Privacy Policy

 

 

1. Who We Are

The company responsible for your information under this Privacy Policy (the “data controller”) is:

The Edo sp z o.o.

  1. Stanisława Leszczyńskiego 4/25

50-078 Wroclaw

Poland

2. Where This Privacy Policy Applies

This Privacy Policy applies to noobly app available on Android and IOS platforms and noobly website at noobly.xyz and nooblyapp.com. For simplicity, we refer to these as our “services” in this Privacy Policy. 

3. Information We Collect

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 with at least one of the following: your phone number, email address, facebook social login, apple ID or Google gmail adress as well as some basic details necessary for the service to work, such as chosen name and date of birth.
  • When you complete your profile, you can share with us additional information, such as details on your bio as well as content such as photos. To add certain content, like pictures, you may allow us to access your camera or photo album.
  • When you subscribe to a paid service or make a purchase directly from us (rather than through a platform such as iOS or Android), you provide us or our payment service provider with information, such as your debit or credit card number or other financial information.
  • If you contact our customer care team, we collect the information you give us during the interaction.
  • Of course, we also process your chats with other members as well as the content you publish, as necessary for the operation of the services.

Information collected when you use our services

When you use our services, this generates technical data 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 Using the services generates data about your activity on our services (when you logged in we save the exact time) and your interactions with other members (e.g., members you connect and interact with, when you exchanged with them, 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 hardware and software information such as device ID and type, apps settings and characteristics, app crashes, advertising IDs (which are randomly generated numbers that you can reset by going into your device’ settings), or other technologies that may uniquely identify a device.
  • Other information with your consent If you consent, we may collect photos (for instance, if you want to publish or send a photo)

4. How We Use Information

The main reason we use your information is to deliver and improve our services. Additionally, we use your info 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 for which we use your information, together with practical examples.

1. To administer your account and provide our services to you

  • Create and manage your account
  • Provide you with customer support and respond to your requests
  • Complete your transactions
  • Communicate with you about our services

2. To help you connect with other users

  • Recommend you other members to meet
  • Show members’ profiles to one another

3. To operate advertising and marketing campaigns

  • Administer sweepstakes, contests, discounts or other offers
  • Perform and measure the effectiveness of advertising campaigns on our services and marketing campaigns promoting our services
  • Communicate with you about products or services that we believe may interest you

4. To prevent, detect and fight fraud and other illegal or unauthorized activities

  • Find and address ongoing, suspected or alleged violations of our Terms of Use, notably through the review of reports and interactions between members
  • Better understand and design countermeasures against violations of our Terms of Use
  • Retain data related to violations of our Terms of Use to prevent against recurrences
  • Enforce or exercise our rights, for example our Terms of Use
  • Communicate to individuals who submit a report, what we’ve done as a result of their submission

5. To ensure legal compliance

  • Comply with legal requirements
  • Assist law enforcement
  • Provide our service to you: The reason we process your information for purposes 1 and 2 above is to perform the contract that you have with us. For instance, as you go about using our service to build meaningful connections, we use your information to maintain your account and your profile, make it viewable to other members and recommend other members to you and to otherwise provide our free and paid features to you and other members.
  • Legitimate interests: We process your information for purposes 3 and 4 above, based on our legitimate interest. For instance, we analyze users’ behavior on our services to continuously improve our offerings, we suggest offers we think might interest you and promote our own services, we process information to help keep our members safe and we process data where necessary to enforce our rights, assist law enforcement and enable us to defend ourselves in the event of a legal action.
  • Comply with applicable laws and regulations: We process your information for purpose 5 above where it is necessary for us to comply with applicable laws and regulations and evidence our compliance with applicable laws and regulations. For example, we retain traffic data and data about transactions in line with our accounting, tax and other statutory data retention obligations and to be able to respond to valid access requests from law enforcement. We also keep data evidencing consents members give us and decisions they may have taken to opt-out of a given feature or processing.
  • Consent: In any case, you may withdraw your consent at any time by contacting us at the address provided at the end of this Privacy Policy.

5. How We Share Information

We also share some members’ information with service providers and partners who assist us in operating the services and in some cases, legal authorities. Read on for more details about how your information is shared with others.

  • With other members
    You share information with other members 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 visible.
    If someone submits a report involving you (such as a claim you violated our Terms of Use), We may communicate to the reporter actions, if any, we took as a result of their report.

  • 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 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.

  • 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.

  • With law enforcement / 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 members, 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.

6. Your Rights

We want you to be in control of your information, so we want to remind you of the following options and tools available to you:

  • Device permissions. Mobile platforms can have permission systems for specific types of device data and notifications, such as phone contacts, pictures, push notifications and advertising identifiers. You can change your settings on your device to either consent or oppose the collection or processing of the corresponding information or the display of the corresponding notifications. Of course, if you do that, certain services may lose functionality.
  • Uninstall. You can stop all information collection by an app by uninstalling it using the standard uninstall process for your device. Remember that uninstalling an app does NOT close your account. To close your account, please use the corresponding functionality on the service.
  • Account closure. You can close your account by using the corresponding functionality directly on the app by using the ‘Delete account’ option in app settings.

We also 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, right to know or variations of those terms). You can exercise this right by putting in such a request by contacting us at the address provided at the end of this Privacy Policy
  • 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, object to or restrict its processing, please contact us by contacting us at the address provided at the end of this Privacy Policy

7. How Long We Retain Your Information

We keep your personal information only as long as we need it for legitimate business purposes and as permitted by applicable law. If you decide to stop using our services, you can close your account and your profile will stop being visible to other members. Note that we will close your account automatically if you are inactive for a period of two years. After your account is closed, we will delete your personal information, as laid out below:

  1. To protect the safety and security of our members, we implement a safety retention window of three months following account closure or one year following an account ban. During this period, we keep your information in the event that it might be necessary to investigate unlawful or harmful conduct. The retention of information during this safety retention window is based on our legitimate interest as well as that of potential third-party victims.
  2. Once the safety retention window elapses, we delete your data and only keep limited information for specified purposes, as laid out below:
    • a) We maintain limited data to comply with legal data retention obligations: in particular, we keep transaction data for 10 years to comply with tax and accounting legal requirements, credit card information for the duration the user may challenge the transaction and “traffic data” / logs for one year to comply with legal data retention obligations. We also keep records of consent members give us for five years to evidence our compliance with applicable law.
    • b) We maintain limited information on the basis of our legitimate interest: we keep customer care records and supporting data for five years to support our customer care decisions, enforce our rights and enable us to defend ourselves in the event of a claim, information on the existence of past accounts and subscriptions, which we delete three years after the closure of your last account to ensure proper and accurate financial forecasting and reporting, profile data for one year in anticipation of potential litigation, for the establishment, exercise or defense of legal claims, and data necessary to prevent members who were banned from opening a new account, for as long as necessary to ensure the safety and vital interests of our members.
    • c) Finally, we maintain information on the basis of our legitimate interest where there is an outstanding or potential issue, claim or dispute requiring us to keep information (in particular if we receive a valid legal subpoena or request asking us to preserve data (in which case we would need to keep the data to comply with our legal obligations) or if data would otherwise be necessary as part of legal proceedings).

8. Children’s Privacy

Our services are restricted to individuals who are 13 years of age or older. We do not permit individuals under the age of 13 on our platform. If you suspect that a member is under the age of 13, please use the reporting mechanism available on the service. In the case we discover that a child under 13 has provided us with personal information, we immediately delete this from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we will be able to do the necessary actions.

9. How to Contact Us

If you have questions about this Privacy Policy, you can reach us at hello@noobly.com