Last modified: January 27, 2019
By using the app we may be exposed to certain data which we process, store and use. This data includes: un-identified and non-identifiable information (“Non-Personal Data”), or identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Data”), all as detailed herein:
Technical data: We collect technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system) language preference, access time and your usage of the app. We use this information for functionality and to provide you with a better user experience.
Online Identifiers: We, or third parties on our behalf (i.e., Google Analytic), collect information about your use of the app or website. This data includes online identifiers such as IP. This information is collected for fixing errors and bugs as well as for research and analytics purposes.
Sign-up: When you sign-up you will be asked to provide us certain details about yourself, such as your email address and name or you may register through your social network account in which we will have access to basic information from your social network account, such as your name, email address as available on such account or agreed to share with us. We will use this information to provide our services and open your account and to perform our contract with you.
Contacts: To enable the contact managing services, sync and backed up, you will need to share with us your full contact list (i.e. address book). We will use this information, solely upon your explicit consent and to provide you with the services.
Payment: If you use the premium features, you will be required to process the payment through in-app payment methods. We do not collect any payment information. The payment information is subject to the applicable app store policies which we recommend you review.
Contact us: If you contact us, we will have your name and email address. We will use this information solely to provide you with the support you have requested.
When you register, we process your Personal Data in order to perform our contract with you;
When visitors access our website, we may collect certain online identifiers which we have a legitimate interest in processing, some of this data is processed by our third party partners; or
We process Personal Data you voluntarily share with us, such as your contact list, or, we process this data subject to your consent.
HOW WE COLLECT INFORMATION
There are four main methods we may use to collect information about you:
We collect information automatically.
We collect information which you provide us voluntarily.
We collect information through third parties through cookies, SDKs or APIs implemented within our app and website, as detailed below.
We may use third party services for performance tracking and measurement which may collect statistical data, online identifiers and analytic data.
You may control how your browser responds to cookies by adjusting the privacy and security settings of your web browser. Please refer to the support page of the browser you are using.
Following are the cookies we use:
We do not share your Personal Data with third parties except: (i) affiliates and business partners; (ii) our subsidiaries; (iii) subcontractors and other third party service providers; We may disclose your information to third parties when you consent to a particular disclosure. Please note that once we share your information with another company, that information becomes subject to the other company’s privacy practices (iv)any potential purchasers or investors of the Company. We may also disclose Personal Data, or any information you submitted via the Services if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law or governmental request; (ii) enforce our policies; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) to establish or exercise our rights to defend against legal claims; (v) prevent harm to the rights of us, our users, yourself or any third party.
We retain the information we collect as long as it remains necessary for the purposes set forth above, all in accordance with applicable laws, or until an individual expresses a preference to opt-out.
Individuals (either our users, partners, associates, etc.) have the right to control the Personal Data processed by us, if you wish to exercise your right, please use the link here and follow the instructions, or send a request here.
Data privacy and related laws in your jurisdiction may provide you with different or additional rights related to the information we collect from you, which may also apply.
Some rights may be executed through the app: you may choose to opt out from sharing your contacts, at any time through the App, by accessing: More -> Account -> Advanced selection. Here's a tutorial for the process.
We take great care in implementing and maintaining the security of the Services and your information. We employ industry standard procedures and policies to ensure the safety of your information, and prevent unauthorized use of any such information. For more information please see our Security Policy
Since we operate globally, it may be necessary to transfer your Personal Data to countries outside the European Union. The data protection and other laws of these countries may not be as comprehensive as those in the European Union − in these instances we will take steps to ensure that a similar level of protection is given to your Personal Data. You hereby consent to transfer of your Personal Data to countries outside the European Union
Individuals from the EU may contact our EU representative according to Art. 27 GDPR regarding all requests related to data protection and privacy:
Attn: Top Floor Inc.