Privacy Policy

This Privacy Policy covers what Virgin ("Virgin", "Virgin App", "we", "us" or "our") does with the Personal Information (as defined herein) that you share with us and the data we collect when you are accessing our App and/or our Service. Personal Information about our users is an integral part of our business, so please read this Privacy Policy carefully. By using or accessing our App or our Service, you agree to the privacy policies outlined below. Capitalized terms not defined in this Privacy Policy have the meanings provided in our Terms of Service.

What Does this Privacy Policy Cover?

This Privacy Policy covers Virgin's treatment of Personal Information that we collect while you are using the App and the Service. This policy does not apply to the practices of third parties that Virgin does not own or control, including but not limited to third party services you access through Virgin, the App or the Service, or to individuals that Virgin does not employ or manage. As our Service integrates with third party sites, such as Instagram, and other sites and social networks, we assume that you are already aware of the privacy policies of those other sites and networks when using our App and/or our Service and when you allow us to interact with these sites and networks on your behalf.

The Service

Virgin is a new type of social network based on voice and video — where people around the world come together to talk, listen, and learn from each other in real-time. It's a place to meet with friends and with new people to tell stories, ask questions, debate, learn, and have impromptu conversations.

According to relevant international regulation, we will not provide the Service in the following countries or territories:

• Cuba
• Iran
• Syria
• North Korea
• Crimea

What Virgin Collects and Shares About You

Here's an overview of the information we collect when you interact with our App, and examples of how we use the specific types of information. We may collect:

• Account data, such as your first and last name, organization name, email addresses, phone number, profile picture, and user name.
• Your contacts' phone numbers (if you choose to authorize this). To help users connect with people they know, we offer them the option to invite friends to join them on Virgin. To take advantage of this feature, users can opt in to share phone numbers from their address book or add phone numbers manually.
• Names of friends you choose to invite to join you on the App.
• Interests, usage, and connections, including information about your interests (if you choose to add them) and how you use the App, such as the types of Virgin conversations you engage in, content you share, features you use, actions you take, people or accounts you interact and connect with, and the time, frequency, and duration of your use.
• Communications that we exchange with users when they contact us with questions or feedback, including feedback about interacting with other users.
• Information provided by social media companies, if you interact with our pages on their services or connect your social media accounts. Connecting your social media accounts allows the App to authenticate your identity and access limited information about those accounts. The information that social networking accounts provide to Virgin may depend on the privacy settings you have with each company, so please consult their privacy and data practices.
• Device data, such as device IP address (and derived location), device name and operating system, browser type and settings, telecommunications provider, operating system, the date and time of App use, interactions with the App, and the time, frequency, and duration of the interactions.

How We Protect Your Information

Protecting user privacy and personal information is a top priority for us. We process your personal information to improve and enforce our security measures, combat spam, malware, malicious activities, or security risks, and to monitor and verify your identity so that unauthorized users do not access your account with us. Access to any user information is restricted to our employees, contractors, agents, and third-party service providers ONLY who need to know the information in order to provide, operate, develop, maintain, support, and optimize our service experience and security. We use password protection, access logs, and system monitoring to safeguard the confidentiality and security of all user information. Due to the inherent nature of the internet and related technology, we do not guarantee the protection of information under our control against loss, misuse, or alteration.

Use of Personal Information by Third Parties and the Public

Third Parties

You expressly agree that all of your User Contributed Content, as well as your Personal Information, images and any other data or information contained in your account associated with the implementation of Virgin, may be published and made available to the rest of Virgin's users. Furthermore, other users may follow you on the App, and your followers can see, for example, the User Contributed Content that you have uploaded to the App. Individuals reading this information may use it or disclose it to other individuals or entities without our control and without your knowledge. We therefore urge you to think carefully about including any specific information you may deem private in your User Contributed Content or other content that you create in the Service.

Publicly Available Information

Please note that certain information, including without limitation, your public user profile information (including username, public photo, etc.), will be available to the Internet's general public while you participate in some aspects of the Service, so you should exercise discretion when using the Service. Personal information disclosed by you may be collected by other third parties or users of such Services and may result in unsolicited messages or may be shared with or disclosed to other third parties. We are not responsible for protecting such information that you may disclose to third parties through our Service (for example, sending your personal telephone number to another user through the Service). To the extent that you use a profile that may be available to others on our Service, you are solely responsible for its content and accuracy at all times. To edit, change, or delete such information, follow the instructions provided on our Service.

Use of Cookies

We may use cookies to manage our users' sessions and to store preferences, tracking information, and language selection. Cookies may be used whether you register with us or not. "Cookies" are small text files transferred by a web server to your hard drive and thereafter stored on your computer. The types of information a cookie collects include the date and time you visited, your browsing history, your preferences, and your username. In some instances, our third party service providers may use cookies. We cannot control or access cookies used by third party service providers. This Privacy Policy covers only Cookies used by us, and not any cookies used by third parties. You have the ability to either accept or decline the use of cookies on your computer, whether you are registered with us or not by clicking ok in the web site pop up window related to the use of cookies. Typically, you can configure your browser to not accept cookies. However, declining the use of cookies may limit your access to certain features of the App and the Service, including without limitation, certain interactive features of the App.

Use of Related Personal Information in Connection with Third Parties and Our Partners

To protect your privacy, we limit the sharing of Personally Identifiable Information with third parties. We conduct our business with great respect for the confidential nature of the information being provided. We will not share information about you except as outlined below. We do not sell, license, lease or otherwise disclose non-public information about you with such third parties that is likely to uniquely identify or locate any individual or entity to any unaffiliated third party for any reason, except as noted here.

1. We may share or disclose user information with such user's consent.
2. Where such disclosure is required or appropriate pursuant to laws or securities regulations, including cooperating with government agencies, other regulatory bodies and law enforcement officials, performing background checks, resolving disputes or performing risk-management functions.
3. To help us improve our services to you, we may engage another business to help us to carry out certain internal functions such as account processing, client services or other data collection relevant to our business. We may also provide a party with client information from our databases to help us analyze and identify client needs or to notify clients of particular services offerings. Use of the information shared is strictly limited to the performance of the task we request and used for no other purpose.
4. As mentioned above, we may share aggregate information about our users with our partners, such as the number of users who used a particular service, which would include as a part thereof your personal information. We do not have any control over, and are not responsible for, our partner's use of this information.
5. We may share information with non-financial companies that perform services for us.
6. We may share information with affiliates if the information is required to provide the services you requested. An affiliate is a company that we own or control, or with which there is common ownership with us.
7. We may also disclose your information as necessary to credit reporting or collection agencies, or when necessary to protect our rights or property.
8. While your Personally Identifiable Information is protected as outlined above, we reserve the right to use, transfer, sell, and share aggregated, anonymous data about our users as a group for any business purpose, such as analyzing usage trends and seeking compatible advertisers and partners.
9. We may share information with the acquiring or surviving entity in addition, as our business changes, we may buy or sell various assets. If we are involved in a merger, acquisition, or sale of all or a portion of our assets, you will be notified via email and/or a prominent notice on our website of any change in ownership or uses of your personal information, as well as any choices, if any, you may have regarding your personal information.
10. Your information may also be stored and processed in any country in which we provide service due to server facilities and third-party service teams. By using our service, you consent to any such transfer of information outside of your country.

If you do not agree with all of the terms of this Privacy Policy, please do not use our service. Community safety is our number one priority and some of the above user information is mandatory in order to create a safe community for all users.

Children's Privacy

Virgin is intended for use solely by individuals who are eighteen (18) years of age or older. The App and its Services are not directed to, and must not be accessed or used by, individuals under the age of 18. In compliance with the Children's Online Privacy Protection Act ("COPPA"), which requires that online service providers obtain parental consent before knowingly collecting personally identifiable information from individuals under the age of eighteen (18), we do not knowingly collect or solicit personal information from individuals under the age of 18. If we become aware that we have inadvertently collected personal information from an individual under 13, we will promptly delete such information from our records. If you believe that an individual under 18 may have provided us with personal information, please contact us at support@virgin.chat. Individuals under the age of 18 are strictly prohibited from using the Services.

Government Requests for Information

We may notify affected users of any emergency government or law enforcement requests for their account information, however, we are not required to do so and may, in fact, be precluded from doing so by applicable law. Furthermore, we may disclose account information to a government agency or to law enforcement in response to a valid emergency disclosure request. In connection with any such request, we will require that any such law enforcement or government agency comply with basic principles of free expression, clearly state the legal reason for ascertaining the requested information, and respect the security and infrastructure of the App and the Service by not building any security kinks into our backend. Virgin will evaluate all emergency disclosure requests on a case-by-case basis in compliance with relevant law. Furthermore, if Virgin receives information that provides us with a good faith belief that there is an exigent emergency involving the danger of death or serious physical injury to a person, we may provide information necessary to prevent that harm, if we have it. We may not comply with requests for a variety of reasons, including, but not limited to, a request that fails to identify a Virgin account or a request that is overly broad, in which case we may seek to narrow that request. Virgin will comply with all applicable laws regarding any government or emergency request for information.

Email Contact

Accepting our privacy policy, you give the express consent to Virgin to contact you and/or send to you commercial communications by any means, including electronic communications, to inform about our products, services, offers, or any commercial content related to us or our products or services which, at Virgin's discretion, may be interesting to you. If you do not want to receive commercial communications, you can always opt-out by following the unsubscribe instructions provided in each such communication. To opt-out of commercial communications sent by any medium, including third party social networks, you can opt-out at any time by logging into the website/app and adjusting your user preferences in your account profile by unchecking the relevant boxes. Please note that even if you opt-out from receiving commercial communications, you may still receive administrative communications from Virgin, such as transaction confirmations, notifications about your account activities (e.g., account confirmations, password changes, etc.), and any other important announcements.

Account Information Access and Deletion

Access and Updates. We strive to let you access and update the personal information that we have about you. There are limits though to the requests we'll accommodate. We may reject a request for a number of reasons, including, for example, that the request risks the privacy of other users or is unlawful. You can access and update your account information right in the app by visiting the app's Settings page. If you need to access, update, or delete any other personal information that we may have, you can put in a request via email at support@virgin.chat. Because your privacy is important to us, we may ask you to verify your identity or provide additional information before we let you access or update your personal information. You can also remove our service from your mobile device or process account deletion.

Revoking Permissions. If you change your mind about our ongoing ability to collect information from certain sources that you have already consented to, such as your phonebook, camera, photos, or location services, you can simply revoke your consent by changing the settings on your device if your device offers those options, but this may result in certain services to lose full functionality.

Account Deletion. You can remove your data anytime you want by a) ["Me" > "Settings" > "Apply for account deletion"] in our App; or b) sending your request to us via email at support@virgin.chat. For security reasons, your account cannot be deleted unless you follow our instructions. Upon your request, we will temporarily disable your account to prepare for removal. During this time you can cancel your deletion request and we will resume your account. Upon the end of 30 days, we will use commercially reasonable efforts to remove your data from our servers. Please note, some information may remain in archived/backup copies for legal purposes or required by law (for instance, some "traffic data" may be kept for one year to comply with statutory data retention obligations).

Policy & Term Updates

We may change and update this Privacy Policy from time to time, and you should regularly check the App for the most up-to-date version. Should you have any questions regarding the content, please feel free to contact us by using our contact page.

Community Guidelines

Virgin is a global community, and we're committed to creating an online space where individuals can genuinely connect with new people and make new friends, securely and safely. We created these guidelines to make sure every user has a safe and positive experience on Virgin. Any violation of these guidelines may result in a permanent account ban from Virgin.

Be Respectful

We have a zero-tolerance policy for offensive content and abusive behavior. Bullying, harassment, discrimination, and inappropriate content are strictly prohibited on Virgin. We take this policy very seriously and have specific moderation procedures in place for reported users and content. Users are encouraged to help keep Virgin safe by reporting or blocking users who go against this policy. Reported content will be removed immediately until it is reviewed. Conversations with blocked users will be removed along with any type of profile engagement. If you see someone breaking the rules anywhere on Virgin, report them using the Block/Report button, and we will take it from there.

Things That Are NOT Allowed on Virgin:

• Bullying and harassment
• Nudity
• Drugs and illegal activity
• Spam

18 and Over

The age rating for Virgin is 18+. Individuals under the age of 18 are strictly prohibited from using this platform. Any individuals found to be under 18 will be blocked from accessing the site, and their accounts will be terminated. Help us keep Virgin safe and compliant by reporting any individuals you suspect to be under the age of 18. All accounts in violation of this policy will be subject to permanent removal.

Sexually Explicit Content

Virgin has a zero-tolerance policy for users promoting and/or distributing pornographic content. Saving, asking and/or threatening to post explicit content is strictly prohibited. We would also like to emphasize the uncompromising enforcement that we place regarding content involving minors. Any and all indications of child sexual exploitation are promptly reported and turned over to the authorities.

Spam

Spam, bot activity, and deceptive practices are not allowed on Virgin. To enforce this policy, we do not allow images or links of any kind to be sent in Direct Messages. Spam and bot-like messages are also flagged to our system and are blocked before they are received by the end-user. Help keep Virgin safe by reporting users and content that you suspect are spam by tapping report and selecting "spam" as the reason for reporting. All accounts found violating this guideline will be terminated.

Impersonation

Any attempt to impersonate others is strictly prohibited. This includes any type of deception about who you are, whether it's lying about your age, your name, using someone else's photos, and any other type of deception. Help keep Virgin safe by reporting users who you suspect are pretending to be someone they're not by tapping the report and selecting "spam" or "underage" as the reason for reporting. All accounts found violating this guideline will be terminated.

Obey the Law

Illegal activity of any nature is prohibited on Virgin. Safety is our number one priority. Please do not ever engage in activity or post content of any of the following: threats, drugs, weapons, violence, underage users, sexual services, hate speech, discrimination, impersonation, selling or promoting illegal services.

Contact Us

We take these Community Guidelines seriously and ask that you follow them in the spirit in which they are intended. We further recognize that these guidelines must continually evolve, so please do contact us with questions, suggestions, or comments.

Thank you for reading, and for helping us build an amazing community!

Team Virgin