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PRIVACY POLICY

Effective Date of Current Policy: November 26, 2018


1. PURPOSE

This Privacy Policy is incorporated by reference into the Dipsea Terms of
Service (the “Terms”). The terms “Dipsea,” “we,” and “us” refer to Dipsea Inc.
This Privacy Policy explains our online and offline information practices, the
kinds of information we may collect, how we intend to use and share that
information, and how you can opt-out of a use or correct or change such
information. All other terms not defined in this Privacy Policy will have the
meanings set forth in the Terms.


2. SCOPE

This Privacy Policy applies to any information relating to an identified or
identifiable natural person (“Personal Information”) that is collected,
recorded, organized, structured, stored, adapted or altered, retrieved,
consulted, used, disclosed by transmission, dissemination or otherwise made
available, aligned or combined, restricted, erased, destroyed, or subject to any
other operation performed upon Personal Information, whether or not by automatic
means ( “Processed”) by Dipsea in the course of our business, including on the
Dipsea website (our “Site”) and our mobile application (our “App”) (together
with any and all future online and offline offerings operated by or on behalf of
Dipsea, the “Services”). All individuals whose responsibilities include the
Processing of Personal Information on behalf of Dipsea are expected to protect
that data by adherence to this Privacy Policy.


3. TRANSPARENCY/NOTICE—TYPES OF PERSONAL INFORMATION WE COLLECT AND HOW WE USE
IT

The types of Personal Information we may collect (directly from you or from
third-party sources) and our privacy practices depend on the nature of the
relationship you have with Dipsea and the requirements of applicable law. Some
of the ways that Dipsea may collect Personal Information include:

 * You may provide Personal Information directly to Dipsea through interacting
   with the Services.

 * As you navigate the Services, certain passive information may also be
   collected about your visit, including through cookies and similar
   technologies as described below.

We endeavor to collect only that information which is relevant for the purposes
of Processing. Below are the ways we collect Personal Information and how we use
it.


3.1 TYPES OF PERSONAL INFORMATION WE COLLECT

Dipsea collects Personal Information regarding its current, prospective, and
former users and visitors to our Site.

 * Information You Provide Directly to Us. When you use the Services or engage
   in certain activities, such as registering for an Account with Dipsea,
   requesting Services or information, or contacting us directly, we may ask you
   to provide some or all of the following types of information:
   
   * Communications with Us. We may collect Personal Information from you such
     as your email address when you choose to request information about our
     Services, or register for Dipsea’s waitlist or newsletter, request to
     receive customer or technical support, or otherwise communicate with us.
   
   * Automatic Data Collection. We may collect certain information automatically
     through our Services or other methods of web analysis, such as your
     Internet protocol (IP) address, cookie identifiers, mobile carrier, mobile
     advertising identifiers, MAC address, IMEI, Advertiser ID, and other device
     identifiers that are automatically assigned to your computer or device when
     you access the Internet, browser type and language, geo-location
     information, hardware type, operating system, Internet service provider,
     pages that you visit before and after using the Services, the date and time
     of your visit, the amount of time you spend on each page, information about
     the links you click and pages you view within the Services, and other
     actions taken through use of the Services such as preferences.

 * Information from Other Sources. We may receive information about you from
   other sources, including through third-party services and organizations to
   supplement information provided by you. For example, if you access our
   Services through a third-party application, such as an App Store or SNS, we
   may collect information about you from that third-party application that you
   have made public via your privacy settings. Information we collect through
   App Stores or SNS accounts may include your name, your SNS user
   identification number, your SNS user name, location, sex, birth date, email,
   profile picture, and your contacts on the SNS. This supplemental information
   allows us to verify information that you have provided to Dipsea and to
   enhance our ability to provide you with information about our business and
   Services.


3.2 HOW DIPSEA USES YOUR INFORMATION

We acquire, hold, use, and Process Personal Information about individuals for a
variety of business purposes, including:

 * To Provide Services or Information Requested. Dipsea may use information
   about you to fulfill requests for our Services or other information including
   to:
   
   * Generally manage individual information and Accounts;
   
   * Respond to questions, comments, and other requests;
   
   * Provide access to certain areas, functionalities, and features of Dipsea’s
     Services;
   
   * Contact you to answer requests for customer support or technical support.

 * Administrative Purposes. Dipsea may use Personal Information about you for
   its administrative purposes, including to:
   
   * Measure interest in Dipsea’s Services;
   
   * Develop new Services;
   
   * Ensure internal quality control;
   
   * Verify individual identity;
   
   * Communicate about individual Accounts and activities on Dipsea’s Services
     and systems, and, in Dipsea’s discretion, changes to any Dipsea policy;
   
   * Send email to the email address you provide to us to verify your Account
     and for informational and operational purposes, such as Account management,
     customer service, or system maintenance;
   
   * Process payment for purchases related to our Services;
   
   * Process transactions;
   
   * Prevent potentially prohibited or illegal activities;
   
   * Enforce our Terms.

 * Marketing Dipsea Services. Dipsea may use Personal Information to provide you
   with materials about offers and Services that may be of interest, including
   new content or Services. Dipsea may provide you with these materials by
   phone, postal mail, facsimile, or email, as permitted by applicable law. Such
   uses include:
   
   * To tailor content, advertisements, and offers;
   
   * To notify you about offers and services that may be of interest to you;
   
   * To provide Services to you and our sponsors;
   
   * For other purposes disclosed at the time that individuals provide Personal
     Information; or
   
   * Otherwise with your consent.

You may contact us at any time to opt-out of the use of your Personal
Information for marketing purposes, as further described in Section 5 below.

 * Research and Development. Dipsea may use Personal Information to create
   non-identifiable information that we may use alone or in the aggregate with
   information obtained from other sources, in order to help us to optimally
   deliver our existing Services or develop new Services. From time to time,
   Dipsea may perform research (online and offline) via surveys. We may engage
   third-party service providers to conduct such surveys on our behalf. All
   survey responses are voluntary, and the information collected will be used
   for research and reporting purposes to help us better serve individuals by
   learning more about their needs and the quality of our Services. The survey
   responses may be utilized to determine the effectiveness of our Services,
   various types of communications, advertising campaigns, and/or promotional
   activities. If an individual participates in a survey, the information given
   will be used along with that of other study participants. We may share
   anonymous individual and aggregate data for research and analysis purposes.

 * Services via Mobile Devices. Dipsea provides Services that are specifically
   designed to be compatible and used on mobile devices, including our App.
   Dipsea will collect certain information that your mobile device sends when
   you use such Services, like a device identifier, user settings, location
   information, mobile carrier, and the operating system of your device.
   Information about use of mobile versions of the Services may be associated
   with your Account.

 * Anonymous and Aggregated Information Use. Dipsea may use Personal Information
   and other information about you to create anonymized and aggregated
   information, such as de-identified demographic information, de-identified
   location information, information about the computer or device from which you
   access Dipsea’s Services, or other analyses we create. Anonymized and
   aggregated information is used for a variety of functions, including the
   measurement of visitors’ interest in and use of various portions or features
   of the Services. Anonymized or aggregated information is not Personal
   Information, and Dipsea may use such information in a number of ways,
   including research, internal analysis, analytics, and any other legally
   permissible purposes. We may share this information within Dipsea and with
   third parties for our or their purposes in an anonymized or aggregated form
   that is designed to prevent anyone from identifying you.

 * Sharing Content with Friends or Colleagues. Dipsea’s Services may offer
   various tools and functionalities. For example, Dipsea may allow you to
   forward or share certain content with a friend, such as an email inviting
   your friend to use our Services. Email addresses that you may provide for a
   friend or colleague will be used to send your friend or colleague the content
   or link you request, but will not be collected or otherwise used by Dipsea or
   any other third parties for any other purpose.

 * Other Uses. Dipsea may use Personal Information for which we have a
   legitimate interest, such as direct marketing, individual or market research,
   anti-fraud protection, or any other purpose disclosed to you at the time you
   provide Personal Information or with your consent.


3.3 COOKIES, PIXEL TAGS/WEB BEACONS, ANALYTICS INFORMATION, AND INTEREST-BASED
ADVERTISING

We, as well as third parties that provide content, advertising, or other
functionality on our Services, may use cookies, pixel tags, local storage, and
other technologies (“Technologies”) to automatically collect information through
the Services. We use Technologies that are essentially small data files placed
on your computer, tablet, mobile phone, or other devices (referred to
collectively as a "device") that allow us to record certain pieces of
information whenever you visit or interact with our Services, and to recognize
you across devices.

 * Cookies. Cookies are small text files placed in visitors’ computer browsers
   to store their preferences. Most browsers allow you to block and delete
   cookies. However, if you do that, the Site may not work properly.

 * Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece
   of code embedded on the Site that collects information about users’
   engagement on that web page. The use of a pixel allows us to record, for
   example, that a user has visited a particular web page or clicked on a
   particular advertisement.

 * Social Media Widgets: Our Site includes social media features such as the
   Facebook “Like” button and LinkedIn (that might include widgets such as the
   share this button or other interactive mini-programs). These features may
   collect your IP address, which page you are visiting on our site, and may set
   a cookie to enable the feature to function properly. These social media
   features are either hosted by a third party or hosted directly on our Site.
   Your interactions with these features are governed by the privacy policy of
   the company providing it.

 * Analytics. We may also use Google Analytics and Google Analytics Demographics
   and Interest Reporting to collect information regarding visitor behavior and
   visitor demographics on some of our Services, and to develop website content.
   This analytics data is not tied to any Personal Information. For more
   information about Google Analytics, please visit
   www.google.com/policies/privacy/partners/. You can opt out of Google’s
   collection and Processing of data generated by your use of the Services by
   going to tools.google.com/dlpage/gaoptout.

Our uses of such Technologies fall into the following general categories:

 * Operationally Necessary. We may use cookies, web beacons, or other similar
   technologies that are necessary to the operation of our Site and App. This
   includes technologies that allow you access to our Site and App; that are
   required to identify irregular site behavior, prevent fraudulent activity and
   improve security; or that allow you to make use of certain functions such as
   saved search;

 * Performance Related. We may use cookies, web beacons, or other similar
   technologies to assess the performance of our Site and App, including as part
   of our analytic practices to help us understand how our visitors use our
   Site, determine if you have interacted with our messaging, determine whether
   you have viewed an item or link, or to improve our Services;

 * Functionality Related. We may use cookies, web beacons, or other similar
   technologies that allow us to offer you enhanced functionality when accessing
   or using our Site and App. This may include identifying you when you sign
   into our sites or keeping track of your specified preferences, interests, or
   content viewed so that we may enhance the presentation of content on our
   Services;

If you would like to opt-out of the Technologies we employ on our Services, you
may do so by blocking, deleting, or disabling them as your browser or device
permits.


3.4 THIRD-PARTY SERVICES

The Site may contain links to other websites and other websites may reference or
link to our Site or other Services. These other domains and websites are not
controlled by us, and Dipsea does not endorse or make any representations about
Third-Party websites or social media platforms. We encourage our users to read
the privacy policies of each and every website and application with which they
interact. We do not endorse, screen or approve, and are not responsible for the
privacy practices or content of such other websites or applications. Visiting
these other websites or applications is at your own risk.

Dipsea’s Services may contain links and interactive features with various social
media platforms (e.g., widgets). If you already use these platforms, their
cookies may be set on your device when using our Site or other Services. You
should be aware that Personal Information which you voluntarily include and
transmit online in a publicly accessible blog, chat room, social media platform
or otherwise online, or that you share in an open forum may be viewed and used
by others without any restrictions. We are unable to control such uses of your
information when interacting with a social media platform, and by using such
services you assume the risk that the Personal Information provided by you may
be viewed and used by third parties for any number of purposes.


3.5 THIRD-PARTY PAYMENT PROCESSING

We sell Subscriptions (as defined in our Terms) to our Services. When you make
purchases through the Services, we process your payments through a third-party
application, including the Apple App Store (together with any similar
applications, “App Stores”). The third-party application may collect certain
financial information from you to process a payment on behalf of Dipsea,
including your name, email address, address and other billing information.


4. ONWARD TRANSFER—DIPSEA MAY DISCLOSE YOUR INFORMATION


4.1 INFORMATION WE SHARE

We may share your information as described in this Privacy Policy (e.g., with
our third-party service providers; to comply with legal obligations; to protect
and defend our rights and property) or with your permission.

 * We Use Vendors and Service Providers. We may share any information we receive
   with vendors and service providers. The types of service providers
   (processors) to whom we entrust Personal Information include service
   providers for: (i) provision of IT and related services; (ii) provision of
   information and services you have requested; (iii) payment processing; (iv)
   customer service activities; and (v) in connection with the provision of the
   Site and App. Dipsea has executed appropriate contracts with the service
   providers that prohibit them from using or sharing Personal Information
   except as necessary to perform the contracted services on our behalf or to
   comply with applicable legal requirements.

 * Business Partners. Dipsea may share Personal Information with our business
   partners and affiliates for our and our affiliates’ internal business
   purposes or to provide you with a service that you have requested. Dipsea may
   also provide Personal Information to business partners with whom we may
   jointly offer products or services, or whose products or services we believe
   may be of interest to you. In such cases, our business partner’s name will
   appear, along with Dipsea. Dipsea requires our affiliates and business
   partners to agree in writing to maintain the confidentiality and security of
   Personal Information they maintain on our behalf and not to use it for any
   purpose other than the purpose for which Dipsea provided them.

 * Marketing – Interest-Based Advertising and Third-Party Marketing. Through our
   Services, Dipsea may allow third-party advertising partners to set tracking
   tools (e.g., cookies) to collect information regarding your activities (e.g.,
   your IP address, page(s) visited, time of day). We may also share such
   de-identified information as well as selected Personal Information (such as
   demographic information and past purchase history) we have collected with
   third-party advertising partners. These advertising partners may use this
   information (and similar information collected from other websites) for
   purposes of delivering targeted advertisements to you when you visit
   non-Dipsea related websites within their networks. This practice is commonly
   referred to as “interest-based advertising” or “online behavioral
   advertising. We may allow access to other data collected by the Site to
   facilitate transmittal of information that may be useful, relevant, valuable
   or otherwise of interest to you. If you prefer that we do not share your
   Personal Information with third-party advertising partners, you may opt-out
   of such sharing at no cost by following the instructions in Section 5 below.

 * Disclosures to Protect Us or Others (e.g., as Required by Law and Similar
   Disclosures). We may access, preserve, and disclose your Personal
   Information, other Account information, and content if we believe doing so is
   required or appropriate to: (i) comply with law enforcement or national
   security requests and legal process, such as a court order or subpoena; (ii)
   respond to your requests; (iii) protect yours’, ours’ or others’ rights,
   property, or safety; (iv) to enforce Dipsea policies or contracts; (v) to
   collect amounts owed to Dipsea; (vi) when we believe disclosure is necessary
   or appropriate to prevent physical harm or financial loss or in connection
   with an investigation or prosecution of suspected or actual illegal activity;
   or (vii) if we, in good faith, believe that disclosure is otherwise necessary
   or advisable.

In addition, from time to time, server logs may be reviewed for security
purposes—e.g., to detect unauthorized activity on the Services. In such cases,
server log data containing IP addresses may be shared with law enforcement
bodies in order that they may identify users in connection with their
investigation of the unauthorized activities.

 * Merger, Sale, or Other Asset Transfers. If we are involved in a merger,
   acquisition, financing due diligence, reorganization, bankruptcy,
   receivership, sale of company assets, or transition of service to another
   provider, then your information may be sold or transferred as part of such a
   transaction as permitted by law and/or contract. In such event, Dipsea will
   endeavor to direct the transferee to use Personal Information in a manner
   that is consistent with the Privacy Policy in effect at the time such
   Personal Information was collected.


4.2 DATA TRANSFERS

All Personal Information collected via or by Dipsea may be stored anywhere in
the world, including but not limited to the United States, in the cloud, on our
servers, on the servers of our affiliates or the servers of our service
providers. Your Personal Information may be accessible to law enforcement or
other authorities pursuant to a lawful request. By providing information to
Dipsea, you consent to the storage of your Personal Information in these
locations.


5. OPT-OUT (RIGHT TO RESTRICT PROCESSING)


GENERAL

You have the right to opt out of certain uses and disclosures of your Personal
Information. Where you have consented to Dipsea’s Processing of your Personal
Information, you may withdraw that consent at any time and opt-out to further
Processing by contacting support@dipseastories.com. Even if you opt-out, we may
still collect and use non-Personal Information regarding your activities on our
Sites and/or information from the advertisements on third-party websites for
non-interest based advertising purposes, such as to determine the effectiveness
of the advertisements.


EMAIL AND TELEPHONE COMMUNICATIONS

If you receive an unwanted email from us, you can use the unsubscribe link found
at the bottom of the email to opt-out of receiving future emails. We will
process your request within a reasonable time after receipt. Note that you will
continue to receive transaction-related emails regarding Services you have
requested. We may also send you certain non-promotional communications regarding
Dipsea and our Services and you will not be able to opt out of those
communications (e.g., communications regarding updates to our Terms or this
Privacy Policy).


MOBILE DEVICES

Dipsea may occasionally send you push notifications through our App with other
notices that may be of interest to you. You may at any time opt-out from
receiving these types of communications by changing the settings on your mobile
device. Dipsea may also collect location-based information if you use our App.
You may opt-out of this collection by changing the settings on your mobile
device.


“DO NOT TRACK”

Do Not Track (“DNT”) is a privacy preference that users can set in certain web
browsers. DNT is a way for users to inform websites and services that they do
not want certain information about their webpage visits collected over time and
across websites or online services. Please note that we do not respond to or
honor DNT signals or similar mechanisms transmitted by web browsers.


COOKIES AND INTEREST-BASED ADVERTISING

As noted above, you may stop or restrict the placement of cookies on your
computer or remove them from your browser by adjusting your web browser
preferences. Please note that cookie-based opt-outs are not effective on mobile
applications. However, on many mobile devices, App users may opt out of certain
mobile ads via their device settings.

The online advertising industry also provides websites from which you may
opt-out of receiving targeted ads from our data partners and our other
advertising partners that participate in self-regulatory programs. You can
access these, and also learn more about targeted advertising and consumer choice
and privacy, at www.networkadvertising.org/managing/opt_out.asp, or
www.youronlinechoices.eu/ and www.aboutads.info/choices/. You can also choose
not to be included in Google Analytics
chrome.google.com/webstore/detail/google-analytics-opt-out/fllaojicojecljbmefodhfapmkghcbnh?hl=en.

To be clear, whether you are using our opt-out or an online industry opt-out,
these cookie-based opt-outs must be performed on each device and browser that
you wish to have opted-out. For example, if you have opted-out on your computer
browser, that opt-out will not be effective on your mobile device. You must
separately opt-out on each device. Advertisements on third-party websites that
contain the AdChoices link and that link to this Privacy Policy may have been
directed to you based on anonymous, non-Personal Information collected by
advertising partners over time and across websites. These advertisements provide
a mechanism to opt-out of the advertising partners’ use of this information for
interest-based advertising purposes.


6. RIGHTS OF ACCESS, RECTIFICATION, ERASURE, AND RESTRICTION

You may inquire as to whether Dipsea is Processing Personal Information about
you, request access to Personal Information, and ask that we correct, amend or
delete your Personal Information where it is inaccurate. Where otherwise
permitted by applicable law, you may send an e-mail to support@dipseastories.com
or use any of the methods set out in this Privacy Policy to request access to,
receive (port), seek rectification, or request erasure of Personal Information
held about you by Dipsea. Please include your full name, email address
associated with your Account, and a detailed description of your data request.
Such requests will be processed in line with local laws.

Although Dipsea makes good faith efforts to provide individuals with access to
their Personal Information, there may be circumstances in which Dipsea is unable
to provide access, including but not limited to: where the information contains
legal privilege, would compromise others’ privacy or other legitimate rights,
where the burden or expense of providing access would be disproportionate to the
risks to the individual’s privacy in the case in question or where it is
commercially proprietary. If Dipsea determines that access should be restricted
in any particular instance, we will provide you with an explanation of why that
determination has been made and a contact point for any further inquiries. To
protect your privacy, Dipsea will take commercially reasonable steps to verify
your identity before granting access to or making any changes to your Personal
Information.


7. DATA RETENTION

Dipsea retains the Personal Information we receive as described in this Privacy
Policy for as long as you use our Services or as necessary to fulfill the
purpose(s) for which it was collected, provide our Services, resolve disputes,
establish legal defenses, conduct audits, pursue legitimate business purposes,
enforce our agreements, and comply with applicable laws.


8. SECURITY OF YOUR INFORMATION

We take steps to ensure that your information is treated securely and in
accordance with this Privacy Policy. Unfortunately, the Internet cannot be
guaranteed to be 100% secure, and we cannot ensure or warrant the security of
any information you provide to us. We do not accept liability for unintentional
disclosure.

By using the Site or providing Personal Information to us, you agree that we may
communicate with you electronically regarding security, privacy, and
administrative issues relating to your use of the Site. If we learn of a
security system’s breach, we may attempt to notify you electronically by posting
a notice on the Site or sending an e-mail to you. You may have a legal right to
receive this notice in writing.


9. CHILDREN’S PRIVACY

The Services are not directed to users under 18, and Dipsea does not knowingly
collect Personally Identifiable Information from children under 13 (and in
certain jurisdictions under the age of 16) years of age. If you are under the
age of 18, you must have your parent’s permission to access the Services. Dipsea
urges parents to instruct their children never to give out their real names,
addresses, or phone numbers, without parental permission, when online. If you
learn that your child has provided us with Personal Information without your
consent, you may alert us at support@dipseastories.com. If we learn that we have
collected any Personal Information from children under 13 (and in certain
jurisdictions under the age of 16), we will promptly take steps to delete such
information and terminate the child’s Account.


10. REDRESS/COMPLIANCE AND ACCOUNTABILITY

If you have any questions about our privacy practices or this Privacy Policy,
please contact Dipsea by email at support@dipseastories.com. We will address
your concerns and attempt to resolve any privacy issues in a timely manner.


11. CHANGES TO OUR PRIVACY POLICY AND PRACTICES

This Privacy Policy may change from time to time. You understand and agree that
you will be deemed to have accepted the updated Privacy Policy if you use the
Services after the updated Privacy Policy is posted on the Services. If at any
point you do not agree to any portion of the Privacy Policy then in effect, you
must immediately stop using the Services.

 * Revision to the Privacy Policy. We may revise this Privacy Policy in our sole
   discretion, so review it periodically. If you continue to visit this Site and
   use the services made available to you after such changes have been made, you
   hereby provide your consent to the changes.

 * Posting of Revised Privacy Policy. If there are any material changes to this
   Privacy Policy, Dipsea will notify you by email or as otherwise required by
   applicable law. We will post any adjustments to the Privacy Policy on this
   web page, and the revised version will be effective immediately when it is
   posted (or upon notice as applicable). If you are concerned about how your
   information is used, bookmark this page and read this Privacy Policy
   periodically.

 * New Uses of Personal Information. Additionally, before we use Personal
   Information for any new purpose not originally authorized by you, we will
   endeavor to provide information regarding the new purpose and give you the
   opportunity to opt-out. Where consent of the individual for the Processing of
   Personal Information is otherwise required by law or contract, Dipsea will
   endeavor to comply with the law or contract.


12. REVISION HISTORY

Title (Effective Date)

Dipsea Privacy Policy

(Effective: 11/26/2018)