We welcome your comments and/or suggestions on improving this Policy. If you have any concerns, please contact us at the address given below.
This Policy explains generally our practices, but in all respects this Policy and the application of our practices will be subject to and in accordance with the provisions of applicable privacy protection laws.
What Personal Information Do We Collect?
We may collect the following types of information from or about you, your computer and your mobile device, which may include some information that can be used to identify you (“Private Personal Information”):
a) Information You Provide: You may provide us with certain Private Personal Information, such as your mobile phone number, email address, your name, your mobile identifier number, and any IP address uniquely associated with your mobile device or computer, when choosing to use the Site, such as when you register as a user. If you use the Facebook connect feature in the Site we may receive from Facebook your Facebook name and Facebook email address and your Facebook friends list.
b) Cookies: We may store one or more cookies (a small text file containing a string of alphanumeric characters) on your device that uniquely identifies your browser. These cookies may store your unique account ID, an API key, encoded profile information or a username, but no other personal information. The Site uses persistent cookies. A persistent cookie remains after you close your browser, and may be used by your browser on subsequent visits to the Site or subsequent sessions of the Site. Persistent cookies can be removed by following your web browser help file directions. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, the Site may not function properly if the ability to accept cookies is disabled. By using the Site you agree to accept the placement of cookies on your mobile device browser.
c) Site Logs: When you use the Site our servers may log certain information that your web browser sends to us. These logs may include information such as your web request, Internet Protocol address, type of browser, browser language, referring / exit pages and URLs, platform type, number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time of your request. When you use the Site, our servers log certain general information that our application sends whenever a message is sent or received, or if you update or request any status information, including time and date stamps and the Site users the messages were sent from and to.
d) Analytics: We may partner with third party agents to provide analytics on usage of the Site by our users. The data collected by our agents may include, but is not limited to: agent version, platform, SDK version, timestamp, API key (identifier for application), application version, device identifier, iOS Identifier for Advertising, iOS Identifier for Vendors, Android Advertiser ID, Media Access Control (MAC) address, International Mobile Equipment Identity (IMEI), Model, manufacturer and OS version of device, session start/stop time, device uptime, locale (specific location where a given language is spoken), mobile network code/mobile country code, time zone, network status (WiFi, etc.), memory, disk, CPU, battery usage information, and non-personally identifying demographic information (including, but not limited to; age, sex, location).
e) Web Beacons: A web beacon is an electronic image placed on a web page that can serve many of the same purposes that cookies serve, For example, recording the pages you visit on the Site. We, or third parties service providers, may use web beacons to track the traffic patterns of users from one page to another. We, or our third party service provider, may use web beacons in some of our emails to let us know which emails have been opened by recipients or track click-through rates. This allows us to gauge the effectiveness of our communications to customers and our marketing campaigns.
Use of Personal Information
We may use your Personal Private Information that we collect for the following purposes:
We retain your Personal Information for as long as necessary to fulfill the purposes for which we collected the information or as required by law. We maintain a records retention and destruction program to destroy information when it is no longer needed or required.
Disclosure of Personal Information
Under certain circumstances, we may disclose your Private Personal Information:
Your Choices and Rights Regarding Your Personal Information
Right to Access Your Information
You can request a copy of your Private Personal Information which we hold. If you would like a copy of some or all of your information in a structured, commonly used and machine-readable format, please:
• write to us at the address below
• provide proof of your identity, and
• identify the information you want a copy of, including any account or reference numbers, if you have them
We may charge a small fee for this service where you request the information in a format other than what was provided.
Right to Modify Your information
You can require us to correct any mistakes in your Private Personal information which we hold free of charge. If you would like to do this, please:
• write to us at the address below
• provide us enough information to identify you (e.g. account number, user name, registration details), and
• let us know the information that is incorrect and what it should be replaced with.
Right to be Forgotten
You can ask us to stop contacting you for direct marketing purposes. If you would like to do this, please:
• write to us at the address below), you can also click on the ‘unsubscribe’ button at the bottom of any email we may send you. It may take up to ten (10) days for this to take place.
• provide proof of your identity;
• let us know the nature of your complaint and how we may be in contact with you, if at all.
To Delete Your Account
You may request the deletion of your account by sending a request for deletion along with your account details to our support team at firstname.lastname@example.org.
Transfer of Private Personal Information
Your Private Personal Information may be processed by us in the country in which it was collected and in other countries, including the United States and/or Canada, where laws regarding processing of Private Personal Information may be different than the laws in your country. Our servers are located in the United States and/or Canada, and as such, your Private Personal Information may be available to the Canadian and U.S. government or its agencies under lawful orders made in Canada or the U.S. Please be advised that through your continued use of the Site, we may be transferring your Private Personal Information to Canada and/or the U.S. and you expressly consent to that transfer and consent to be governed by Canadian or U.S. law for these purposes.
We will never ever sell, lease, license, or in any other way commercially distribute your personally identifiable information to third parties. We promise this to you on pain of death and commercial ridicule in the industry press. However as you can understand, we want to make sure that this service meets your needs as best as possible, so to that end, we do reserve the right to use your personal information strictly and only in a limited fashion where it helps us improve the product. An example could be if we see that customers using a specific type of handset are having issues with certain pages - this could indicate to us that our product has a bug, and that we should investigate the usability of our product on that handset. Where we interface with 3rd parties to improve our product - for example in relation to matters of product analytics, functionality, and scalability, we will ensure that all data exposed to such 3rd parties will be Summarized Data, an anonymized, general, and non-personally identifiable manner. "Summarized Data" means records which have been stripped of information potentially identifying individuals, and which have been manipulated or combined to provide generalized, anonymous information. Your identity and Private Personal Information will be kept anonymous in Summarized Data.
You may revoke any and/or all consents you have given to us; in order to revoke such consent(s), please contact our privacy officer in writing at the address listed at the end of these terms. At least twenty (20) business days are required to effectuate your revocation of consent from the time we receive it. Please note, however, that revocation of any consent does not have retroactive effect.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred.
Your Security and Private Personal Information
We take administrative, technical and physical measures to safeguard your personal information against unauthorized access, unauthorized disclosure, theft and misuse. This includes limiting access of employees to, and the use of, your personal information through the use of passwords and graduated levels of clearance to those who have a genuine business need to know it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We do not publish all of our security measures online because this may reduce their effectiveness. We take physical precautions to ensure that the computer servers on which your personal information is stored and archived are secure and that access to such servers is protected. We educate our employees with respect to their obligations to protect your personal information and we require our affiliates and any third-party service providers to take comparable steps to ensure the protection of any of your personal information that is shared with them.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Although we take precautions against possible breaches of our security systems, no company can fully eliminate the risks of unauthorized access to your personal information and no website is completely secure. We cannot guarantee that unauthorized access, hacking, data loss or breaches of our security systems will never occur.
While we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data that are transferred from you or to you via the internet.
Please remember that you control what Private Personal Information you provide while using the Site. Ultimately, you are responsible for maintaining the secrecy of your Private Personal Information in your possession. Always be careful and responsible regarding your Private Personal Information. We are not responsible for, and cannot control, the use by others of any information which you provide to them and you should use caution in selecting the Private Personal Information you provide to others through the Site. Similarly, we cannot assume any responsibility for the content of any Private Personal Information or other information which you receive from other users through the Site, and you release us from any and all liability in connection with the contents of any Private Personal Information or other information which you may receive from other users. We cannot guarantee, or assume any responsibility for verifying, the accuracy of the Private Personal Information or other information provided by other users of the Site. You release us from any and all liability in connection with the use of such Private Personal Information or other information of others.
Traffic and Usage
We may monitor traffic patterns, usage and related information. We use this information in order to optimize and assess usage of the Site. We reserve the right to disclose information about your usage of the Site, and demographics in forms that do not reveal your personal identity.
Personal Information of Individuals Under 16 Years Old
We do not knowingly provide the Site to, and will not knowingly collect Private Personal Information from anyone under the age of 16.
Merger or Sale
In the event that we are acquired by or merged with a third party entity, we reserve the right to transfer or assign the Private Personal Information, and any other information we have collected from our users as part of such merger, acquisition, sale, or other change of control.
Strawinskylaan 411, WTC, Tower A, 4th Floor, 1077 XX, Amsterdam, P.O. Box 79141, 1070 ND, Amsterdam, The Netherlands
February 4, 2022
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