21x20 Media, Inc. PRIVACY POLICY FOR APP USERS

21x20 Media, Inc. (“21x20 Media”) knows that you care about how your personal information is used and shared, and we take your privacy seriously. Please read the following to learn more about our privacy practices (“Privacy Policy”). By using a mobile application that incorporates or utilizes 21x20 Media’s services (collectively, the “Services”) you accept the practices outlined in this Privacy Policy.

WHAT DOES THIS PRIVACY POLICY COVER?

This Privacy Policy covers 21x20 Media’s treatment of personally identifiable information (“Personal Information”) that 21x20 Media gathers when you access or use the Services. This Privacy Policy does not cover (i) use of information by third parties we do not control (including Developers), or (ii) our collection or use of Personal Information collected other than through Apps (e.g., through use of our websites at www.writing.com.com or www.21x20.com (the “Websites”)). Our collection and use of information via our Website is covered in our Website Privacy Policy.

WHAT PERSONAL INFORMATION DOES 21x20 Media COLLECT?

We collect the following types of information from you when you use one of our Apps: your IP address (including country of origin), App version, device operating system (including version), device make and model, UDID or other unique device identifier (only in anonymized form—i.e., not associated with any other personally identifiable information), and the current time each time you launch an App. In addition, while you are using an App, we collect information regarding the various actions and paths you take when using that App (“Events”), including a timestamp associated with each Event.

Cookies/SessionIDs – Although the Services do not place cookies on your device when you use an App, each time you launch an App, we assign a unique session ID (a “Session ID”) to that launch of the App which we associate with the other information that we collect during your use of the App during that launch session. We do not associate Session IDs with Personal Information.

HOW DOES 21x20 Media USE PERSONAL INFORMATION?

We only use your Personal Information (i) in aggregate, anonymized form for marketing purposes (e.g., to describe the total number of users who are using Apps which use the Service), (ii) to further develop and improve our Services.

WILL 21x20 Media SHARE ANY OF THE PERSONAL INFORMATION IT RECEIVES?

We do not rent, sell or disclose your Personal Information to anyone – except for the following limited purposes:

Agents: We may employ other companies and people to perform tasks on our behalf – meaning they are helping us provide our Services. We may share your Personal Information with such companies/persons solely as necessary for them to help us provide the Services. Unless we tell you differently, 21x20 Media’s agents do not have any right to use Personal Information we share with them beyond what is necessary to assist us.

Business Transfers: In some cases, we may choose to buy or sell assets. In these types of transactions, customer information is typically one of the business assets that are transferred. Moreover, if 21x20 Media, or substantially all of its assets were acquired, or in the unlikely event that 21x20 Media goes out of business or enters bankruptcy, customer information would be one of the assets that is transferred or acquired by a third party.

Protection of 21x20 Media and Others: We may release Personal Information when we believe in good faith that release is necessary to comply with the law; enforce or apply our conditions of use and other agreements; or protect the rights, property, or safety of 21x20 Media, our employees, our users, or others.

With Your Consent: Except as set forth above, you will be notified when your Personal Information may be shared with third parties, and will be able to prevent the sharing of this information.

CONDITIONS OF USE

If you decide to access or use the Services, any possible dispute over privacy is subject to this Privacy Policy and our Terms of Use, including limitations on damages, arbitration of disputes, and application of Pennsylvania state law.

WHAT CHOICES DO I HAVE?

Data collected is anonymous and whether or not you use the app is your choice.

CHANGES TO THIS PRIVACY POLICY

21x20 Media may amend this Privacy Policy from time to time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used. If we make changes in the way we use Personal Information, we will notify you by changing this document and posting on our website. Users are bound by any changes to the Privacy Policy when he or she uses the Services (including through any App) after such notice has been provided.

QUESTIONS OR CONCERNS

If you have any questions or concerns regarding privacy in connection with the Services, please send us a detailed message at privacy@21x20.com. We will make every effort to resolve your concerns.

Effective Date: January 27, 2016

21x20 Media Inc.
PO Box 22131
Lehigh Valley, PA 18002