We appreciate that you trust us with your information and we intend to always keep that trust. This starts with making sure you understand the information we collect, why we collect it, how it is used and your choices regarding your information. This Policy describes our privacy practices in plain language, keeping legal and technical jargon to a minimum.
EFFECTIVE DATE: May 25, 2018
WHO WE ARE
If you live in the European Union anywhere else, you can mail us at:
Verve Mobile Pvt Ltd, 210, 2nd Floor, Swapnalok Complex, S.D. Road, Secunderabad-500003, Telangana, India. Alternatively you cal email us at email@example.com.
INFORMATION WE COLLECT
It goes without saying, we can't help develop meaningful connections without some data about you, such as profile details and the different people you wish to meet. We also collect information generated as you use our services, for example access logs, as well as information from third parties, like when you access our services through a social media account. If you want additional info, we go into more detail below.
Information you give us
You choose to give us certain information when using our services. This includes:
When you create an account, you provide us your credentials like email, password, as well as some basic details necessary for the service to work, such as your gender and date of birth.
When you complete the profile, you share with us information, like details on your personality, lifestyle, interests and other details about you, as well as content such as photos and videos. To add certain content, like pictures or videos, you may allow us to access your camera or photo album. Some of the information you choose to provide us may be "special" or "sensitive" in certain jurisdictions, for example your racial or ethnic origins, sexual orientation and religious beliefs. By choosing to provide this information, you consent to our processing of that information.
When you subscribe to a paid service or make a purchase directly or indirectly (via our payment processors) from us, you provide us or our payment service provider with information, such as your debit or credit card number or other financial information along with your email address, name.
When you participate in surveys or focus groups, you give us your insights into our products and services, responses to our questions and testimonials.
When you choose to participate in our promotions, events or contests, we collect the information that you use to register or enter.
If you contact our customer care team, we collect the information you give us during the interaction. Sometimes, we monitor or record these interactions for training purposes and to ensure a high quality of service.
If you ask us to communicate with or otherwise process information of other people (for example, if you ask us to send an email on your behalf to one of your friends), we collect the information about others that you give us in order to complete your request.
Of course, we also process your chats with other users as well as the content you publish, as part of the operation of the services.
Information we receive from others
In addition to the information you provide us directly, we receive information about you from others, including:
Other Users: Other users may provide information about you as they use our services. For instance, we may collect information about you from other users if they contact us about you
Social Media: You may be able to use your social media login (such as Facebook) to create and log into your Townler account. This saves you from having to remember yet another user name and password and allows you to share some information from your social media account with us.
Other Partners: We may receive info about you from our partners, for instance where Townler ads are published on a partner's websites and platforms (in which case they may pass along details on a campaign's success).
Information collected when you use our services
When you use our services, we collect information about which features you've used, how you've used them and the devices you use to access our services. See below for more details:
Usage Information: We collect information about your activity on our services, for instance how you use them (e.g., date and time you logged in, features you've been using, searches, clicks and pages which have been shown to you, referring webpage address, advertising that you click on) and how you interact with other users (e.g., users you connect and interact with, time and date of your exchanges, number of messages you send and receive).
Device information: We collect information from and about the device(s) you use to access our services, including:
Similarly, if you consent, we may collect your photos and videos (for instance, if you want to publish a photo, video or streaming on the services).
COOKIES AND OTHER SIMILAR DATA COLLECTION TECHNOLOGIES
Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) have a "Do Not Track" (" DNT") feature that tells a website that a user does not want to have his or her online activity tracked. If a website that responds to a DNT signal receives a DNT signal, the browser can block that website from collecting certain information about the browser's user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many businesses, including Townler, do not currently respond to DNT signals.
HOW WE USE INFORMATION
The main reason we use your information is to deliver and improve our services. Additionally, we use your information to help keep you safe and to provide you with advertising that may be of interest to you. Read on for a more detailed explanation of the various reasons we use your information, together with practical examples.
To administer your account and provide our services to you
To help you connect with other users
To ensure a consistent experience across your devices
To serve you relevant offers and ads
To improve our services and develop new ones
To prevent, detect and fight fraud or other illegal or unauthorized activities
To ensure legal compliance
To process your information as described above, we rely on the following legal bases:
HOW WE SHARE INFORMATION
Since our goal is to help you make meaningful connections, the main sharing of users' information is, of course, with other users. We also share some users' information with service providers and partners who assist us in operating the services, with other products within our company and, in some cases, legal authorities. Read on for more details about how your information is shared with others.
With other users: You share information with other users when you voluntarily disclose information on the service (including your public profile). Please be careful with your information and make sure that the content you share is stuff that you're comfortable being publicly viewable since neither you nor we can control what others do with your information once you share it.
If you choose to limit the audience for all or part of your profile or for certain content or information about you, then it will be visible according to your settings.
With our service providers and partners: We use third parties to help us operate and improve our services. These third parties assist us with various tasks, including data hosting and maintenance, analytics, customer care, marketing, advertising, payment processing and security operations.
We may also share information with partners who distribute and assist us in advertising our services. For instance, we may share limited information on you in hashed, non-human readable form to advertising partners.
We follow a vetting process prior to engaging any service provider or working with any partner. Most of our service providers or partners agree to a strict confidentiality obligations. However, there can be circumstances where we may not have certain confidentiality obligations with certain companies, in such cases, we do not share any user identifiable information.
We share your information with other products of our company to benefit you in two respects:
for other products of our company to assist us in processing your information, as service providers, upon our instructions and on our behalf. Assistance provided by other products of our company may include technical processing operations, such as data hosting and maintenance, customer care, marketing and targeted advertising, finance and accounting assistance, better understanding how our service is used and users' behavior to improve our service, securing our data and systems and fighting against spam, abuse, fraud, infringement and other wrongdoings.
For corporate transactions: We may transfer your information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control.
When required by law: We may disclose your information if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government / law enforcement investigation or other legal requirements; (ii) to assist in the prevention or detection of crime (subject in each case to applicable law); or (iii) to protect the safety of any person.
To enforce legal rights: We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.
We may use and share non-personal information (meaning information that, by itself, does not identify who you are such as device information, general demographics, general behavioral data, geolocation in de-identified form), as well as personal information in hashed, non-human readable form, under any of the above circumstances.
We want you to be in control of your information, so we have provided you with the following tools:
Access / Update tools in the service: Tools and account settings that help you to access, rectify or delete information that you provided to us and that's associated with your account directly within the service. If you have any question on those tools and settings, please contact our customer care team for help here.
Device permissions: Mobile platforms have permission systems for specific types of device data and notifications, such as phone book and location services as well as push notifications. You can change your settings on your device to either consent or oppose the collection of the corresponding information or the display of the corresponding notifications. Of course, if you do that, certain services may lose full functionality.
Deletion: You can deactivate your account by using the corresponding functionality directly on the service. If you wish to delete your account, you need to contact our support team. However, in this process, your account will only be suspended and will not be visible to anyone. We will have to keep certain records for security purposes.
We want you to be aware of your privacy rights. Here are a few key points to remember:
Reviewing your information: Applicable privacy laws may give you the right to review the personal information we keep about you (depending on the jurisdiction, this may be called right of access, right of portability or variations of those terms). You can request a copy of your personal information by putting in such to our customer support team.
Updating your information: If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion or object to its processing, please contact us.
For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer the above requests.
Keep in mind, we may reject requests for certain reasons, including if the request is unlawful or if it may infringe on trade secrets or intellectual property or the privacy of another user. If you wish to receive information relating to another user, such as a copy of any messages you received from him or her through our service, the other user will have to contact our customer support to provide their written consent before the information is released.
Also, we may not be able to accommodate certain requests to object to the processing of personal information, notably where such requests would not allow us to provide our service to you anymore. For instance, we cannot provide our service if we do not have your date of birth.
Uninstall: You can stop all information collection by an app by uninstalling it using the standard uninstall process for your device. If you uninstall the app from your mobile device, the unique identifier associated with your device will continue to be stored. If you re-install the application on the same mobile device, we will be able to re-associate this identifier to your previous transactions and activities.
RESIDENTS OF CALIFORNIA
If you are a California resident, you can request a notice disclosing the categories of personal information about you that we have shared with third parties for their direct marketing purposes during the preceding calendar year. To request this notice, please submit your request to our customer support. Please allow 30 days for a response. For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer such a request.
HOW WE PROTECT YOUR INFORMATION
We work hard to protect you from unauthorized access to or alteration, disclosure or destruction of your personal information. As with all technology companies, although we take steps to secure your information, we do not promise, and you should not expect, that your personal information will always remain secure. We will not be liable to any data ‘hack’ or leak and if your personal information gets public.
We regularly monitor our systems for possible vulnerabilities and attacks and regularly review our information collection, storage and processing practices to update our physical, technical and organizational security measures.
We may suspend your use of all or part of the services without notice if we suspect or detect any breach of security. If you believe that your account or information is no longer secure, please notify us immediately here.
In order to ensure that our systems and your information are protected against unauthorized access, theft and loss, we implemented a bug bounty program. For more information about our bug bounty program, please contact our support.
HOW LONG WE RETAIN YOUR INFORMATION
We keep your personal information only as long as we need it for legitimate business purposes.
In practice, we do not delete or anonymize your information upon deletion of your account because:
there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or
the information must be kept for our legitimate business interests, such as fraud prevention and enhancing users' safety and security. For example, information may need to be kept to prevent a user who was banned for unsafe behavior or security incidents from opening a new account.
Keep in mind that even though our systems are designed to carry out data deletion processes according to the above guidelines, we cannot promise that all data will be deleted within a specific time frame due to technical constraints.
Our services are restricted to users who are 18 years of age or older. We do not permit users under the age of 18 on our platform and we do not knowingly collect personal information from anyone under the age of 18. If you suspect that a user is under the age of 18, please use the reporting mechanism available through the service.
Because we're always looking for new and innovative ways to help you build meaningful connections, this policy may change over time. We may or may not notify you before any material changes take effect so we request you to review the same from time to time.
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