Privacy Policy

Last updated: September 24, 2024

Paula (“we”) operates the Paula mobile application (“Service”).
This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service, as well as your choices related to that data. Paula’s privacy policy is managed through a free privacy policy website.
At Paula, we are committed to protecting and respecting your privacy. This policy covers experiences on our platform for users aged 18 and over.

I. Types of Data Collected

(a) Personal Information

When using our Service, we may ask you to provide us with certain personally identifiable information (“Personal Data”) that can be used to contact or identify you. Personally identifiable information may include, but is not limited to:

Name
Avatar
Date of Birth and Age
Gender
Address, State, Province, Postal Code, City

(b) Usage Data

When you access the Service through a mobile device, we may automatically collect certain information, including but not limited to the type of mobile device you use, your mobile device’s unique ID, your mobile device’s IP address, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers, and other diagnostic data (“Usage Data”).

(c) Tracking and Cookie Data

We use cookies and similar tracking technologies to track activity on our Service and store certain information.
Cookies are files containing a small amount of data which may include an anonymous unique identifier. Cookies are sent from a website to your browser and stored on your device. Other tracking technologies used include beacons, tags, and scripts to collect and track information and improve and analyze our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

Session Cookies. We use session cookies to operate our Service.
Preference Cookies. We use preference cookies to remember your preferences and various settings.
Security Cookies. We use security cookies for security purposes.

(d) Permissions Explanation

To provide better service, our app may request the following permissions:

READ_PHONE_STATE: Allows the app to access phone state, including the device’s phone number, current call state, etc.
INTERNET: Allows the app to access the network for data transmission.
RECORD_AUDIO: Allows the app to record audio. Typically used for voice recognition or audio recording features.
CAMERA: Allows the app to access the device’s camera, typically used for taking photos or video recordings.
MODIFY_AUDIO_SETTINGS: Allows the app to modify global audio settings, such as volume and media audio streams.
ACCESS_NETWORK_STATE: Allows the app to get information about network connections, such as whether there is a network connection.
ACCESS_WIFI_STATE: Allows the app to get information about Wi-Fi status, such as whether connected to Wi-Fi.
READ_EXTERNAL_STORAGE: Allows the app to read files from external storage (e.g., photos, videos).
WAKE_LOCK: Allows the app to prevent the phone from going to sleep, commonly used to keep the screen on.
BLUETOOTH: Allows the app to access Bluetooth functionality.
BLUETOOTH_ADMIN: Allows the app to configure and manage Bluetooth devices.
BLUETOOTH_CONNECT: Allows the app to connect to paired Bluetooth devices.
READ_MEDIA_IMAGES: Allows the app to read media image files from the device.
READ_MEDIA_AUDIO: Allows the app to read media audio files from the device.
POST_NOTIFICATIONS: Allows the app to send notifications to the user’s status bar.
RECEIVE_BOOT_COMPLETED: Allows the app to receive broadcasts after the device has completed booting, which can be used to start services, etc.
com.google.android.gms.permission.AD_ID: Allows the app to access the advertising ID, typically used for ad tracking and analysis.
READ_PRIVILEGED_PHONE_STATE: This is a protected permission that allows the app to access more sensitive phone state information, typically restricted to system apps.
READ_MEDIA_VIDEO: This permission allows the app to read video files on the device. This is a security enhancement introduced in Android 10, designed to protect user media files.
VIBRATE: Allows the app to control vibration. Typically used for notifications or game feedback.
BIND_GET_INSTALL_REFERRER_SERVICE: Allows the app to bind to the install referrer service to get installation source information, such as from which ad link the app was downloaded.
com.android.vending.BILLING (usually marked as android:vending.BILLING): Allows the app to perform in-app purchases and subscription management. This permission is related to the integration with Google Play’s billing library.
FOREGROUND_SERVICE: Allows the app to run a service in the foreground. Even if the user is not directly interacting with the app, it can display a notification and the service will not be terminated by the system.
INSTALL_PACKAGES: Allows the app to install other application packages. This is a sensitive permission because it can be used to install untrusted applications.
BIND_JOB_SERVICE: Allows the app to create background tasks. Using the JobScheduler API, the app can perform delayed actions when specific conditions are met.

II. How We Use Your Personal Information

The primary reasons we use your personal information are to enable Paula to function properly, such as providing core functionalities of the Service, providing support, and maintaining platform security. We process your personal information only for specific purposes and based on legal grounds.
Generally, we use your personal information for:

To provide you with services related to your Paula account.
To respond to your inquiries and provide support.
To improve our performance and support user safety within the Service.
To enable you to enjoy certain functionalities of the Service and its attributes.
To allow third-party advertising/marketing partners to use cookies and other technologies to serve advertisements to free users of the Service.
To conduct surveys or obtain voluntary feedback on our properties.
To respond to law enforcement agencies, regulatory authorities, and other third parties to comply with legal obligations.

III. How We Share Your Personal Information

Paula’s personal center/discovery list. The Paula Service is intended to be a safe space where you can discover and interact with others in Paula. As part of the Service, Paula allows you to share your profile information, location, and other details with the Paula community.

Service Providers: We also transfer or disclose your information to carefully selected companies that provide services on our behalf, such as companies assisting us in developing and operating the Service, payment and refund service providers, IT service providers, security, hosting, analytics, mailing, billing, or marketing service systems. These entities are only authorized to access and use your personal information to the extent necessary to provide services to us and may not use it for any other purpose.
Business Advisors: For example, we may share your information with our lawyers, accountants, business advisors, insurers, and auditors whenever they need to provide services to us.
Necessary Disclosure to Government Agencies, Judicial Bodies, Regulatory Authorities, or Other Third Parties: When required by law or when we believe it is necessary, we may disclose personal information to government agencies, judicial bodies, regulatory authorities, or other third parties: to comply with the law or in response to compulsory legal processes (such as search warrants, subpoenas, or court orders);
i. To verify or enforce compliance with the terms and policies governing our Service and investigate fraud or other illegal activities related to the use of our Service or affecting our business; and
ii. To protect and defend our rights, property, and the business operations, security of our company, our respective affiliates, employees, business partners, customers, or the public.
Corporate Transactions: If we are involved in a merger, sale, acquisition, asset divestiture, restructuring, reorganization, dissolution, bankruptcy, or any other change of ownership or control, we may transfer your information.
Other Parties with Your Consent or at Your Direction: In addition to the disclosures described in this Privacy Policy, we may share information about you with third parties when you separately consent to or request such sharing.

User content that you voluntarily disclose and post to the Service ("User Content") may be publicly accessible. Once you share User Content or make it public, it may be re-shared by others. This Privacy Policy does not apply to such publicly disclosed information.

IV. How We Retain Your Personal Information

We take appropriate measures to ensure that information is processed and retained according to the following principles:

At least for the period during which the information is used to provide you with the Service.
If required for legal or security purposes, personal information may be retained for a longer period. For example, Paula may retain some account information, device identifiers (e.g., IDFV and Android ID), and limited log information for accounts that have been disabled or violated Paula's Terms of Service and Conditions and/or Paula's Community Guidelines. In some cases, Paula may also retain chat messages due to violations.

V. Your Choices and Rights

Where permitted, we may contact you via email, telephone, text message, or push notifications through our mobile application. To submit a request regarding our communication with you, please note:

If you choose not to receive our marketing communications, we will still send you service-related information to provide necessary information related to your contract and the services you use (e.g., updates to our Terms of Use).
To the extent permitted by applicable law, you may request access to your personal information, or correct or update outdated or inaccurate personal information we hold about you. You may also have the right to request the deletion of personal information we hold about you. You can access and update some of your information through your account settings. It is your responsibility to keep your personal information up-to-date.
To the extent permitted by applicable law, you may also request restrictions on the processing of your personal information and request that we provide you with personal information we have collected about you for your own purposes and share (port) this data to another controller.

In addition, to the extent permitted by applicable law, in certain situations, you may object to the processing of your personal data (especially when we do not need to process the data to meet contractual or other legal requirements).

Under applicable law, you also have the right to object at any time to the use of your personal information for direct marketing purposes, including analytics related to direct marketing.

However, these rights may be subject to limitations, such as when fulfilling your request would reveal the personal information of others, infringe upon the rights of third parties (including our rights), or if you request us to delete information that we are legally required to retain or have a compelling legitimate interest in retaining. When responding to your request, we will inform you of any relevant exemptions we rely on.

VI. How We Protect Your Personal Information

At Paula, we take the privacy and security of your personal information (including sensitive data) very seriously. Our cybersecurity team actively maintains the integrity, confidentiality, and availability of Paula, and our policies and protocols focus on protecting your personal information and sensitive personal information. In our ongoing battle against threat actors, we continuously strive to enhance our defenses. That said, no method of transmission over the Internet or electronic storage is completely secure, and Paula cannot guarantee the security of your personal information. Our security, safety, and privacy terms are provided "as is." Therefore, we cannot guarantee their effectiveness and error-free operation, nor can we ensure absolute confidentiality, anonymity, or personal safety. Individuals who have particular concerns about how their data is protected are advised not to use these features. If required by law, we may notify you electronically or in writing of any unauthorized access to your personal information.

VII. Personal Information of Children

Our Service is not directed to children under eighteen (18) years of age, and we do not knowingly solicit or collect personally identifiable information from children under eighteen (18) years of age in the Service. Additionally, we do not knowingly sell the personal information of children under sixteen (16) years of age. If we become aware that we have inadvertently received personally identifiable information from a user under eighteen (18) years of age, we will promptly delete such information from our records. If you believe a child under eighteen (18) years of age may have provided us with personal information, please contact us using the information specified in the "Contact Us" section below.

VIII. Contact Us

For more information about our privacy practices or to exercise any rights you may have under applicable law, please contact us via email [email protected] or customer service.

IX. Updates to Our Privacy Policy

We reserve the right to change this privacy policy at any time. Any changes to this privacy policy will be effective upon posting. We recommend that you keep a copy of this privacy policy for reference and review this policy periodically to stay informed of any changes. Your continued use of the website constitutes your acceptance of any changes.