PRIVACY POLICY

Last modified date: 23 April 2019

Welcome to the Ringoid Ltd ("Ringoid", "we", "us", or "our") Privacy Policy.

At Ringoid, your privacy is paramount. Our users' privacy is one of main reasons why we built the App and at the core of the way we designed and develop it. We appreciate that you put your trust in us when you provide us with your information and we take this very seriously.

Ringoid is committed to safeguarding and preserving the privacy of our users. We strive to minimise the amount of data we collect and process to the bare minimum necessary to deliver the services. We do and will always respect your right to privacy. Ringoid takes every reasonable precaution to ensure that your information is only used in the ways outlined by this Privacy Policy.

This Privacy Policy operates within compliance of the EU General Data Protection Regulation 2018.

IMPORTANT INFORMATION AND WHO WE ARE

Ringoid is the controller and is responsible for your personal data. We are a private company registered in England with Company No. 09427326 and VAT Reg No: GB 208660511, with registered office at 97 Friars Mead, London, E14 3JY. We are registered with the UK's Information Commissioner's Office ("ICO") with registration number ZA455969.

This Ringoid Application ("the App") is not intended for children, it is 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 data for anyone under the age of 18. If you suspect that a user is under the age of 18, please report this user immediately by tapping on the "..." icon at the user's photo in the App and select "Report and Block" option.

We have appointed a data protection officer ("DPO"). If you have any questions about this privacy policy, please contact them using the details set out below.

Contact details. If you have any questions about this privacy policy or our privacy practices, please contact our DPO:

By post: The Data Protection Officer, Ringoid Ltd, 97 Friars Mead, London, E14 3JY, United Kingdom.

By email: data.protection@ringoid.com

You can contact our DPO if you have any questions about this privacy policy, including any requests to exercise your legal rights, by email at data.protection@ringoid.com . However, our customer support team may be able to resolve your questions and requests more quickly. Our customer support team can be contacted at support@ringoid.com or via the App.

You have the right to make a complaint at any time to the ICO, the UK supervisory authority for data protection issues or other competent supervisory authority of an EU member state if the App is downloaded outside the UK. The ICO can be reached here. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the Privacy Policy. We keep our Privacy Policy under regular review. It may change and if it does, these changes will be notified to you when you next start the App. The link to a new policy may be displayed on-screen and you may be required to open it, read and accept the changes to continue your use of the App.

THE DATA WE COLLECT AND HOW THE DATA IS COLLECTED

We will collect and process the following data about you:

Information you give us

Information we collect about you and your device

We collect and store your personal data in the databases, server logs or other similar technologies. This includes the following items of data:

Information we receive from others

We may receive personal data about you from various third parties as set out below:

HOW WE USE YOUR PERSONAL DATA?

The main reason we use your personal data is to improve the App usability. We also use your personal data to keep you safe. Please see the following paragraph, for a more detailed explanation of the various reasons we use your personal data, together with practical examples:

Purposes for which we will use your personal data

Most commonly we will use your personal data in the following circumstances:

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

HOW WE SHARE YOUR PERSONAL DATA?

We do not share your personal data with other people or companies that are not linked to us except under the following circumstances:

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

INTERNATIONAL TRANSFERS

Some of our external third parties (including Amazon AWS, Papertrail, Google Fabric, Google Firebase, Yahoo Flurry, Sentry, Branch) are based outside the European Economic Area ("EEA") so their processing of your personal data may involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

HOW WE PROTECT YOUR DATA?

All information you provide to us is stored on our secure servers and we work hard to protect you from unauthorised access to or alteration, disclosure or destruction of your personal data. 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 limit access to your personal data to only those employees who have a legitimate reason to view and process it. All parties with access to your personal data are all subject to a strict duty of confidentiality.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way. We have put in place procedures to deal with any suspected personal data breach and will notify you and the ICO of a breach where we are legally required to do so. We reserve the right to suspend all or part of the App without notice if we suspect or detect any data breach. We may send an automatic text message to your phone number to notify you if we believe that your account was compromised or some or all of your personal data were leaked.

If you believe that your Ringoid account has been compromised or is no longer secure, you can erase data or delete your account from the App. If you can't do that (for example, you do not have access to your phone number or your device), please notify us immediately by sending email to data.protection@ringoid.com . You will be asked to prove to us that you are a legal account holder of that phone number by providing us with a copy of a government issued identity document (such as a passport) and a bill from your mobile phone provider where we can identify both your name and phone number. We won't be able to give you access to the account but we will delete it and block phone number permanently. Unfortunately, we can't migrate account to another phone number.

HOW LONG DO WE RETAIN YOUR PERSONAL DATA?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for (as set out above), including for the purpose of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data, and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data: see Your legal rights section below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

YOUR LEGAL RIGHTS

Under certain circumstances you have the following rights under data protection laws in relation to your personal data: