Last updated: July 12, 2021
‘Data Controller,’ ‘Personal Data’ and ‘Processing’ shall have the same meaning as defined in Article 4 of the EU General Data Protection Regulation 2016/679 (EU GDPR);
‘Data Subject’ means a natural person whose personal data is processed by the Company or its processors.
3.What information do we collect, and how do we use it?
There is some personal data that you voluntarily provide us when you sign-up for a user account on the App, when you subscribe to our mailing list, when you send us enquiries and support requests, etc., and there is some personal data that we are able to collect automatically from your use of the Service. Regardless of whether we receive your personal data directly from you or automatically, we will only process it if we have a legal basis to do so, such as your express consent, the performance of a contract, or legitimate interest.
You may decline to submit any personal data that you do not wish to provide us with. However, you understand that your refusal to provide any information required for the provision of the Service may result in us not being able to provide the Service to you.
We process the following personal data for our users:
3.1.User Account Data
When you register a user account on the App, you must provide us with your mobile phone number and full name. You also have the option to provide your profile photo and email id if you wish to do so, but this information is not mandatory.
How do we use this data?
We use your user account data:
To verify your phone number;
To create your user account; and
To enable you to use the Services as intended.
The legal basis we rely upon for processing this data is Article 6(1)(b) of the EU GDPR, which provides that data may be processed if such processing is required for the performance of a contract.
We will keep your user account data until your user account is terminated. We will remove your user account data from our database within six months from the date of your account termination. Please note that we may be allowed to keep your user account data for a longer duration on other lawful grounds.
3.2.User Content Data
Your User Content Data includes all your user content on the App, such as the events you create, the photographs you upload, your full name, email address and the content of any inquiries/support requests you send to the Company.
Your User Content data also includes any personal information we receive from you about your contacts when you authorize us to access your phone book, such as your contacts’ name, phone number, photo, email address, or manually add a contact to the App.
How do we use your User Content Data?
We use your User Content Data for purposes, including but not limited to:
Delivering, maintaining and improving the Service to our users;
Enabling our users to easily add their contacts from their phone;
Responding to users support requests/enquiries and resolving any issues;
Detecting and preventing any unauthorized activities, including spam.
The legal basis we rely upon for processing this data is Article 6(1)(f) of the EU GDPR, which provides that data may be processed if the controller has a legitimate interest and data processing does not override the data subject's rights.
Data Retention Duration
We will retain all your User Content Data for the entire duration your user account is active on the App. If your user account is terminated, we will remove all your User Content Data within 6 months of your user account termination.
If you do not have a user account, we retain your personal data associated with your inquiry for a maximum period of three months from the date of last communication. We will safely remove all personal data linked to your inquiry from our records after three months unless we have another legal basis for processing this data.
When you subscribe to receive direct marketing communication from us, such as our newsletter, you provide us with your full name and your email address.
How do we use your data?
We will use your data to send you direct marketing material.
The legal basis we rely upon for processing this data is Article 6(1)(a) of the EU GDPR, which provides that data may be processed if the data subject freely grants his/her consent for such processing.
Data Retention Duration
Your marketing data is only retained as long as you are subscribed to receive such communication. You can opt-out of receiving marketing communication from us by clicking the unsubscribe button in our marketing email. If you wish, you can also send your request to opt-out by emailing us at firstname.lastname@example.org using the same email that you used to subscribe to the newsletter, and we will immediately remove you from our mailing list.
We may automatically collect some data from you when you make use of the App, such as:
Your phone logs (date and time when you connected with your contact);
Your facetime logs (date and time when you connected with your contact);
Your message logs (date and time when you connected with your contact); and
Email logs (date and time when you connected with your contact)
How do we use this data?
We use this data to:
Send you reminders to connect with your contacts according to your relationship goals; and
Maintain and improve our Service.
We rely upon Article 6(1)(b) of EU GDPR as the legal basis for the processing of this personal data. Article 6(1)(b) provides that data processing of data during the performance of a contract is lawful.
Data Retention Duration
Your log data is only retained for as long as your user account is active on the App. We will terminate your log data within 6 months of your user account termination.
Google Analytics for Firebase
The legal basis we rely upon for processing this Analytics Data is Article 6(1)(f) of the EU GDPR, which provides that data may be processed if the controller has a legitimate interest and data processing does not override the data subject's rights.
4.Sharing your personal data
We will not sell or rent your personal data to any third party. Your personal data may be shared with third parties in the following circumstances:
With other users you invite to your event
The App enables you to invite other users to an event planned by you. Please note that by default all the content linked to your event, such as event details, participants, and photographs, will be shared with all users who are invited to that event through the App. If you do not wish to make all event-related content visible to all invitees, you should change your default privacy settings to your preferred visibility setting.
Our third-party service providers
Our third-party service providers may have access to your personal data to the extent necessary to deliver the Services on our behalf.
If we undergo a merger, acquisition, or any other commercial transaction such as the sale of our business, our users’ personal data will be disclosed to the other entity as part of initial due diligence and will be transferred to the new entity if we conclude the commercial transaction.
Valid requests for information
We may be obliged to share your personal data with any local or international law enforcement authorities, governmental bodies or in the event, we are ordered or subpoenaed by a court of law to do so.
If we are ever involved in any legal action arising from our Agreement with you, we may disclose your personal data to the extent required to assert our rights or defend any claims against us.
Email distribution tools
We may make use of third-party email distribution tools to send marketing emails to our subscribers. If you opt-in to receive our newsletter, your name and email address will be stored on these email distribution tools.
5.Data Subject Rights
As a data subject, your rights relating to your personal data that we hold are as follows:
Right to access your personal data
As a data subject, you may request what personal data we have for you.
Right to rectification
As a data subject, you may request rectification of any incorrect or incomplete information we hold about you.
Right to withdraw consent
If you subscribe to receive our newsletter by opting in, you can withdraw your consent by clicking the “unsubscribe” button in our marketing email.
Right to erasure of personal data
In limited circumstances, you may exercise your right to request the erasure of your personal data, such as where your personal data is being processed unlawfully or where your personal data is retained for a longer period than specified in our data retention policies.
Right to lodge a complaint
If you are in the European Economic Area (EEA), you may also exercise the right to lodge a complaint against any infringement of your privacy rights by contacting your local data protection authority.
As a California resident, you may request access to the specific personal data that we have collected about you in the preceding year. You also have the right to request information about our privacy practices, how we collected your personal data, parties with whom we share your personal data. You may make specific requests to exercise the aforementioned rights by sending a support request.
7.Security of your data
We care about the security of data, and we use industry best practices to ensure that your data is protected from all unauthorized access, use, modification, destruction and accidental loss. However, the technical realities of our present world mean that despite our best efforts, no mode of digital storage and transmission of data over the internet is completely secure. Therefore we cannot offer you any guarantees as to the security of the data that we store.
8.Transfer of your data
We are operating from the United States, and we will process your data within the United States as well as other parts of the world. If you are located in a European Economic Area (including the United Kingdom or Switzerland), we will transfer your data outside of the EEA, UK, and Switzerland to the United States as well as other third countries where the data protection laws are not as strict as those in the country of your residence.
Whenever we transfer your data to the United States or any country outside of the EEA, which does not offer adequate protection to your personal data, we will take all the steps necessary to protect your data as provided by the European Commission.
11.Protection of Children’s Privacy
We do not target our website to anyone under the age of thirteen (13) years ("Children"). If you are the parent or legal guardian of a child who you believe has provided us with his/her personally identifiable information, please contact us, and we will immediately investigate the matter and take appropriate steps.
Address: 361 Borgato Ct, Las Vegas NV 89145