Privacy and protection of User data
OUR COMMITMENT TO YOU
At Llename, your privacy is our top priority. It is at the core of how much we design and create, the services and products you know and love, so you can fully trust them and focus on building meaningful relationships.
We are grateful to you for trusting us and providing us with your information, it is not something we take lightly.
We do not put your privacy at risk. We design all products and services with your privacy in mind. We involve experts from various fields, (legal, security, engineering, product design and others), to ensure that no decision is made that does not take your privacy into account.
We work hard to keep your information protected and we have teams dedicated to keeping your data safe and secure. Our security practices are constantly updated and we invest in security to improve the protection of your information.
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We appreciate that you entrust us with your information and we intend to maintain that trust forever. It all starts with making sure you understand the information we collect, why we collect it, how we use it, and what your choices are regarding your information. This Policy describes our privacy practices in plain language, so we try to use as little legal and technical terminology as possible.
DATE OF ENTRY INTO FORCE: May 25, 2018
WHERE THIS POLICY APPLIES
THE INFORMATION WE COLLECT
COOKIES AND OTHER SIMILAR DATA COLLECTION TECHNOLOGIES
HOW WE USE THE INFORMATION
HOW WE SHARE THE INFORMATION
CROSS-BORDER DATA TRANSFERS
HOW WE PROTECT YOUR INFORMATION
HOW LONG DO WE KEEP YOUR INFORMATION
HOW TO CONTACT US
1. WHO WE ARE
C / Jeronima Gales 37, Valencia, Spain
2. WHERE THIS POLICY APPLIES
3. THE INFORMATION WE COLLECT
Clearly, we can’t help you build meaningful relationships without having some information about yourself, such as the basic details of your profile and the types of people you would like to meet. We also collect information generated as you use our services; for example, access logs, as well as third-party information, such as when you access our services through a social media account. If you want additional information, we go into more detail below.
The information you provide us
You choose to give us certain information when you use our services. This includes:
When you create an account, you provide us with at least your login credentials, as well as some basic details necessary for the service to work, such as your gender and date of birth.
When you complete your profile, you can share with us additional information, such as details about your personality, lifestyle, interests, and other details; and also content such as your photography and videos. To add some context, such as photos or videos, you can give us permission to access your camera or photo album. Certain information you choose to provide to us may be considered “special” or “sensitive” in some jurisdictions; for example, your racial or ethnic origin, sexual orientation, and religious beliefs. By providing this information to us, you consent to our processing.
When you subscribe to a payment service or make a purchase directly from us (rather than through a platform such as iOS or Android), you give us, or our payment service provider, information such as your debit card number or credit and other financial information.
When you participate in surveys or focus groups, you give us your perspectives on our products and services, answer our questions, and give us testimonials.
When you participate in our promotions, events or contests, we collect the information that you use to register or participate.
If you contact our customer service team, we collect the information you provide to us during the interaction. Sometimes we monitor or record these interactions for training purposes and to ensure a high quality of service.
If you ask us to communicate with, or otherwise process the information of, other people (for example, if you ask us to send an email on your behalf to one of your friends), we collect the information you give us from other people for the purpose to be able to complete your application.
Obviously, we also process your chats with other users as well as the content you publish, as part of the operation of the services.
Information we receive from others
In addition to the information you provide us directly, we also receive information about you from other people, such as:
Other users may provide information about you as they use our services. For example, we may collect information about you from other users if they contact us about you. In turn, if a user asks us to access the contacts in your phone book, and you are part of it, we can use it to contact you on behalf of the user.
You may be able to use your social media login information (such as your Facebook username and password) to create your account login details on Llename. This helps you avoid having to remember another username and password and allows you to share some information from your social media accounts with us.
We may receive information about you from our partners; for when Llename accounts are created through our partners ‘websites (in which case they pass on registration information to us) or when Llename advertisements are posted on our partners’ websites and platforms (in which case case they can pass on the details about the success of a campaign).
Information collected when you use our services
When you use our services, we collect information about the features you used, how you used them, and the devices you used to access our services. See below for more details:
We collect information about your activity on our services; for example, how you use them (e.g., the date and time you logged in, the features you used, your searches, the clicks and pages that were shown to you, the addresses of referring websites, the ads you clicked on) and how you interact with other users (e.g., the users you interact with, the date and time of your exchanges, the number of messages you send and receive).
We collect information from and about the devices you use to access our services, such as:
Information about hardware and software such as IP address, device identification and type, specific device and application features and preferences, application failures, advertising identifiers (such as Google AAID and Apple IDFA, which are randomly generated numbers that you can reset in the device settings), browser type, version and language, operating system, time zones, identifiers associated with cookies or other technologies that can uniquely identify your device or browser (eg eg IMEI / UDID and MAC address).
Information about your wireless and mobile connection, such as your service provider and signal strength.
Information about your device’s sensors such as accelerometers, gyros, and compasses.
Other information with your consent
If you give us permission, we may collect your precise geolocation (latitude and longitude) through various means, depending on the service and device you are using, including GPS, Bluetooth, or Wi-Fi connections. Obtaining your geolocation may occur in the background when you are not using the services, if the permission you expressly granted us allows such obtaining. If you refuse permission for us to obtain your geolocation, we will not collect it.
Similarly, if you give us your consent, we may collect your photos and videos (for example, if you want to post a photo, video, or broadcast on the services). We may also collect your address book (for example, if you want us to contact your friends on your behalf).
4. COOKIES AND OTHER SIMILAR DATA COLLECTION TECHNOLOGIES
Some web browsers (including Safari, Internet Explorer, Firefox, and Chrome) have a “Do Not Track” (“DNT”) feature that alerts the website that a user does not want their activity to be tracked on line. If a website that responds to a DNT signal receives one, the browser can block that website from collecting certain information about the browser user. Not all browsers offer the DNT option and DNT signals are not yet uniform. For this reason, many businesses, including Llename, currently do not respond to DNT signals.
5. HOW WE USE THE INFORMATION
The main reason we use the information is to provide and improve our services. Additionally, we use the information to protect you and provide you with advertising that is of interest to you. Read on for a more detailed explanation of why we use your information, with practical examples.
To manage your account and provide you with our services
Create and manage your account.
Provide customer service and respond to your requests.
Complete your transactions.
Communicate with you about our services, including order management and billing.
To help you connect with other users
Analyze your profile and that of other users to recommend meaningful relationships.
Show users the profiles of other users.
To ensure a consistent experience across all your devices
Link all the devices you use so that you can enjoy a consistent experience of our services across all of them. To do this, we link devices and browser data, such as when you log into your account on different devices or when using full or partial IP addresses, browser versions and similar data about your devices to identify and link them.
To provide you with relevant offers and advertisements
Manage sweepstakes, contests, discounts or other offers.
Develop, display and track content and advertising tailored to your interests on our services and other sites.
Communicate with you via email, telephone, social networks or mobile devices about the products and services that we think may interest you.
To improve our services and develop new ones
Manage focus groups and surveys.
Carry out research and analysis of user behavior to improve our services and content (for example, we may decide to change the appearance, or even substantially modify a certain characteristic based on user behavior).
Develop new features and services (for example, we may decide to create a new feature based on the interests of the requests received from users).
To prevent, detect and fight fraud and other illegal or unauthorized activities
To deal with alleged misconduct, or continued, on and off the platform.
Perform data analysis to better understand and design measures to combat these activities.
Keep data related to fraudulent activities to prevent their repetition.
To ensure compliance with legislation
Comply with legal requirements.
Assist law enforcement authorities.
Apply and exercise our rights; for example, our Terms and Conditions.
To treat your information as previously described, we use the following legal bases:
Provide our service to you: Most of the time, the reason we process your information is to fulfill the contract we have with you.
For example, as you use our service to create meaningful relationships, we use your information to maintain your account and profile, to make it visible to other users, and to be able to refer you to other members.
Legitimate interests: We use your information when we have legitimate interests to do so. For example, we analyze user behavior on our services to continually improve our offers, suggest offers that we think may interest you, and process information for administrative purposes, fraud detection and other lawful purposes.
6. HOW WE SHARE THE INFORMATION
Since our goal is to help you create meaningful relationships, obviously, user information is shared with other users. We also share certain user information with service providers and partners who assist us in operating our services, in some cases, with legal authorities. Read on for more details on how information is shared with other people.
With other users
You share information with other users 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 material that you do not care to see publicly, as neither you nor we can control what others do with the information once it is shared.
If you choose to limit the audience of all or part of your profile or of certain content or information about you, it will be visible according to your preferences.
With our service providers and partners
We use third parties to help us operate and improve our services. These third parties assist us in various tasks, such as data hosting and maintenance, analytics, customer service, marketing, advertising, payment processing, and security operations.
We may also share the information with partners who distribute and assist us in advertising our services. For example, we may share limited information about you in a processed, human-unreadable format to our advertising partners.
We follow a strict evaluation process before hiring a service provider or working with a partner. All service providers and partners must accept strict confidentiality obligations.
For corporate transactions
We may transfer your information if we participate, in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy, or other change of ownership or control.
When required by law
We may disclose your information if it is reasonably necessary: i) to comply with a legal process, such as a court order, subpoena or search warrant, government / police investigation or other legal requirement; ii) to assist in the prevention or detection of a crime (subject in each case to the applicable legislation); or iii) to protect the safety of any person.
To apply legal rights
We may also share information: i) if the disclosure mitigates our liability in an actual or alleged claim; ii) as necessary to protect our legal rights and those of our users, business partners and other interested parties; iii) to enforce our agreements with you; and iv) to investigate, prevent, or take other actions related to illegal activities, suspected fraud or other misconduct.
With your consent or at your request
We may ask for your consent to share your information with third parties. In that case, we will be clear as to why we want to share the information.
We may use and share non-personal information (meaning information that, by itself, does not identify who you are, such as your device information, general demographic data, general behavioral data, geolocation in non-identifiable format), as well as personal information in a processed format, unreadable for humans, in any of the aforementioned circumstances. We may also share this information with other companies in the Llename group and third parties (especially advertisers) to develop and provide targeted advertising on our services and on third-party websites or applications, and to analyze and report on the advertising you may see. This information may be combined with additional non-personal information or information in a processed format.
7. CROSS BORDER DATA TRANSFERS
Sharing the information set forth in Section 6 sometimes involves cross-border data transfers; for example, to the United States of America and other jurisdictions. As an example, where the service allows users to be located in the European Economic Area (“EEA”), your personal information is transferred to countries outside the EEA. We use model contractual clauses approved by the European Commission or other appropriate protection to allow the transfer of data from the EEA to other countries. Model contractual clauses are binding commitments between companies that transfer personal data, to protect the privacy and security of your data.
8. YOUR RIGHTS
We want you to have control of your information, for this we provide you with the following tools:
Access / update tools in the service. Tools and account settings that help you access, rectify or delete the information that you provided us and that is associated with your account directly within the system. If you have any questions about those tools and settings, please contact our customer support team here for assistance.
Permissions for devices. Mobile platforms have permission systems for specific types of device data and notifications, such as the phone book, location services, and push notifications. You can change the preferences on your device to consent or object to the collection of the relevant information or to display the relevant notifications. Obviously, if you do that, certain services may not have full functionality.
Elimination. You can delete your account directly in the service, using the relevant function for this.
We want you to know your privacy rights. Some key points to remember:
Review your information. Applicable privacy laws may give you the right to review the personal information that we hold about you (depending on the jurisdiction, this may be called the right of access, right of portability, or variations of these terms).
Update your information. If you believe that the information we have about you is inaccurate or that we no longer have the right to use it, and you want to request its rectification, deletion or object to its treatment.
For your protection and that of our users, we may ask you to provide proof of identity before responding to the aforementioned requests.
Remember, we may reject some requests for certain reasons, for example if the request is unlawful or if it violates trade secrets, intellectual property, or the privacy of another user. If you wish to receive information related to another user, such as a copy of a message that he / she received from him / her through our service, the other user must contact our Privacy Director to provide written consent before the information is communicated. .
Similarly, we may not be able to accommodate certain requests to object to the processing of personal information, especially when such requests do not allow us to provide our service to you. For example, we cannot provide our service if we do not have your date of birth.
Uninstall. You can stop all information gathering for an app by uninstalling it, using the standard uninstall process for your device. If you uninstall the application from your mobile device, the unique identifier associated with your device will continue to be stored. If you reinstall the application on the same mobile device, we may again associate this identifier with your previous transactions and activities.
Responsibility. In certain countries, including those in the European Union, you have the right to file a complaint with the appropriate data protection authority if you have concerns about how we treat your personal information. The data protection authority to which you can lodge a complaint can be found in the place of your habitual residence, where you work or where you are established.
9. HOW WE PROTECT YOUR INFORMATION
We work hard to protect you from the unauthorized use, alteration, disclosure or destruction of your personal information. As with all technology companies, although we take steps to protect your information, we do not promise, nor should you expect, that your personal information will always be kept secure.
We regularly monitor our systems to find possible vulnerabilities and attacks and we constantly review the information collection, storage and processing practices to update our physical, technical and organizational security measures.
We may suspend your use of all or part of the services without notice if we suspect or detect any security breach. If you believe your account or information is no longer secure, please let us know immediately here.
10. HOW LONG DO WE KEEP YOUR INFORMATION
We keep your personal information only as long as we need it for our legitimate business purposes (as set out in Section 5) and as permitted by applicable law. To safeguard the security and protection of our users inside and outside our services, we have implemented a security retention period of one year, after account deletion. During this period the account information will be kept even though, obviously, the account will no longer be visible in the services.
In practice, we delete or anonymize your information after the deletion of your account (depending on the security retention period) or after two years of continuous inactivity, unless:
there is a pending issue, claim or dispute that requires us to keep relevant information until resolution; or
the information should be kept for our legitimate business interests, such as preventing fraud and improving user protection and safety. For example, it may be necessary to keep the information to prevent a user who was kicked out due to unsafe behavior or security incidents from opening a new account.
Remember that although our systems are designed to execute data deletion processes in accordance with the aforementioned guidelines, we cannot promise that all data will be deleted in a specific period of time due to technical restrictions.
11. PRIVACY OF MINORS
Our services are limited to users who are over 18 years of age. We do not accept users under the age of 18 on our platform and we do not knowingly collect personal information from anyone who is under the age of 18. If you suspect that a user is under 18 years of age, please use the reporting mechanism available on our service.
Because we are always looking for new and innovative ways to help you build meaningful relationships, this policy may change as time goes on. We will notify you before any material changes take effect so that you have time to review the changes.
13. HOW TO CONTACT US
By mail: [email protected]
C / Jerónima Gales 37, 46017 Valencia, Spain