research purposes. When we use a third party to do this, we do not share any personal information with that party, we only provide anonymized questions and answer content and other non-personalised statistical data for analysis purposes.
16D. Tell me more about sharing my data for advertising purposes
(a) Anonymous Data
In order to understand our audience better and improve our service, such anonymous information is provided to third parties for their business purposes, including the creation of reports, market research, and trend analysis. This information does not contain information from which users can be identified and we will not provide additional information to such third parties that enable such third parties to identify you. Notwithstanding any other provision, we may also engage a third-party partner for the purpose of identifying users and delivering to them interest-based content and advertisements. We may share information about you with our partners such as your name, postal address, e-mail, or other identifier and may do so in non-human readable format to ensure the security of your information.
(b) Sometimes it’s personal data
Our partners also may collect information directly from your device, such as your IP address, device ID (which in some countries is considered as personal data) or similar information regarding the location of your mobile device; may combine our personal and non-personal information about you with information from other sources; and may place or recognize a unique cookie on your browser. If we are sharing ANY data that is considered to be personal data by the appropriate laws of the country in which you live, we will always ask your consent before we use your data in this way (and you can ask us to stop at any time).
(c) To opt out of third-party cookies, please go to http://www.aboutads.info/choices and/or https://liveramp.com/opt_out/ and/or https://liveramp.uk/privacy/ if you are in Great Britain. To opt out of the use of your mobile device ID for targeted advertising, please see http://www.aboutads.info/appchoices.
(d) Our current Partner List, that means companies we have agreed to share data with for the above purposes, includes the following companies and what data we share with them:
|Third Party||Location of Users||Types of data shared|
|Adsquare||Global||Age, gender, interests and device IDs/cookies|
|Circulate||US, Canada, France and UK||E-mail (encrypted) and cookies and/or device IDs|
|CleverDATA||Global||Age, gender, interests and device IDs/cookies|
|Zeotap||Global||Device IDs, age, gender, e-mail (encrypted)|
|Pangle||Global||Age, gender, interests and device IDs/cookies|
16E. I live in Europe, what does “profiling” mean and why do you need me to consent to it?
Profiling means we analyse your information and content (like your interests) so that we can tailor our advertising to you and what you’d like to see. Since the law changed in Europe in May 2018, we now need to ask your consent before we profile your information. That’s why, before we use your information in this way, you are asked to tick a box to allow us to profile your information and use it for tailored advertising.
16F. What is tailored advertising?
When accessing the Services from a mobile application you may also receive tailored in-application advertisements. Each operating system: iOS, Android and Windows Phone provides its own instructions on how to prevent the delivery of tailored in-application advertisements. You may review the support materials and/or the privacy settings for the respective operating systems in order to opt out of tailored in-application advertisements. For any other devices and/or operating systems, please visit the privacy settings for the applicable device or operating system or contact the applicable platform operator.
17. What are online analytics?
To help us better understand your use of the Services, we may use third-party web analytics on our Services, such as Google Analytics or Flurry. These service providers use the sort of technology that we’ve explained above for data that is automatically collected about your device, for example. The information collected by this technology will be disclosed to or collected directly by these service providers, who use the information to evaluate ASKfm users’ use of the Services. We also use Google Analytics as described more below. To prevent Google Analytics from collecting or using your information, you may install the Google Analytics Opt-Out Browser Add-on; to opt out of Flurry collecting or using your information, go to Google Analytics Opt-Out Browser Add-on.
18. How long do you keep my information for?
We keep your information and store it safely as long as you are using the Services. After you close your account we still keep some or all of your information for up to 9 months. It is important that we retain your data for this short period after cancellation to ensure that we can answer any payment or other account related queries, or provide information to third parties in line with our disclosure provisions outlined in this policy, e.g., assisting police investigations. Even after you remove information from your profile or delete your account, copies of that information may still be viewable and/or accessed on the Internet to the extent such information has been previously shared with others, or copied or stored by other users or to the extent such information has been shared with search engines. We cannot control this, nor do we accept any liability for this. If you have given third party applications or websites access to your personal information, they may retain such information to the extent permitted under their terms of service or privacy policies. We also keep a record of some of your information like you IP address or e-mail address if you’ve broken the rules and we’ve added you to our block list: this helps to keep everyone safe on the Services.
19. Important notice about our Do Not Track Disclosure
We are committed to providing you with meaningful choices about the information collected on our Services for third-party purposes, and that is why we provide the above links to the NAI “Consumer Opt-out”, DAA opt-out, and Google opt-out. However, we do not currently recognize or respond to browser-initiated Do Not Track signals, as the Internet industry is still working on Do Not Track standards, implementations and solutions.
20. How can I update my privacy choices?
You have a variety of choices regarding the collection, use, and sharing of your personal information through the Services, including the ability to prevent other users from submitting questions to you.
- The “Privacy” tab of the Settings page allows you to: (1) switch off receiving anonymous questions; and (2) hide your answers from appearing in the “Stream”.
- You can opt out of receiving certain e-mail notifications from us, including e-mails advertising ASKfm products and services, by clicking the “Notifications” tab of the Settings page on the mobile app and through the “Privacy” tab of the Settings page on the site.
- You can opt-out of consent to share your data with us and our partners here:
- (1) If you are using our Application on IOS device, please visit Help center → Manage choice for your data;
- (2) If you are using our Application on Android device, please visit Settings → Application /Manage choice for your data;
- (3) If you are using Mobile web or Desktop site, please click this link.
21. How can I block other users?
You have the ability to add any user to your “blocklist” at any time by clicking on the “block” button on that user’s profile. This will prevent the user from asking you a question.
22. How does ASKfm protect my information?
23. I want to deactivate my profile or leave ASKfm
23A. Deactivating Your Profile
You can deactivate your profile by signing in to the Services with your password and opting to deactivate your profile. This option is available from your Settings page. By deactivating your account, it will no longer be visible to other users of the Services. Your profile information will be retained in case you later decide to restore your account. Many members deactivate their accounts for temporary reasons and in doing so expect us to maintain their information until they return to ASKfm. You should ordinarily be able to restore your account and the whole of your profile within 12 months of deactivating it, but we cannot guarantee that this will always be the case.
23B. Leaving ASKfm
24. Are my privacy rights different depending on where I live?
24A. Your rights if you live in Europe
Because you control your profile, you can see the personal information you’ve provided to us by accessing your “Profile” page, which gives you the option to correct or update your information at any time by just logging into the Services. Once you register, you will be able to change most of your personal information, including: your name; your country; your contact e-mail address; your profile picture; and your password. You will not be able to change your birth date. You will also have the option to delete questions and answers posted to your profile at any time. You have a right to request a copy of the information we hold about you. Such a request must be in writing. You can do this via our contact form: Feedback. We will contact you to let you know what else we need from you before we send you a copy of your personal information. By law, in Europe we must respond to you within 30 days. You also have the right to be “forgotten” — that means, if you close your account and ask us to delete all your information, we need to do that. Although we are allowed to keep some of the information for security purposes in case we ever need to help the police with any criminal investigations.
24B. Your rights if you live in California, USA or Virginia, USA
Automated Decision-Making/Profiling and Targeted Advertising. We do use profiling and targeted advertising (although the advertising relates to your activity within our platform so it isn’t covered by the US Data Laws). Sections 16E and 16F explain more about these activities.
Limiting Sensitive Personal Information processing (as defined in the US Data Laws). How do I limit the processing of my sensitive personal information? For limiting your sensitive personal information processing, you are in full control of the information you share with us – to delete your sensitive information please remove it from your profile. If you wish us to no longer process your financial information then you will require to contact customer services, or downgrade/close your account online, as we are unable to provide a paid for service to you if you do not permit us to process your payment information.
US Data Laws give you certain rights if you live in California or Virginia which may include the following rights:
- You have the right to obtain from us access to the information we hold on you, and you are entitled to know if we have shared that information with any third parties. You can also ask us to correct it and provide a copy in a machine readable format. If you would like to request this information, please submit your request by clicking here or by emailing SUPPORT@ASK.FM or by calling + 1 310 3623927. It is important for us to ensure that the person making the request is really you, and we will contact you to let you know what else we need from you before we send you a copy of your personal information, which currently involves providing us with photographic identification (which is used for the purpose of verifying your identity and is not otherwise used or stored by us). You are entitled to receive a response from us within 45 days.
- You have the right to ask us to delete all the personal information we hold on you. If you would like to request the deletion of your information, please submit your request by clicking here or by emailing SUPPORT@ASK.FM or by calling + 1 310 3623927. It is important for us to ensure that the person making the request is really you, and we will contact you to let you know what else we need from you before we send you a copy of your personal information, which currently involves providing us with photographic identification (which is used for the purpose of verifying your identity and is not otherwise used or stored by us). You are entitled to receive a response from us within 45 days.
- Your Right to Access and Right to Deletion are not absolute and are subject to certain exceptions. For instance, we cannot disclose specific pieces of Personal Information if the disclosure would create a substantial, articulable, and unreasonable risk to the security of the Personal Information, your account with us or the security of the business’s systems of networks.
(a) Virginia residents: We do not sell your personal information per the definition of “sell” under Virginia state law. Virginia state law provides exceptions for sharing personal information meaning that, if you opt-out of data sharing, we do not need to honour that opt out, if we require to disclose your information in the following permitted ways (i) to a third party acting as a data processor for us e.g. payment processing provider, (ii) to a third party for purposes of providing a product or service that you have requested we/they provide to you, (iii) to our affiliate companies, (iv) if the information is information you have intentionally made available to the general public via a mass media channel and did not restrict such information to a specific audience e.g. information which is publicly available through such platforms, and (v) as part of a merger, acquisition or such similar corporate transaction.
(b) California residents. We do not sell your personal information, however we do share it as disclosed in this policy.
- You have the right to appoint an authorized agent to submit a request to opt-out of the sale of personal information on your behalf if you provide the authorized agent’s written permission to do so. If you use an authorized agent to submit a request, he or she must provide their name, email address, phone number, and written permission from you that includes your contact information. We will contact you using the information provided and verify your identity directly with us. We cannot respond to your request to provide additional disclosures or delete any personal information if we cannot verify your identity and the authorized agent’s authority to make the request on your behalf. Written permission is not required if the agent provides proof of power of attorney pursuant or you are submitting the request on behalf of your minor child.
- Appealing a decision we’ve made (Virginia residents only). You may have the right to appeal our refusal of any data request your make, through an appeal process. To appeal our refusal to provide the information (if this ever occurs), please write to us at SUPPORT@ASK.FM. We are legally obligated to respond within 60 days to you. If we do not accept your appeal you will then be entitled to escalate the matter by the submitting a complaint to the Virginia Attorney General’s office by mailing firstname.lastname@example.org or writing to 202 North Ninth Street. Richmond, VA 23219. We cannot guarantee these details are accurate and if you require to contact the AG Office, please double check all contact information.
24C. Your rights if you live elsewhere
While the Service is provided from Ireland, it is a global website that operates and provides Services in various countries around the world. By giving us any personal information or by using the applications available on the Services, you agree that your personal information may be transferred to and stored and processed in our and our third-party vendors’ facilities in various countries around the globe, including the United States. These countries may have privacy laws that differ from the laws in your country or the laws of Ireland.
25. What are your rules on children’s data?
The Services are not intended for use by children under the age of 13. We do not knowingly collect (or knowingly allow any third party to collect) personal information from persons under the age of 13. If we become aware that personal information has been collected from a person under the age of 13, we will delete this information and terminate the person’s account as quickly as possible. If you believe that we may have personal information from or about a child under the age of 13, please contact us using the contact information below.
Regarding California users aged 13 to 16, we do not sell the personal information of such users we actually know to be of this age without affirmative authorisation to do so.
26. What about third-party links and services?
28. How do I contact you if I have a question about this policy?
The following representatives are authorised to receive written communications on our behalf from the relevant supervising authorities and any data subjects exercising their rights under the UK Data Protection Act 2018, or the European General Data Protection Regulation:
UK Representative (in accordance with the UK Data Protection Act 2018):
Laroch Data Management, Technology House, 9 Newton Place, Glasgow, G3 7PR.
EU Representative (in accordance with the EU GDPR):
Due to our established presence and office bases within the EU, we are not required to appoint a designated EU Representative, however, all enquiries may be directed to the above named Data Protection Officer, at our Irish office address as stated above.
We take data protection very seriously. If you have concerns or complaints please address these to our data protection officer (see above).
If you are not happy with how we handle any complaint, you are able to raise a complaint at any time to your country’s national data protection authority, for example if you live in the UK, this would be the Information Commissioner’s Office.