Last modified date: 23 April 2019
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.
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.
By post: The Data Protection Officer, Ringoid Ltd, 97 Friars Mead, London, E14 3JY, United Kingdom.
By email: email@example.com
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.
THE DATA WE COLLECT AND HOW THE DATA IS COLLECTED
We will collect and process the following data about you:
Information you give us
- When you install the App from Google Play or App Store and create an account via the App you will provide us with some very basic details necessary for the App to function, limited to your phone number, year of birth and sex (male or female).
- After you complete account registration, you can use the App immediately. If you want to interact with other users (such as receive likes from them, like or message them), you need to upload your photo however this is submitted voluntarily at your absolute discretion. After you uploaded your photo, other Ringoid users can discover your profile and view your photos. You can upload or delete your photos at any time in the App. Please ensure that you do not upload photos or send messages which you would not want to be seen, collected, used, saved or shared by other users.
- If you report other users through the App or send us email, we will keep a record of that correspondence.
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:
- Contact Data: This is strictly limited to phone number you provided during registration.
- Location Data: This is limited to recent geolocation (latitude, longitude). You will need to opt-in and explicitly enable location in the App.
- Technical Data: includes internet protocol (IP) address.
- Device Data: includes the model of device you use and its operating version.
- Profile Data: This is limited to your year of birth and sex you provided during registration, the App settings, photos you voluntarily choose to upload, and records of your interactions with other users or their profiles (including when you like, message, block or report them).
- Usage Data. This limited is to running and operation of App and crashes that may occur.
Information we receive from others
We may receive personal data about you from various third parties as set out below:
- Other users of the App. In certain instances other users may provide information about you in emails they write and send to us.
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:
- To administer your Ringoid account. This includes creating and managing your account, informing the algorithms used to show you the best user profiles in relation to your location and other preferences, and providing you with customer support and responding to your requests, queries and resolving complaints.
- To help you discover and connect with other Ringoid users. We strive to show you such profiles of users of the opposite sex that might
arise your interests and prompt you to start exchanging messages. By using your geolocation and sex you provided during registration, we allow you to
browse users of the opposite sex in the nearby area and view their photos, and other users can discover your profile and view your photos as well.
We do not display location or distance, and do not allow search by specific location or area. You will be asked to consent to the App collecting
your geolocation and using it for this purpose by tapping on "Enable Location" in the App. You can revoke location permission at any time from
Android system settings or by reinstalling the App.
- For statistical purposes. This includes analysing the performance of the App to understand how you use and interact with the App and other users.
- For security and fraud prevention. We strive to ensure that the App is safe and remains safe, secure and used by all Ringoid users in line
with our Terms of Service. For example, we collect our users' year of birth to ensure
they are at least 18 years old. We develop various methods to analyse fraud or illegal or unauthorised activities, and retain data related to
fraudulent activities to prevent against recurrences.
- To ensure legal compliance. To ensure that you are complying with our Terms of Service and our statutory and regulatory obligations.
Purposes for which we will use your personal data
Most commonly we will use your personal data in the following circumstances:
- Where you have consented before the processing. Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want.
- Where we need to perform a contract. Performance of contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
- Where it is necessary for our legitimate interests. Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
- Where we need to comply with a legal or regulatory obligation. This is where we are required to process your personal data where it is necessary for compliance with a legal obligation that we are subject to.
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 use third parties (including Amazon AWS, Papertrail, Google Fabric, Google Firebase, Yahoo Flurry, Sentry, Branch) to help us operate the data hosting, maintenance, analytics, security and technical management of the App.
- We may reveal your personal data to any law enforcement agency, court, regulator, government authority or other organisation if we believe we need to do so to keep to a legal or regulatory obligation, or otherwise to protect our rights or the rights of anyone else. This may include HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.
- We may reveal your personal data to professional advisers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
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.
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:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield
- Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
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 firstname.lastname@example.org . 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:
- Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.