JigTalk App Limited (“JigTalk”, “us” or “we”) is a company registered in England and Wales with company registration number: 09954196. We are committed to protecting and respecting your privacy.

SCOPE OF POLICY

This policy (together with our end-user licence agreement as set out at https://www.jigtalk.com (“EULA”) and any additional terms of use incorporated by reference into the EULA, together “our Terms of Use”) applies to your use of JigTalk mobile application software (“App”) once you have downloaded a copy of the App onto your mobile telephone or portable device (“Device”).

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

By downloading and using the App you are accepting and consenting to the practices described in this policy.

For the purpose of the Data Protection Act 1998, the data controller is JigTalk.

Our Legal Justification For Processing Your Personal Data

We process your personal data on the basis of your express and explicit consent. We will make you aware of the data that we are processing about you either as part of this privacy policy or upon your request to us at any time.

The Purpose Of Our Processing

We process your Personal Data in order to provide the Services to you and to provide you with the other information that we set out in this Privacy Policy.

Change Of Purpose

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.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Information We May Collect From You

We may collect and process the following categories of Personal Data from you:

– First name
– Last name
– Gender
– Facebook id
– DOB
– Biography
– Occupation
– Phone
– Email
– MAC address
– IP address
– Data contained in your messages
– Sexual preference

We may collect and process the following data about you:

● “Information you give us (Submitted information)”: You may give us information about you by filling in forms on the App or by corresponding with us (for example, by e-mail or chat). This includes information you provide when you download or register to use the App, subscribe to any of our Services, share data via the App’s social media functions, or when you report a problem with the App or our Services. The information you give us may include your name, address, e-mail address and phone number, age, date of birth, identification code, password and other registration information, personal description and photograph.

● “Special Categories (sensitive data) of Information you give us (Submitted information)”. Your personal description will include a special category of personal data such as your sexual orientation and may also include your race or ethnicity, religious or philosophical beliefs, sex life, political opinions, trade union membership, information about your health and genetic and biometric data or any other information that you decide to submit. Any information that you provide as part of your personal description will be made generally available to the users of the service and therefore it will become public knowledge. You should consider very carefully what information you decide to disclose about yourself when using the service as you may be making that information available publicly.

● Information we collect about you and your device. (“Log Information”) Each time you use our App we may automatically collect the following information:

● technical information, including the type of device you use, (for example, the MAC address of the Device’s wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use and your time zone setting (Device Information);

● The User ID information stored on your Device; or

● details of your use of the App (Log Information).

● Location information. (“Log Information”) We will use GPS technology to determine your current location. All of our Services require your personal data to work. You will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by selecting the settings button from the App’s main menu and turning off visibility (or by disabling location services on your Device), however doing so will mean you will be unable to use the App or the Services. We need access to your location data because the services we provided are based and reliant upon your location in order to provide a service which is relevant and valuable. Without this, users would not be able to search for people within their own region. If you have background location services turned on, then the App will use this to determine if you have drastically changed your position. The App does this because it needs to know where you are in order for you to search for users in your area or for other users to see that you are in their area. You can turn this off by disabling background location services in your device’s settings, although this might restrict the effectiveness of the App.

Information we receive from other sources (Third Party Information). We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers and credit reference agencies) and may receive information about you from them.
If you contact us, we may keep a record of that correspondence;

● Content Information. This is information which tracks the usage of users who use the platform. This includes recording where and how often you tap a certain screen and when you leave certain pages within the App.

Cookies

We do not use cookies in the provision of our Services.

Uses Made of the Information

We use information held about you in the following ways:

● Submitted Information: To create your publicly visible account and to allow other users to search for you based on the information you provide about yourself. This also helps us to conduct research and analysis of the Service to ensure the highest standards and identify areas for improvement. We may also use this data to provide customer support and management of your account.

● Content Information: To see how our users actually use our Service in order to conduct research and analysis and identify areas for improvement.

● Log information: To provide relevance to the Services because they are location based and also to conduct research and analysis of the Service to ensure the highest standards of services and identify areas for improvement and to provide customer support and management of your account.

We may associate any category of information with any other category of information and will treat the combined information as personal data in accordance with this policy for as long as it is combined.

We do not disclose information about identifiable individuals to our advertisers, but we may provide them with anonymous aggregate information about our users (for example, we may inform them that “X” number of men aged under “X” have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience.

Direct Marketing

We will only send you direct marketing by the method you have indicated to us, which can include Facebook Messenger, SMS and email. We will not allow third parties to send you any direct marking and we will not share your personal data with third parties for the purpose of them sending you direct marketing.

Disclosure of Your Information (Categories of Recipients)

We may disclose your personal information to the follow categories of third parties:

● Authentication Service providers such as Twilio, who receive your registered mobile phone number in order to provide a text message to you are part of a two-factor authentication service;

● In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;

● If JigTalk, or substantially all of its assets are acquired by a third party, in which case personal data held by it about its users will be one of the transferred assets;

● If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request;

● • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services in order to enforce or apply the EULA and other agreements or to investigate potential breaches; or help us comply with our obligations.

● Credit reference agencies and Fraud prevention organisations in order to protect the rights, property or safety of JigTalk, our users, or others.

● HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

Where We Store Your Personal Data (Transfers outside of the EEA)

Generally all of the data that we process is stored within the EEA and is hosted by Amazon Web Services, regardless of the country that we collect that data from. The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”) when strictly required to do so. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy and in any event we will ensure that such transfers of your personal data will be in compliance with the relevant requirements of Data Protection Law.

All Submitted information and other information collected by the App is stored by Parse on their secure servers in accordance with their privacy policy which can be viewed at https://www.parse.com/about/privacy.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to us and any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Certain Services include social networking, chat room or forum features. Ensure when using these features or communicating with any other user that you do not submit any personal data that you do not want to be seen, collected or used by other users.

Data Retention Policy

We will process your data for the duration of your agreement with us. We may have to retain certain information about you and/or your use of the App for tax, legal or statistical purposes but we will then delete your data after seven (7) years have passed and we no longer require your data for legal/claims or tax purposes.

Your Rights You have the right to:

• 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 products or services to you. We will advise you if this is the case at the time you withdraw your consent

No Fee Usually Required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What We May Need From You

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time Limit to Respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Access to Information

If you wish to correct, update or delete any of the personal data which is held about you then you may be do so by selecting settings from the App’s main menu and making any necessary amendments.

Changes to Privacy Policy

Any changes we may make to our privacy policy in the future will be notified to you when you next start the App after the changes have been made. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the App or the Services.

Our App may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates (including, but not limited to, websites on which the App or the Services are advertised). If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.

Contact

Questions, comments, complaints and requests regarding this privacy policy are welcomed and should be addressed to privacy@jigtalk.com

Jigtalk App Limited, Company number 09954196

Registered office address: PO Box 239, 33 Great George Street, Leeds, United Kingdom, LS1 3AJ