Privacy Policy

1. Information We Collect

1.1 Information You Provide (Required for Service Delivery)

The following information is necessary for us to provide the App’s core functionality. If you choose not to provide required information, we may not be able to provide you with the service or certain features:

• Account Information: Your name and email address as shared through Sign in with Apple, and the authentication credentials needed to keep you signed in.
• Profile Information: Your full name, username, profile photo, bio, and other profile details you choose to provide. Your name, username, and profile photo are shown to other viewers next to your comments.
• Age Information: Your date of birth, which we use to confirm that you meet the minimum age to use the App.
• Agreement Records: The date and time you agreed to our Terms of Service and this Privacy Policy.
• Comments and Reactions: The comments and replies you post in a Show’s chat, and the likes and reactions you leave on comments.
• Votes: The choices you make when a Show asks its audience to decide what happens next.
• Shows You Follow: The Shows you subscribe to or bookmark, and the episodes you ask to be reminded about.
• Sign-Up Answers and Preferences: How you heard about Choises, your notification choices, chat settings, and other in-app settings.

You may also enter text into open text fields, including comments, replies, and your bio. To the extent this text includes personal information, it may be processed as described in this Privacy Policy and, for comments, shown to other viewers. You should not include sensitive or confidential personal information in open text fields.

We may collect other information from you with your consent or as otherwise permitted or required by Applicable Law.

1.2 Information Collected Automatically

When you use the App or the Site, we automatically collect certain technical and usage information:

• Device Information: Device type, operating system, app version, unique device identifiers, and mobile network information.
• Usage Data: The Shows and episodes you watch and how far you get, when and how often you use the App, the features you use, your interactions with chats and votes, and other engagement metrics.
• Diagnostic Data: Crash reports, performance data, and other diagnostic information.
• Notification Data: If you allow notifications, the token Apple provides so that we can send them to your device.
• Website Data: When you visit the Site, our hosting provider records standard request information, such as your IP address, browser type, and the pages you view.

2. How We Use Your Information

2.1 Required Processing (Necessary for Service Delivery)

We may use your information for the following purposes, which are necessary to deliver the App’s service to you:

• Running the Show: Streaming Shows and episodes, showing the live chat, counting Votes, and showing the audience’s results.
• Your Profile: Creating and maintaining your profile and showing your name, username, and photo next to your comments.
• Personalization: Remembering what you have watched, saved, and followed so that you can pick up where you left off and see the Shows that matter to you.
• Age Assurance: Confirming that you meet the minimum age to use the App.
• Communications: Sending you notifications you have asked for, such as when a Show you follow releases an episode or a premiere starts, and service-related messages.
• Safety and Moderation: Acting on reports, enforcing blocks, and detecting and preventing fraud, abuse, spam, and security incidents.
• Legal Compliance: Complying with applicable laws, regulations, and legal processes as permitted by Applicable Law.

2.2 Improvement and Analytics Processing

The following uses help us improve the App. Where required by Applicable Law, these uses are based on your consent or our legitimate interests:

• Service Improvement: Analyzing usage patterns, identifying issues, and improving the App’s features, Shows, and performance using aggregated and/or de-identified data.
• Analytics: Understanding how viewers use the App and measuring how well its features work.
• Promotional Communications: Where you have opted in and as otherwise permitted by Applicable Law, sending you news about Choises and its Shows. You may opt out at any time.

3. Third-Party Service Providers

We use the following third-party services to operate the App and the Site. Where required by Applicable Law, prior to disclosing your personal information to our providers, we put appropriate contractual safeguards in place that require our providers to handle your data in accordance with this Privacy Policy and Applicable Law.

• Apple: Sign in with Apple to create and access your account, the App Store to distribute the App, and the Apple Push Notification service to deliver notifications. Apple’s privacy practices are described at apple.com/legal/privacy.
• Vercel: Hosts the Site and processes the request information described in Section 1.2. Vercel’s privacy practices are described at vercel.com/legal/privacy-policy.
• Cloud Infrastructure: Hosting, database, storage, and analytics providers that run the App’s online features on our behalf and process information only on our instructions.

We do not currently use advertising or attribution SDKs in the App. If we add them, we will update this Privacy Policy and, in accordance with Apple’s App Tracking Transparency (ATT) framework, the App will request your permission before tracking your activity across other companies’ apps and websites.

4. Data Sharing and Disclosure

We do not sell your personal information. We do not share your personal information for cross-context behavioral advertising purposes.

Comments you post, along with your name, username, and profile photo, are visible to other viewers of that Show. Votes are counted and shown to the audience in aggregate; we do not show other viewers how you individually voted.

We may disclose your information in the following circumstances:

• Service Providers: With the third-party providers described in Section 3, under applicable data processing agreements where required by Applicable Law, solely to provide and improve the App’s functionality.
• Legal Requirements: When required by law, regulation, legal process, or governmental request.
• Safety: When we believe disclosure is necessary to protect the rights, safety, or property of Choises, our users, or the public.
• Business Transfers: In connection with a merger, acquisition, reorganization, or sale of assets, your information may be transferred as part of that transaction. We will provide notice of such transfer in accordance with Applicable Law.
• De-identified and Aggregated Data: To the extent permitted under Applicable Law, we may share de-identified, aggregated data that cannot reasonably be used to identify you, such as total vote counts or audience sizes.
• With Your Consent: When you have given us explicit consent to share your information for a specific purpose.

5. Data Retention

We retain your personal information for as long as necessary to satisfy the purposes of collection, or as otherwise required by Applicable Law. Information stored on your device stays there until you log out or delete the App.

Where we retain data following account termination by Choises (e.g., for fraud, abuse, safety, or legal hold), we will retain only the data necessary for those purposes and for the minimum duration required.

6. Data Security

We implement commercially reasonable technical, physical, and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include encryption in transit, access controls, and periodic security reviews. However, no method of electronic transmission or storage is 100% secure, and we cannot guarantee absolute security.

Data Breach Notification: In the event of a security breach that results in unauthorized access to, disclosure of, or loss of your personal information, we will notify affected users and the relevant authorities as required by Applicable Law.

7. Your Rights and Choices

Depending on your jurisdiction, you may have the following rights regarding your personal information:

• Access: You may request a copy of the personal information we hold about you.
• Correction: You may request that we correct inaccurate or incomplete personal information. You can also edit your profile at any time in the App.
• Deletion: You may request that we delete your personal information, subject to certain legal exceptions.
• Data Portability: You may request a copy of your data in a structured, commonly used, machine-readable format.
• Withdrawal of Consent: Where processing is based on consent, you may withdraw your consent at any time without affecting the lawfulness of processing carried out before withdrawal.
• Notifications: You may turn notifications off at any time in your device’s Settings.
• Opt-Out of Promotional Communications: You may opt out of marketing messages by following the unsubscribe instructions in any promotional message.
• Lodge a Complaint: You also have a right to lodge a complaint with a competent data protection authority, in particular in the region where you normally reside, where we are based, or where an alleged infringement of data protection law has taken place.

To exercise any of these rights, please contact us at support@montra.com. We will respond to your request within the timeframe required by Applicable Law. A parent or legal guardian may exercise these rights on behalf of a minor user, subject to reasonable identity verification. Additional jurisdiction-specific rights are described in Sections 10 and 11.

8. Children’s Privacy

Choises is not intended for users under 13, and we do not knowingly collect personal information from users under 13. The App asks for your date of birth and does not let anyone under 13 create a profile. If we learn that a user under 13 has used the App or provided personal information, we may suspend or terminate the account and delete associated information, subject to Applicable Law.

If you are a minor where you live but are at least 13, you are responsible for obtaining any required permission from a parent or legal guardian before using the App. We encourage parents and guardians to monitor their children’s use of online services and to contact us at support@montra.com if they believe a person under 13 has provided us with personal information.

9. International Data Transfers

Choises is based in Toronto, Ontario, Canada. Your information may be transferred to and processed in Canada, the United States, or other countries where our third-party service providers operate. These countries may have data protection laws that differ from your jurisdiction. When transferred outside of your jurisdiction of residence, your personal information may be subject to lawful requests by foreign law enforcement and other authorities, and may be subject to local laws that differ from those in your jurisdiction.

Where we transfer personal data outside of your jurisdiction of residence, we ensure that appropriate safeguards are in place as required by applicable data protection laws.

10. Additional Disclosures for Users in the EEA, UK, and Switzerland (GDPR)

If you are located in the European Economic Area (EEA), the United Kingdom (UK), or Switzerland, the General Data Protection Regulation (GDPR) and applicable local implementing legislation provide you with additional rights and protections. This section supplements the rest of this Privacy Policy.

10.1 Data Controller

Montra Interactive Inc. is the data controller responsible for your personal data.

10.2 Lawful Bases for Processing

We process your personal data on the following lawful bases:

• Consent (Article 6(1)(a)): Processing sensitive information you choose to include in comments, your bio, or other open-input fields; notifications; analytics where local tracking rules require consent; and promotional communications (opt-in required, withdrawal available at any time).
• Performance of a Contract (Article 6(1)(b)): Account creation, authentication, and management; your profile; streaming Shows, the live chat, and Votes; and service-related notifications and communications.
• Legitimate Interests (Article 6(1)(f)): App security monitoring, fraud detection, moderation, and abuse prevention; aggregated and de-identified analytics for service improvement (where consent is not required); and maintaining service performance, debugging, and infrastructure monitoring.
• Legal Obligation (Article 6(1)(c)): Age assurance where required, compliance with tax, accounting, and regulatory requirements, responding to lawful government and regulatory requests, and data breach notification obligations.

We have conducted balancing tests for each legitimate interest to ensure they do not override your fundamental rights and freedoms.

10.3 Processing of Special Category Data

Choises is not designed to collect special category data. However, information you choose to share in comments, your bio, or other User Content, such as information about health, beliefs, or identity, may be considered special category data under Article 9 of the GDPR. Where required, we process this data on the basis of your explicit consent (Article 9(2)(a)). You may withdraw that consent at any time by deleting the content, deleting your account, or contacting us.

10.4 Your Rights Under the GDPR

• Right of Access (Article 15): Obtain confirmation of whether we process your data and request a copy.
• Right to Rectification (Article 16): Request correction of inaccurate or incomplete data.
• Right to Erasure (Article 17): Request deletion of your data in certain circumstances.
• Right to Restriction of Processing (Article 18): Request that we restrict processing in certain circumstances.
• Right to Data Portability (Article 20): Receive your data in a structured, commonly used, machine-readable format.
• Right to Object (Article 21): Object to processing based on legitimate interests. We will cease processing unless we demonstrate compelling legitimate grounds that override your interests.
• Right Regarding Automated Decision-Making (Article 22): Not be subject to a decision based solely on automated processing that produces legal or similarly significant effects. The App does not make such decisions about you. Where a moderation decision affects your content, you may request human review.
• Right to Withdraw Consent: Withdraw consent at any time without affecting prior lawful processing.
• Right to Lodge a Complaint: Lodge a complaint with a supervisory authority in the EEA member state of your habitual residence, place of work, or place of alleged infringement. For UK residents, the relevant authority is the Information Commissioner’s Office (ICO).

To exercise these rights, contact us at support@montra.com. We will respond within one (1) month, extendable by up to two additional months for complex or numerous requests, with notice provided within the initial month.

10.5 Data Retention Under GDPR

We retain your personal data only for as long as necessary to fulfill the purposes described in this Privacy Policy (see Section 5). When your personal data is no longer necessary, we will securely delete or anonymize it.

10.6 International Transfers from the EEA/UK

As described in Section 9, your personal data may be transferred to Canada and the United States. For transfers from the EEA or UK, we rely on Standard Contractual Clauses and, where applicable, the European Commission’s adequacy decision for Canada. We ensure that any onward transfers by our third-party service providers also incorporate appropriate safeguards.

11. Additional Disclosures for California Residents

If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, “CCPA”), provides you with additional rights.

We do not sell your personal information, and we do not share it for cross-context behavioral advertising.

Sensitive Personal Information: We collect sensitive personal information only if you choose to include it in comments, your bio, or other open-input fields. We use it only as necessary to provide the App’s services. We do not use sensitive personal information for purposes beyond what is necessary to provide the services you have requested.

Your rights under the CCPA include:

• Right to Know: The categories and specific pieces of personal information we collect, the purposes for collection, and the categories of third parties to whom we disclose it.
• Right to Delete: Request deletion of your personal information, subject to certain exceptions.
• Right to Correct: Request correction of inaccurate personal information.
• Right to Limit Use of Sensitive PI: Request that we limit our use of sensitive personal information to what is necessary to provide the services.
• Right to Non-Discrimination: We will not discriminate against you for exercising your CCPA rights.

To exercise your CCPA rights, please contact us at support@montra.com. We will verify your identity before fulfilling your request.

12. Sensitive Information Disclaimer

The information you choose to share through the App, including comments, replies, your bio, and other profile information, may include details that are considered sensitive personal information under certain privacy laws. Comments are visible to other viewers.

In jurisdictions that require explicit consent for the collection and processing of sensitive personal information, we obtain your consent before you first submit such information through the App’s open-input features.

You may withdraw your consent at any time by deleting the content, deleting your account, or contacting support@montra.com.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy within the App and on the Site as required by Applicable Law. The “Effective Date” at the top of this policy indicates when it was last revised. Your continued use of the App after any changes constitutes your acceptance of the revised policy. If you do not agree to the revised policy, you must stop using the App and may request account deletion.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

For privacy-related inquiries, we aim to respond within 30 days, or within one month for GDPR-related requests.