This Privacy Policy explains how Gist App LLC, a subsidiary of AppLovin Corporation (“Gist,” “we,” “our,” or “us”) collects, uses, discloses, and otherwise processes your personal information in connection with your use of the Gist mobile applications, content, our website, and any related products, services, and features that we may provide or make available from time to time (collectively, the “Services”). This Privacy Policy also explains your rights and choices regarding your personal information.

This Privacy Policy covers the following topics:

1. PERSONAL INFORMATION WE COLLECT AND HOW

2. HOW WE USE YOUR INFORMATION

3. DISCLOSURE OF YOUR INFORMATION

4. MANAGING YOUR INFORMATION AND PRIVACY CHOICES

5. SECURITY OF YOUR INFORMATION

6. DATA RETENTION

7. AGE RESTRICTION AND CHILDREN’S PRIVACY

8. ADDITIONAL U.S. MULTI-STATE PRIVACY NOTICE

9. CHANGES TO THIS Privacy Policy

10. CONTACT US

PERSONAL INFORMATION WE COLLECT AND HOW

When you interact with or use the Services, we may collect personal information about you. We may collect this information directly from you (e.g., when you create an account), automatically (e.g., information about how you use the Services), or from other sources and third parties.

a. Information We Collect from You Directly

Registration and Account Information – When you create, access, maintain, or recover an account, we collect information such as your username, display name, email address, phone number, password, one-time verification codes, date of birth, authentication credentials, account preferences, referral codes, and records relating to your acceptance of our Terms of Service and Privacy Policy. If you register or sign in using a third-party authentication provider (such as Google or Apple), we also receive information described in the “Information We Collect from Other Sources” section below.

Contacts – If you choose to sync your contacts, we may collect information such as phone numbers and email addresses from your device’s address book. We use this information to help you find and connect with people you know and to personalize the accounts and posts recommended to you. You can turn off contact syncing at any time through your device settings.

Profile Information – We collect information that you choose to include in your profile, such as your username, nickname, profile photo, biography, gender, interests, privacy preferences, and other profile information you elect to provide. Certain profile information may be visible to other users depending on your settings.

User-Generated Content and Communications – We collect information and content that you create, upload, transmit, publish, or otherwise make available through the Services, including posts, articles, discussions, comments, reactions, likes, saves, shares, reports, direct messages, chat content, photos, videos, audio recordings, captions, profile images, and associated metadata. We also collect information relating to your interactions with such content, including reports, moderation actions, and engagement activity. This includes content you create or upload through the Gist camera, microphone, or your device’s photo library — in each case only after you grant the corresponding device-level permission. We may also collect and process content that you authorize us to import or obtain from third-party platforms. Such content may include videos, images, audio, captions, metadata, usernames, profile information, engagement information, and related attribution information associated with the authorized content.

Direct Messaging Information – If you use messaging or chat features, we collect message content, media attachments, conversation identifiers, participant information, timestamps, read receipts, moderation status information, and related metadata necessary to provide and secure the messaging functionality.

Preferences and Settings – We collect information regarding your preferences and settings, including notification preferences, content interests, account privacy settings, and other configuration choices.

Customer Support Information – If you contact us, we collect your contact information, account information, communications with us, and any information you choose to provide in connection with your request.

Communication Preferences – We collect information about your preferences, such as when you subscribe to updates, alerts, or other communications.

Surveys, Research, Promotions, and Feedback – If you participate in surveys, research projects, competitions, contests, referral or promotional programs, or similar activities, we collect your contact information (e.g., name, email, phone number, address) and any additional information you provide in connection with those activities, such as responses, recordings, photos, screen captures, feedback, and reward fulfillment information. This information is used to administer the activity and communicate with you.

Account Deletion and Reactivation Information – If you request account deletion or reactivation, we may collect information relating to that request, including the reason provided and information necessary to process the request.

Content Creator and Partnership Information – If you are a content creator, influencer, partner, or prospective collaborator on the Services, we may collect (i) information you provide directly to us such as your contact information (name, email address, phone number), username or social media handle, profile information, and any other information you choose to share with us and (ii) information about you available on public sources, including content you have published on third-party platforms and your associated public profile or attribution information. Where we feature your content on the Services, including content that you authorize us to obtain from third-party platforms, we do so pursuant to your authorization, including through our content authorization process.

b. Information We Collect

Technical, Device, and Application Information – When you use the Services, we collect certain technical information about your device and application, including IP address, advertising identifiers (such as IDFA, if available), Gist-generated device identifiers, operating system version, device model, application version, build information, push-notification tokens, language settings, notification authorization status, and other diagnostic information.

Usage and Activity Information – We automatically collect information about your use of the Services, including account activity, session information, searches, content views, text highlights, impressions, clicks, taps, scrolling activity, likes, saves, shares, follows, comments, reports, video playback activity, onboarding activity, referral activity, feature usage, and other interactions with the Services.

Performance and Diagnostic Information – We collect information relating to application performance, crashes, errors, debugging events, navigation activity, device performance, and technical diagnostics to maintain, secure, troubleshoot, and improve the Services.

Notification Information – We collect information relating to push notifications and in-app notifications, including notification delivery status, notification preferences, and related metadata.

Cookies and Similar Technologies – To the extent applicable, we and our service providers may use cookies, SDKs, local storage technologies, and similar technologies to collect information regarding your use of the Services, maintain functionality, analyze performance, and support security and fraud prevention.

Location Information – With your permission, we may collect information about your location, including precise location from your device (such as GPS). We may also collect approximate location derived from your IP address, device or network information, or other signals that indicate your general location. In addition, we may collect location information that you choose to provide, such as a city, region, or other location information included in your profile, content, or account settings. We use location information to provide, personalize, and improve the Services, support safety and fraud prevention, and for analytics. You can manage your location permissions through your device settings.

c. Information We Collect from Other Sources

Information from Authentication Providers – If you choose to register or sign in using a third-party authentication service such as Google or Apple, we receive information from that provider, including identity tokens and, where made available by the provider and authorized by you, information such as your name and email address.

Information from Service Providers and Business Partners – We receive information from vendors and service providers that assist us with authentication, cloud hosting, messaging, attribution, security, analytics, crash reporting, customer support, and other operational functions.

Information from Other Users – We may receive information about you from other users, including where another user shares content with you, references you in content, reports content involving you, invites you to use the Services, or otherwise interacts with you through the Services. This may also include contact information about you, such as your phone number or email address, that another user shares with us when they choose to sync their device contacts, whether or not you are a registered Gist user.

Information from Public Sources – We may receive and process information and media content from publicly available sources and publicly accessible online content, including publicly available creator profiles, usernames, attribution information, and content that creators or other users have made publicly available on third-party platforms. Where authorized by the applicable creator or rights holder, we may collect, import, and process such content for use in connection with the Services.

Information Generated by Third-Party Integrations – If you connect or interact with third-party services, we may receive information from those services in accordance with your permissions and the third party’s policies.

Third-Party Content Authorization – If you authorize us to access or use content from a third-party platform, we may collect and process information associated with that content, including the content itself, captions, metadata, usernames, profile information, engagement information, attribution information, and related materials. We use this information to provide, operate, improve, and promote the Services and as otherwise described in this Privacy Policy. The scope of information collected depends on the content you authorize us to access and the information made available by the applicable platform or rights holder.

HOW WE USE YOUR INFORMATION

We use information collected through the Services for the purposes described in this Privacy Policy or otherwise disclosed to you. For example, we use your information for:

a. Delivery of Services

• Create and manage your account and provide access to the Services;
• Suggest connections with other Services users;
• Match contacts you choose to sync to help you find people you know on the Services and to personalize the accounts and posts recommended to you;
• Operate, maintain, and improve the Services;
• Display, promote, and make available creator content in connection with the Services, including content obtained with creator authorization from third-party platforms;
• Understand your preferences to enhance your experience;
• Respond to inquiries and provide customer support;
• Provide products and services you request;
• Send transactional or service-related communications (e.g., confirmations, updates, security alerts);
• Deliver marketing, promotional, and informational communications, where permitted by law and your communication preferences;
• Administer surveys, research, contests, partnerships and promotions;
• Provide and personalize features that depend on your location;
• Enable user-to-user communications;
• Provide, maintain, secure, moderate, and improve messaging, chat, content-sharing, notification, and other communication features available through the Services; and
• Fulfill any other purpose for which you provide information.

b. Research and Development

• Generate aggregated or anonymized data from the personal information we process, which we may use or share for research, development, and other lawful business purposes;
• Combine personal information with data obtained from third parties to better understand your preferences and enhance the Services; and
• Analyze information you provide in connection with surveys and user research to understand user engagement, improve the Services, support the development of new products or features, and for other lawful purposes.

c. Advertising Our Services

• Advertise and promote our Services on third-party platforms; and
• Measure and attribute the performance of that advertising, including through our attribution provider.

d. Compliance and Protection

• Comply with applicable laws and legal processes;
• Protect the rights, privacy, safety, and property of us, our users, or others;
• Audit compliance with legal and internal requirements;
• Enforce our terms and policies; and
• Detect, investigate, and prevent fraudulent or unlawful activity.

e. Aggregated or Deidentified Information

We may use or share information that has been aggregated or deidentified so it can no longer be linked to you for business, research, or other lawful purposes. Where we process such information, we will maintain it in deidentified form and will not attempt to re-identify it, except as necessary to verify our deidentification processes.

DISCLOSURE OF YOUR INFORMATION

We may share your information with the following categories of recipients. Information disclosed to third parties may be processed in accordance with their own privacy policies.

Service Providers and Business Partners – We share information with vendors, service providers, technology partners, and business partners that perform services that help us operate, provide, secure, support, and improve the Services, including providers of cloud hosting and storage, authentication, communications, analytics, customer support, security, fraud prevention, and technical infrastructure. Where you participate in a referral or promotional program, we may also share your contact information (such as your email address) with gift card issuers or reward fulfillment providers solely to deliver rewards you have earned. These parties are authorized to use your information only as necessary to provide services to us.

Advertising and Measurement Partners – We share certain information with advertising and measurement partners to promote the Services and to measure and improve the performance of our advertising.

Third-Party Apps and Integrations – If you choose to connect your account to third-party apps, platforms, or features, we may share information as directed by you to enable those integrations and provide related functionality.

Affiliates and Corporate Group – We may share information within our corporate group, including affiliates, subsidiaries, and related entities, to operate and improve the Services.

Legal, Safety, and Security – We may disclose information where necessary to comply with applicable laws, legal processes, or government requests; enforce our terms and policies; detect and prevent fraud or security issues; or protect the rights, property, and safety of us, our users, or others.

Mergers & Acquisitions – In connection with a merger, acquisition, reorganization, bankruptcy, or other business transaction, your information may be disclosed or transferred to relevant third parties, such as successors or affiliates.

With Your Consent – We may share your information with third parties or publicly for other purposes at your direction or with your consent, such as when you choose to share content, interact with others, or participate in certain features or promotions.

MANAGING YOUR INFORMATION AND PRIVACY CHOICES

a. Information You Choose to Share on the Services

Depending on your settings, certain information (such as your account details, profile information, or content you create or share) may be visible to other users. If you choose to share content in public areas (e.g., videos, photos, posts, discussions, comments), it may be accessible to a broader audience, including outside the Services (such as through search engines or third-party platforms). Please always use caution in disclosing personal information, especially “sensitive” personal information, while using the Services. We are not responsible for the information you choose to publicly disclose.

b. Third-Party Websites and Services

The Services may contain integrations or links to third-party websites or services, including those of our business partners. By interacting with these third parties, you are providing information directly to the third party. The privacy policies of our partners may include additional terms and disclosures regarding their data collection and use practices. We encourage you to review those privacy policies and online terms of those third parties to learn more about their data collection and use practices. Please note that we are not responsible for the privacy practices of these third parties or any entity that it does not own or control.

c. Deleting Your Account

If you have an account with us and would like us to delete your information, you may send an e-mail to the address set forth in the Contact Us section below. Please note that, if you proceed with the deletion of your account, you will no longer have access to the account or the Services associated with your account. Other steps you should take should you wish to delete your account include deleting the app from your mobile device. Please note that if you ask us to delete your account, all your settings, preferences, messages, and content will be lost and we may not be able to restore them in the future. Please note that your information, for example records pertaining to customer service matters, may be retained for legal and accounting purposes. If you have sent or posted content on the Services, we may not be able to delete it.

SECURITY OF YOUR INFORMATION

We implement reasonable technical and organizational measures designed to protect the security of your personal information against accidental or unlawful destruction, loss, change or damage. However, no security system is impenetrable, and we cannot guarantee the security of your personal information. Any transmission is at your own risk.

DATA RETENTION

We retain your personal information for as long as needed to provide you with the Services, unless we are required by law to delete or if we accept your request to delete the information pursuant to applicable law. We will also retain and use your personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. When determining the length of time to retain your information, we consider various criteria, including whether we need the information to continue to provide you the Services, resolve a dispute, enforce our contractual agreements, prevent harm, promote safety, security and integrity, or protect ourselves, including our rights, property or products.

When we no longer require your personal information, we will look to delete, destroy, or anonymize it pursuant to our typical procedures. If this is not possible (for example, because your personal information has been stored in backup archives), then we will apply security measures to your personal information and isolate it from any further processing until deletion or destruction can occur pursuant to our typical procedures. If we anonymize your personal information (so that it can no longer be associated with you), we can use this information indefinitely without further notice to you.

AGE RESTRICTION AND CHILDREN’S PRIVACY

IF YOU ARE UNDER 18 YEARS OF AGE, THEN YOU MAY NOT USE OR ACCESS THE SERVICES AT ANY TIME OR IN ANY MANNER.

The Services are not intended for use by anyone under the age of 18, including children. We do not knowingly collect personal information from children through the Services or knowingly allow them to use the Services. If you believe that we might have collected personal information from or about a child, please contact us at the email address set forth in the Contact Us section below.

ADDITIONAL U.S. MULTI-STATE PRIVACY NOTICE

a. Collection, Use, and Disclosure of Personal Information

b. Selling or Sharing of Personal Information

Gist does not “sell” your personal information as most people would commonly understand that term; Gist does not, and will not, disclose your personal information in direct exchange for money or some other form of payment. However, Gist may “share” your personal information for purposes of advertising the Services, otherwise known as “interest-based advertising.” Under the CCPA and other State Privacy Laws that expansively define or interpret “sell,” certain advertising and analytics activities may constitute a “sale.” You may opt out at any time by emailing us at info@gist.com.

c. Your Privacy Rights

Depending on the state you live in, to the extent permitted under applicable law, you may be able to exercise one or more of the following rights in relation to the personal information that we have collected about you, subject to certain limitations and requirements, including the verification of your identity and our right to retain information to comply with our legal obligations, among other circumstances.

d. Exercising Your Privacy Rights

Contact Us – To exercise the above two or any of your other data subject rights, please contact us at the email address set forth in the Contact Us section below. Our Data Protection Officer can also be reached at this email address. Please be aware that we may be unable to afford these rights to you under certain circumstances, such as if we are legally prevented from doing so.

Verification – We will need to verify your identity before processing your request. In order to verify your identity, we will generally require the matching of sufficient information you provide us to the information we maintain about you in our systems.

Acting through an Authorized Agent or Representative – In certain circumstances, you may also appoint an authorized agent to exercise any rights that you may have on your behalf using the methods described in this Privacy Policy. If you choose to exercise any rights through an authorized agent, you will need to verify your identity directly with us before we can process any requests. In addition, we will need written documentation demonstrating the authorized agent’s authority to act on your behalf.

Response – We will aim to respond to consumer requests within the timeframe required by applicable law. If we require more time, we will inform you of the reason and extension period in writing. In certain circumstances, we may decline a request, particularly where we are unable to verify your identity. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.

e. Right to Appeal

In addition, you may have the right to appeal our decision regarding a request related to these rights by contacting us at the email address or writing to us at the address set forth in the Contact Us section below. When you submit a request or launch an appeal, we will limit our collection of your information to only what is necessary to securely fulfil your request or process your appeal. We will not require you or your authorized agent to pay a fee for the verification of your request or appeal.

CHANGES TO THIS Privacy Policy

We may update this Privacy Policy to reflect changes to our data privacy practices. If we make any material changes, we will notify you by reasonable means (such as posting a notice on the Services) prior to the change becoming effective and will take additional steps as required by law, including obtaining your consent where required. We encourage you to periodically review this Privacy Policy for the latest information on our privacy practices.

CONTACT US

If you have any questions about this Privacy Policy or the Services, please contact us at info@gist.com or the address set forth below:

Gist App LLC
1100 Page Mill Road, Palo Alto, CA 94304