A. IN BRIEF
B. COLLECTION OF AND PROCESSING OF YOUR PERSONAL DATA
The use of this platform may result in the collection and processing of your personal data. The term “personal data” under data protection law refers to all information relating to a specific or personally identifiable person (PII). An IP address can also be considered personal data. An IP address is assigned to each device connected to the internet by the internet service provider so that it can send and receive data. When you use the platform, we collect data that you provide yourself. In addition, when you use the platform, we also automatically collect certain information about your use of it.
We process personal data in compliance with the applicable data protection regulations. We will only process data where we are legally permitted to do so. When you use this platform, we will process personal data only with your consent, for the performance of a contract to which you are a party, or in order to take steps at your request prior to entering into a contract, for compliance with a legal obligation, or if the processing is necessary for the purposes of our legitimate interests or the legitimate interests of a third party, except where such interests are overridden by your interests or fundamental rights and freedom which require the protection of personal data.
C. COLLECTING PERSONAL INFORMATION
We may collect the following personal information, and you choose to give us certain information when using our services including but not limited to the following:
- information about your computer including your IP address, geographical location, browser type and version, and operating system;
- information about your visits to and use of this website including the referral source, length of visit, page views, and website navigation paths;
- information from and about the device(s) you use to access our services, including hardware and software information such as IP Address, 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’s settings and in some cases, disable entirely), and identifies associated with cookies or other technologies
- information, such as your email address, that you enter when you register with our website, to set up subscriptions to our emails and/or newsletters, promotions, events or contests, etc. along with the basic details necessary for the service to work, such as your Account’s Sid and Token.
- information that you enter when you create a profile on our website for example, your name, profile pictures, gender, birthday, relationship status, interests and hobbies, educational details, institute details, employment details etc., which may be requested on portal from time to time;
- when you complete your profile, you have an option to select your number to use our services.
- information that you enter while using the services on our website;
- information that is generated while using our website, including when, how often, and under what circumstances you use it;
- information relating to anything you purchase, services you use, or transactions you make through our website (rather than through a platform such iOS or Android), which includes your name, address, telephone number, email address, and credit / debit card details or other financial information;
- information contained in any communications that you send to us by email or through our website, including its communication content, metadata and hashed data;
- Our application also provides option of referral and hence shall enable collection of referral email id, phone number etc. However, user entering such PII on behalf of the referral shall completely hold consent of the referral for such act and any liability that may arise on us for using such referral’s PII for marketing or otherwise, shall have to be completely indemnify us by you.
In addition to the information you may provide us directly, we receive information about you from others, including:
- Social Media: You may decide to share information with us through your social media account, for instance if you decide to create and log into your account via your social media or other account (e.g., Facebook, Google or Apple).
- Other Partners: We may receive information about you from our partners where our ads are published on a partner’s service (in which case they may pass along details on a campaign’s success). Where legally allowed, we can also receive information about suspected or convicted bad actors from third parties as part of our efforts to ensure our members’ safety and security.
- Information generated or automatically 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.
Certain areas and features of the website are available to you without the need to provide us with any information. However, other features of the Site or the Service will require providing the website with details such as your name, email address, address, mobile number etc., personally identifying information, a username and a password (collectively the “Registration Information”). There are no user IDs & passwords of any government or other institution asked on the platform. Any of your information that has been availed from any third party, basis on this consent, shall be used only in accordance with specific internal procedures as well as the statutory stipulations and safeguards governing access, in order to operate, develop or improve the service.
Before you disclose to us the personal information of another person, you must obtain that person’s consent to both the disclosure and the processing of that personal information in accordance with this policy. In case of any discrepancies and/or issues arising due to such “on behalf” submission, the submitter shall be liable and obligated under the then existing PII and other applicable rules and regulations.
D. PROCESSING PERSONAL INFORMATION
The company and its partners collect and use your personal information and other information only as follows (“The purpose”):
- To deliver and improve our services, using the information is to deliver and improve the services. Additionally, we use the information to help keep you and our community safe.
- Administration of your account and providing services to you: This includes creating and managing account; providing you with customer support and responses to the requests; personalizing prices, offer discounts and other promotions; completion of the transactions; and administration of the sweepstakes and contests.
- Help you connect with others: Displaying call logs; Recording of a call (if enables); and enabling the users to search for and connect.
- To send you any administrative notices, offer alerts and other Transactional Communications relevant to your use of the Service;
- Since, the goal is to help you make meaningful connections, the main sharing of members’ information is, of course, with other members. We also share some types of members’ information with service providers and partners who assist us in operating the services, with other Match Group companies for specified reasons as laid out below and, in some cases, legal authorities.
- To enable you to apply for certain products and services for which you have chosen to apply;
- For market research, project planning, troubleshooting issues, detecting and protecting against error, fraud, advertising campaigns, marketing the services or other criminal activity;
- 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 are comfortable being visible.
- To enforce Company’s terms & conditions;
- To use data in connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation).;
- To analyze usage of the site and to improve the Service/s and security;
- To perform various analytics for the betterment of the user experience/products
- To carry out obligations arising from any contracts entered into between the User and company and to provide User facilities and services as per Users interest.
- To provide User with information about other services, events and services that company offer that are similar to this User have already purchased or inquired about or other communications containing information about new services or upcoming events of the company, company’s affiliates and non-affiliated third parties such as societies and sponsors, if User has consented to receive this information.
- To notify the User about changes or updates to application’s User account.
- To respond to the Users to requests, inquiries, comments or concerns.
- To allow the User to participate in interactive features of our service when User chooses to do so.
- We use vendors to help us operate, distribute, market and improve our services, such as data hosting and maintenance, analytics, customer care, marketing, advertising, payment processing and security operations. We also share information with vendors 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 vendors. We follow a strict vetting process prior to engaging any vendor or working with any partner. Our vendors and partners must agree to strict confidentiality obligations.
- You may choose to share other members’ profiles and they may share yours with people outside of our services, using the sharing functionality.
- 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.
- 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.
If you are a job applicant, the personal information we process about you may vary depending on the job you seek but typically includes what you provide to us as part of your job application as well as professional qualifications, background and reference information that recruiters or other third parties share with us. We use this information to support the recruitment process, which may lead to an employment contract. For contractors and vendor representatives, we may process identification information and work-related information, as necessary to manage our relationship with you and your employer, which is necessary for the performance of the services agreement, and to establish, exercise or defend potential legal claims. We may share personal information with service providers that assist us with recruitment and technical data processing operations as well as with Match Group companies (for instance if you have a business relationship with employees of an affiliate). We keep your personal information only as long as necessary for those purposes.
E. CONSENT TO OVERRIDE DND
By using the platform and its services, you specifically provide consent to the company to send you transaction, service explicit & service implicit communications which are essential to continue the services like sending OTP for log-in, Status of Application etc., irrespective of your Do Not Disturb Registration with TRAI, DoT and/or any other Appropriate Authority. Similarly, you provide your explicit consent for sending across various communications on your registered email as well as phone number through various communication applications like WhatsApp as may be integrated with portal in future.
F. SHARING OF PERSONAL DATA
As a policy we do not disclose any personal information to anyone other than those to our employees, officers, professional advisors’, third party contractors, third party service providers as reasonably necessary for the purposes set out in this policy.
We may disclose your personal information to any member of our group of companies (this means our subsidiaries, our ultimate holding company /ies and all its subsidiaries) as reasonably necessary for the purposes set out in this policy.
There are several products and services that may be offered by third parties on our Site, (collectively, “Offers”). If you choose to apply for these separate products or services, disclose information to the providers, or grant them permission to collect information about you, then their use of your information is governed by their privacy policies and they will be acting as data controllers of your information. You should evaluate the practices of these external services providers and should view their privacy policies or contact them directly for further information before deciding to use their services. The company is not responsible for their privacy practices.
Personal data may also be shared with third party service providers, who will process it on behalf of the Company for the purposes identified above subject to confidentially arrangements and strictly on need-to-know basis, these include:
- Payment collection services providers (Payment gateways and otherwise required for digital payment collection)
- Identity verification agencies
- Fraud prevention agencies
- Digital marketing and content delivery agencies
- Application service provider
- Any other service provider strictly required on need basis to fulfill the purpose of service delivery as envisaged for this portal (“Purpose”).
For the purposes of Data Protection Law, the Company is a data controller of your personal data. You can get in touch with the Company by using the contact details mentioned in the contact us page.
Notwithstanding the foregoing, the company reserves the right (and you authorize the company) to share or disclose your personal information when the company determines, in its sole discretion, that the disclosure of such information is necessary or appropriate:
- As required by law
- When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request,
- in connection with any ongoing or prospective legal proceedings;
- If the company is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information; Optionally, company may provide choices you may have regarding your personal information then.
- In the event that the business is sold or merged or integrated with another business/investor, your details will be disclosed to our advisers and any prospective purchaser’s adviser and will be passed to the new owners/investors of and/or in the business.
- We may sell, license or distribute information in anonymized or aggregated form so that the information does not identify a specific user, without restriction, including, but not limited to, for producing data analytics and reports for business partners or other third parties.
G. SECURITY OF YOUR PERSONAL INFORMATION
- We will take reasonable technical and organizational precautions to prevent the loss, misuse, or alteration of your personal information.We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it.
- We use a combination of firewalls, encryption techniques and authentication procedures, among others, to maintain the security of your online session and to protect the accounts and systems from unauthorized access.
- All electronic financial transactions entered into through our website will be protected by encryption technology.
- When you register for the Service, this platform requires a password from you for your privacy and security. The platform transmits information such as your Registration Information for the company/ this platform or Account Credentials securely.
- Our databases are protected from general employee access both physically and logically. We encrypt your Service password so that your password cannot be recovered, even by us.
- You acknowledge that no method of transmission over the Internet, or method of electronic storage, is 100% secure, however, therefore, we cannot guarantee its absolute security. If you have any questions about security on our Web site, you can contact us on the email provided in contact us segment on our website.
H. DATA TRANSFERS
Presently the platform is operational across various countries and territories across globe. Information that we collect may be stored, processed in, and transferred between any of the countries in which we may operate in the future in order to enable us to use the information in accordance with this policy. You expressly agree to the transfers of personal information described in this Section. We hereby declare that the data localization is not practiced as the platform is independent of territories.
I. USING YOUR INFORMATION FOR MARKETING PURPOSES
From time to time we may request more personal information in order to provide you with other benefits of the Service. The company may aggregate personal information and disclose such data in a manner to:
- Third parties for their marketing and promotional purposes;
- Users of the Service for the purpose of comparing with relative to the broader community.
- Such information may not identify you individually. We may also use third party service providers to help us provide the Service to you, such as sending e-mail messages on our behalf or hosting and operating a particular feature or functionality of the Service. Our contracts with these third parties outline the appropriate use and handling of your information and prohibit them from using any of your personal information for purposes unrelated to the product or service they’re providing.
J. RETENTION OF PERSONAL INFORMATION
We need your personal data in order to:
- Provide our products and services to you.
- Manage our business for our legitimate interests.
- Comply with legal obligations, if any
You may choose not to share personal data or withdraw consent but doing so may limit the services we are able to provide to you. However, once you choose to withdraw the consent the personal data which has been shared, shall continue to remain with us for as long as the applicable law provides.
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. Note that we will close your account automatically if you are inactive. After your account is closed, we will delete your personal information, as laid out below:
- 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 conducts. The retention of information during this safety retention window is based on our legitimate interest as well as that of potential third-party victims.
- Once the safety retention window elapses, we delete your data and only keep limited information for specified purposes, as laid out below:
- 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 consents members give us for five years to evidence our compliance with applicable law.
- We maintain limited information on the basis of our legitimate interest: we keep customer care records and supporting data as well as imprecise location of download/purchase 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 defence 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.
- 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).
We may retain your Personal Data for a period of time consistent with the purpose of collection. We determine the appropriate retention period for Personal Data on the basis of the amount, nature, and sensitivity of your Personal Data, the potential risk of harm from unauthorized use or disclosure, and whether we can achieve the purposes of the processing through other means, as well as the applicable legal requirements (such as applicable statutes of limitation). If there is any information that we are unable, for technical reasons, to delete entirely from our systems post appropriate retention period, we will put in place appropriate measures to prevent any further use of the data.
K. CHANGES TO YOUR PERSONAL INFORMATION
If your personal Information provided when you applied for a product on platform, changes, you may update it whenever you apply for a new product. To review and update your personal information to ensure it is accurate while your application is in process
We will retain your information for as long as your account is active or as needed to provide you services or as may be required for internal analysis purpose or as may be required by law, whichever is later. If you wish to cancel your account or request that we no longer use your information to provide you services, contact us at email provided in contact us section of website. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
L. LOG FILES
As is true of most web sites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you, to improve marketing, analytics, or site functionality
M. TRACKING TECHNOLOGIES / COOKIES
If enabled, we may place cookies on your machine that store small amounts of data on your computer about your visit to any of the pages of this Website. Cookies are small electronic files that collect information when someone visits a website. They can identify the pages that are being viewed and this can assist us in tracking which of our features appeal the most to you and what content you may have viewed on past visits. Some cookies only exist whilst viewers are online, but ‘persistent’ cookies are not session-based and remain on the viewer’s computer. When you visit this site again, ‘persistent’ cookies can enable us to customize our content according to your preferences.
Technologies such as: cookies, beacons, tags and scripts are used by Company and our partner entities, affiliates, or analytics or service providers such as google Ad sense, google analytics etc. These technologies are used in analyzing trends, administering the site, tracking users’ movements around the site and to gather demographic information about our user base as a whole.
We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.
N. TESTIMONIALS, BLOGS, AND OTHER FORUMS ON THIS WEBSITE
With this consent of yours, we may post your testimonial along with your name. If you want your testimonial removed, please contact us at email mentioned in contact us on website.
If you use a blog or other public forum on our Site, any information you submit there can be read, collected, or used by other users and could be used to send you unsolicited messages. We are not responsible for the personal information you choose to submit in these forums. These forums may be hosted by the Company by one of our third-party service providers on the Company’s behalf. To request removal of your personal information from our blog or community forum, contact us on the email mentioned in contact us segment of website. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
O. BEHAVIORAL TARGETING / RE-TARGETING
We may partner with a third party to either display advertising on our platform or to manage our advertising on other sites. Our third-party partner may use technologies such as cookies to gather information about your activities on this site and other sites in order to provide you advertising based upon your browsing activities and interests. There are a number of products and services that may be offered by third parties on our Site, (collectively, “Offers”). If you choose to apply for these separate products or services, disclose information to the providers, or grant them permission to collect information about you, then their use of your information is governed by their privacy policies and they will be acting as data controllers of your information. You should evaluate the practices of these external services providers and should view their privacy policies or contact them directly for further information before deciding to use their services. The Company is not responsible for their privacy practices.
P. SINGLE SIGN-ON
In future, there may be options wherein you can log in to our site using sign-in services such as Facebook, Google or an Open ID provider. These services will authenticate your identity and provide you the option to share certain personal information with us such as your sign-in information, name and email address to link between the sites.
Q. LIKE / SHARE BUTTON
If you use the “Like” / “Share” button to share something, that item will appear on your Social Media profile page and also on your friends’ newsfeed, depending on your social media’s privacy settings. You may also receive updates in your social media account’s newsfeed from this site or item in the future. Such social media companies also collect information such as which pages you have visited on this and other sites that have implemented the “Like” button.
R. LINKS TO THIRD PARTY SITES
S. OPTING OUT
We provide our registered customers with periodic emailers and email/SMS alerts. We also allow users to unsubscribe to email newsletters and from time to time may transmit emails promoting the company or third-party goods or services. The company’s subscribers may opt-out of receiving our promotional emails and terminate their newsletter subscriptions by following the instructions in the emails. Opting out in this manner will not end transmission of service-related emails/SMS, such as email/SMS alerts.
T. YOUR RESPONSIBILITY
You shall not disclose to any other person, in any manner whatsoever, any information relating to the Company of a confidential nature obtained in the course of availing the services through the website of the Company. Failure to comply with this obligation shall be deemed a serious breach of the terms herein and shall entitle the Company to any damages, to which you may be entitled otherwise.
If you have any complaints, security related concern, please contact nodal officer at the email mentioned on contact us segment on our website. We will work closely with you to ensure going a rapid and personal response to your concerns.
You are responsible for maintaining the confidentiality of your login id and password. You are responsible for maintaining the security of your Login ID and Password and may not provide these credentials to any third party. If you believe that they have been stolen or been made known to others, you must contact us immediately at
details mentioned in contact us segment of website. We are not responsible if someone else accesses your account through Registration Information they have obtained from you or through a violation by you of this Privacy and Security Policy or the Company’s Terms & Conditions.
U. USER’S RIGHTS AND CHOICES
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. The options are as follows:
- Access / Update tools in the service: Tools and account settings can help you access, rectify or remove information that you provided to us and that’s associated with your account directly within the service. If you have any questions on those tools and settings, please contact our customer care team for help.
- Device Permissions: Mobile platforms can have permission systems for specific types of device data and notifications, such as phone contacts, pictures, location services, 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 service. We also want you to be aware of your privacy rights. Depending on where you live, you may have the right to access/know, delete/erase, correct/rectify/update, object/restrict.
For your protection and the protection of all of our members, we may ask you to provide proof of identity before we can answer the above requests. Keep in mind, we may reject requests, including if we are unable to authenticate you, if the request is unlawful or invalid, or if it may infringe on trade secrets or intellectual property or the privacy or other rights of someone else. If you wish to receive information relating to another member, such as a copy of any messages you received from them through our service, the other member will have to contact us to provide their written consent before the information is released. We may also ask them to provide proof of identity before we can answer the request. Also, we may not be able to accommodate certain requests to object to or restrict the processing of personal information, notably where such requests would not allow us to provide our service to you anymore. For instance, we cannot provide our service if we do not have your date of birth and thus cannot ensure that you are 18 years of age or older.
V. CHANGES TO THE POLICY
W. CONTACT US WITH QUESTIONS OR CONCERNS
If you have questions, comments, concerns or feedback regarding this Privacy and Security Policy or any other privacy or security concern, send an e-mail to Nodal Officer, as per details mentioned in contact us segment of our website.
This Policy shall be governed by and construed in accordance with the laws of the Republic of India and the courts at Ahmedabad, Gujarat, India shall have sole and exclusive jurisdiction in relation to any disputes arising out of or in connection with this Policy.
X. IPR OWNERSHIP
You shall not copy, modify, transmit, distribute / re-distribute, reverse engineer etc., but not limited to, or in any way exploit the Products or any other copyrighted materials and content provided other than for your individual training. Any other purpose is expressly prohibited under these terms. You shall also not permit anyone else to copy, use, modify, transmit, distribute or in any way exploit the Products or any other copyrighted materials, trademark/ registered mark, the designs, innovations, business ideas etc., which together shall be known as IPR and the ownership of the same belongs to the company. Any infringement, theft etc., of the IPR of the company shall result in criminal proceedings against you at your risk, cost and consequences.
You will not (and will not allow any third party to) attempt to copy, record or reverse engineer any Videos or Documentation supplied by Company or stored on the website (or related) websites, outside the application in any manner.
Y. OUR COMMITMENT TO YOU
At MyTelfon, your privacy is our top priority. Your privacy is at the core of the way we design and build the services and products you know and love, so that you can fully trust them and focus on building meaningful connections.
We appreciate that you put your trust in us when you provide us with your information and we do not take this lightly.
Our commitment to privacy: We design all of our products and services with your privacy in mind. We involve experts from various fields, including legal, security, engineering, product design and others to make sure that our decisions are taken with the utmost respect for your privacy.
Our commitment to security: We have teams dedicated to keeping your data safe and secure. We constantly update our security practices and invest in our security efforts to enhance the safety of your information.
Z. CHILDREN’S PRIVACY
Our Services do not address anyone under the age of 18. We do not knowingly collect personal identifiable information from children under 18. In the case we discover that a child under 18 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 necessary actions. Users below 18 years of age are advised to use this platform/ Services under guardian ship of their parent/s and/or legal guardian. If you believe an underage person might have signed up, feel free to contact us at firstname.lastname@example.org.