Privacy Policy


This privacy policy (“the Policy”) explains how and for what purposes Clear Summit LLC, d/b/a “ClearSummit”, and its related companies as owners, controlling parties, and authorized licensors of the app (collectively, “we”, “us”, or “our”) collect, use, and share information of users (“you” or “your”) of the mobile application VFF (“the app”).

  1. INTRODUCTION.

We value the privacy of our users and want to make sure there is clarity about why we collect your information and what we do with it. We collect information and data in order to provide the best possible product(s) to all of our users. This Policy explains what information about you we collect, and how we use it. Please read this Policy carefully. 

The Policy applies to anyone using the app, no matter their age. It also applies to the parents or guardians of users under age 13. By continuing to use the app, you are agreeing to be bound by the Policy. 

If you are under age 13, you need your parent or guardian’s permission to use the app. You shouldn’t use the app without their ok. 

You are under no obligation to provide any information to us, however, we may not be able to provide you with access to the app or certain features if you decide not to share information we request.


2. INFORMATION WE RECEIVE.

We may collect the following information (“Your Information”) from you:

  1. Date of Birth

  2. Pronouns

  3. User Activity

  4. Crash and Performance Activity

  5. Device ID

  6. Your activity within the app

  7. Audio Data (voice recordings)

  8. Phone Number

  9. Username

  10. Visual Data (selfie)

We ask you not to use your real name or your phone number when creating a Username. This helps protect your safety and privacy. 


3. INFORMATION WE SHARE WITH THIRD PARTIES, AND HOW WE SHARE IT WITH THEM.

We may share the following information with third parties, such as analytics software providers (e.g., Mixpanel). For example, we may use your Device ID performance activity to investigate crashes or bugs we find in the app. Any third parties we share with are required to use the information for the relevant tasks. They are not allowed to use the information for other purposes. We do not sell this data to anyone, and it is not used by us or third parties for commercial purposes outside of the app. 

  1. Date of Birth

  2. Pronouns

  3. User Activity

  4. Crash and Performance Activity

  5. Device ID

  6. Your Activity within the App


We may share your Audio Data with third party machine learning and artificial intelligence (AI) platforms, such as Chat GPT, to assist us with content moderation. We only store this data for up to 7 days, and with AI platforms that will not copy or keep your Audio Data.

We may share your Phone Number with a third-party platform, such as Twilio, to provide 2-factor authentication when you initially create your account or when you reset your password. We do not use it for any purpose other than account management within the app.

We share your Username with other users in the app.

Your Visual Data is used to give an estimated age, and is stored on our servers. It is not shared with any third parties, for any reason whatsoever. 

We also may share Your Information with law enforcement or if ordered to do so by a court that has jurisdiction over us, or to comply with other lawful requests or demands. 

We may share access to and/or transfer Your Information as part of a merger, acquisition, sale of assets, transfer of rights, or similar transaction. 

In some circumstances, we share data and information that doesn’t identify you in order to comply with reporting requirements, or for business or marketing purposes. 


4. WHY WE USE YOUR INFORMATION.

We may use Your Information as part of the creation, improvement, and maintenance of the app. We may use Your Information as part of our business processes to do any of the following: 

  • To operate the app and its current or future features

  • To research and investigate ways to improve or expand the app

  • To provide technical or customer support to you or other users 

  • To find and fix errors or bugs in the app

  • To protect our, your or other users’ safety and security

  • To comply with the law and our own policies, including the Terms of Use

  • To communicate with you


5. HOW YOU CAN VIEW, CHANGE, OR REMOVE INFORMATION.

If you want to view, correct, or delete Your Information, please email us at <email>. If you are under 13 years old, you need to have your parent or guardian email us at that address. You may also delete your account in the app, and if you do so, we will delete your account and all data and information, including Your Information, associated with the account.


6. SECURITY OF YOUR INFORMATION.

 We do our best to keep your information secure, and follow industry standards and best practices to do so. We cannot take responsibility for any unauthorized access or loss of your information that is beyond our reasonable control, and to the fullest extent permitted by law, we are not liable for any unintentional disclosure.

If we learn that Your Information has been involved in a data breach or other unauthorized action, we will notify you in accordance with the law.


7. CHANGES TO THIS PRIVACY POLICY.

We may update this privacy policy from time to time, and will include the date of the most recent updates here. You should review this page regularly. 

Most recent update: August 9, 2023


8. CONTACT INFORMATION.

If you have questions about this Policy, or if you have requests related to your Personal Information, you can reach us at support@vffapp.com, or at 

Clear Summit LLC

Attn: Privacy Manager

6339 Charlotte Pike

Unit #B116

Nashville, TN 37209


10.  LOCATION- SPECIFIC PROVISIONS.

  1. USERS LOCATED IN CALIFORNIA

In accordance with California law, you may have the following rights:

  1. Access to/Portability of Your Information. You can receive a copy of Your Information we have collected, used, disclosed, or shared about you in the past 12 months, consistent with legal requirements. If you are a California resident, you have the right to request the categories of Your Information disclosed for a business purpose, the categories of sources from which Your Information was collected, our business or commercial purposes for collecting Your Information, and the categories of third parties to whom we disclosed Your Information. We have already disclosed most of this information herein. In addition, you may have the right in some cases to receive or have Your Information in a portable format or transferred to another party.

  2. Correction. You can request correction of Your Information where it is inaccurate or incomplete. 

  3. Deletion. You can request we delete Your Information, subject to certain exceptions prescribed by law.

  4. Restriction of or Objection to processing. You can request restriction or object to the processing of Your Information, and you have the right to opt in or opt out of the sale or sharing of Your Information to third parties, if applicable, where such requests are permitted by law. Please note that we do not currently sell or share Personal Information, as defined under the California Consumer Privacy Act and the California Privacy Rights Act. For that reason, we do not currently offer a mechanism for California residents to opt out of the sale or sharing of Personal Information, which includes Your Information. We have no actual knowledge of selling or sharing the Personal Information of minors under 16 years of age.

  5. Non-discrimination. You have the right to not receive discriminatory treatment by exercising your privacy rights. We do not discriminate against California residents who exercise their privacy rights.

  6. To protect your privacy, we will take steps to verify your identity before fulfilling your request so that we can ensure you are the owner of the account making the request.

  1. USERS LOCATED IN COLORADO, CONNECTICUT, AND VIRGINIA

If you are a resident of Colorado, Connecticut, or Virginia, you may have additional privacy rights, including the rights to:

  1. Confirm whether we process Your Information.

  2. Access, correct and delete certain pieces of Your Information.

  3. Receive copies of Your Information data in a portable format.

If you are a resident of one of these states, and wish to assert these additional rights, please contact us at <email>.

  1. USERS LOCATED IN THE EUROPEAN ECONOMIC AREA (EEA), THE UNITED KINGDOM, OR SWITZERLAND

If you are a resident of Europe in the above locations, the following provisions and notices apply to you. We collect the same data and Your Information as described above. 

  1. The basis for collecting your Phone Number and Username is to create your account and to provide the basic functions of the app, under GDPR Art. 6 §1sent 1 lit. b. 

  2. The basis for collecting your Date of Birth, your Audio Data, and your Video Data is to provide the basic functions of the app, in performance of a contract as authorized under GDPR Art. 6 §1 sent. 1 lit. b. We also have a legitimate interest in providing a safe and secure platform for children, which is the primary purpose of collecting Your Information listed under this section.

  3. We may access, process, or review Your Information as part of our customer support and response to requests from you or other users. The basis for this use of Your Information is your consent and performance of a contract under Art. 6 §1 sent. 1 lit. a, b. 

11.  GOVERNING LAW AND JURISDICTION.

The app is operated from the United States of America.  By using the app, you consent to having your personal information processed in the United States. Any dispute or claim arising out of or in connection with this Policy or its subject matter shall be governed by and construed according the laws of the United States, without giving effect to any conflict of laws provisions.