To: Ali Osman Özdilek, Lawyer, CIPP/E
Address: World Trade Center, Prinses Margrietplantsoen 33, 2595 AM The Hague/Netherlands
Last updated on October 6, 2021
Table of Contents
We collect certain data from you directly, like the information you enter yourself, data about your usage, and data from third-party platforms you connect with us. We also collect some data automatically, like information about your device and what parts of our Services you interact with or spend time using.
We may collect different data from or about you depending on how you use the Services. When you create an account and use the Services, including through a third-party platform, we collect any data you provide directly, including:
* The data listed above is stored by us and associated with your account in our Services.
In addition to the information you provide us directly, we receive information about you from others or by automated means, including:
- Device Information: We collect information from and about the device(s) you use to access our Services, including:
hardware and software information such as IP address, device type, device-specific and apps settings and characteristics, app crashes, advertising IDs (such as Google’s AAID and Apple's IDFA, both of which are randomly generated numbers that you can reset by going into your device’ settings), browser type, version and language, operating system, time zones, identifiers associated with cookies or other technologies that may uniquely identify your device or browser.
- Other information with your consent: If you give us permission, we can collect your precise geolocation (latitude and longitude) through various means, depending on the service and device you’re using, including GPS, Bluetooth, or Wi-Fi connections. The collection of your geolocation may occur in the background even when you aren’t using the Services if the permission you gave us expressly permits such collection. If you decline permission for us to collect your geolocation, we will not collect it. Similarly, if you consent, we may collect your photos and videos (for instance, if you want to publish a photo, video, or streaming on the Services).
We use tools like cookies, web beacons, analytics services, and advertising providers to gather the data listed below. Some of these tools offer you the ability to opt-out of data collection.
We use third-party SDKs for various reasons and down below is a list of each third party SDK we use to give better results by receiving better analytics. The information we give and receive are non-user specific. We use these tools to analyze your use of the Services, including information like third party websites you arrive from, how often you visit, events within the Service, usage and performance data, and more. We use this data to improve the Services, better understand how the Services perform on different devices and provide information that may be of interest to you. All the information we send is anonymized and cannot be tracked back to specific users. In other words, it is not possible to draw conclusions about a specific person.
- 3rd Party Usage Analytics Tools: We use tools provided by Google Inc (1600 Amphitheater Parkway, Mountain View, CA 94043, USA, “Google”) in our Services for usage analytics purposes. The answers tool owned by Fabric and acquired by Google is used for usage statistics (https://docs.fabric.io/android/fabric/data-privacy.html). Firebase (https://www.firebase.com/terms/privacy-policy.html) and Google Analytics (https://policies.google.com/privacy?hl=en) operated by Google are also used for usage analytics purposes.
Flurry(https://developer.yahoo.com/flurry/legal-privacy/terms-service/flurry-analytics-terms-service.html) operated by Yahoo is used for usage statistics.
- 3rd Party Conversion Tracking Tools: Google Conversion Tracking APIs and Adjust (https://www.adjust.com/terms/privacy-policy/) are used for user conversion tracking.
- Crash Detection Tools: We use Crashlytics tools owned by Fabric (https://docs.fabric.io/android/fabric/data-privacy.html) for crash detection. It facilitates the maintenance and improvement of the Services. All your crash data is collected anonymously.
We use third-party advertising services like Google’s ad services(DFP, Admob, AdX), Facebook Audience Network, Mopub, and Inmobi to deliver online advertisements to our end users within our Services including mobile applications and websites. The ads may be based on information we know about you as detailed in Section 2.2 Data From Others and information that these ad service providers know about you based on their tracking data. The ads can be based on your recent activity or activity over time and across other services and may be personalized to your likes and interests. When using other services you may also receive personalized online advertisements. From time to time we also advertise our Services on some third-party platforms like Google’s Adwords, Apple’s Search Ads, Unity, Tiktok (Bytedance), Snapchat, Facebook, Google Ads.
Depending on the types of advertising services we use, cookies or other tracking technologies may be placed on your computer, phone, or other device to collect data about your use of our Services, and those tracking technologies may be accessed in order to serve these personalized advertisements to you. To help deliver personalized advertising, we may provide these service providers with a hashed, anonymized version of your personal information in a non-human-readable form and content that you share publicly on the Services.
Only irreversibly anonymized data is used during all advertising processes including personalized advertising thus this does not allow any conclusions to be drawn about the identity of the person concerned.
The main reason we use your information is to deliver and improve our Services. Additionally, we use your info to help keep you safe and to provide you with advertising that may be of interest to you. Read on for a more detailed explanation of the various reasons we use your information, together with practical examples.
To administer your account and provide our Services to you
To help you connect with other users
To ensure a consistent experience across your devices
To provide new services to you
To serve you relevant offers and ads
To improve our Services and develop new ones
To prevent, detect and fight fraud or other illegal or unauthorized activities
To ensure legal compliance
To process your information as described above, we rely on the following legal bases:
Provide our service to you: Most of the time, the reason we process your information is to perform the contract that you have with us. For instance, as you go about using our service to build meaningful connections, we use your information to maintain your account and your profile, to make it viewable to other users and recommend other users to you.
Legitimate interests: We may use your information where we have legitimate interests to do so. For instance, we analyze users’ behavior on our Services to continuously improve our offerings, we suggest offers we think might interest you, and we process information for administrative, fraud detection, and other legal purposes.
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 the stuff that you’re comfortable being publically viewable since neither you nor we can control what others do with your information once you share it.
We use third parties to help us operate and improve our Services. These third parties assist us with various tasks, including data hosting and maintenance, analytics, customer care, marketing, advertising, payment processing and security operations. These service providers may access your personal data and are required to use it solely as we direct, to provide our requested service.
We may also share information with partners 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 partners (these partners are listed in sections 3.2 & 3.3)
We follow a strict vetting process prior to engaging any service provider or working with any partner. All of our service providers and partners must agree to strict confidentiality obligations.
We may disclose your information if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government/law enforcement investigation, or other legal requirements; (ii) to assist in the prevention or detection of crime (subject in each case to applicable law); or (iii) to protect the safety of any person.
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 users, 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.
Moderators to monitor activity on the site/apps and approve content. Fraud prevention and anti-spam providers to protect the service from criminal activity.
In the event that our Services or any of its affiliates undergoes a business transition or change of ownership, such as a merger, acquisition by another company, reorganization, or sale of all or a portion of its assets, or in the event of insolvency or administration, we may be required to disclose your personal data.
You have certain rights around the use of your data, including the ability to opt-out of promotional emails, cookies, and the collection of your data by certain analytics providers. You can update or terminate your account from within our Services, and can also contact us for individual rights requests about your personal data. We want you to be in control of your information, so we have provided you with the following tools:
We want you to be aware of your privacy rights. Here are a few key points to remember:
For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer the above requests.
Keep in mind, we may reject requests for certain reasons, including if the request is unlawful or if it may infringe on trade secrets or intellectual property or the privacy of another user. If you wish to receive information relating to another user, such as a copy of any messages you received from him or her through our service, the other user will have to contact our Privacy Officer to provide their written consent before the information is released.
Also, we may not be able to accommodate certain requests to object to 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.
If you want to exercise any of your rights listed above please visit Feedback Page or email us at firstname.lastname@example.org.
We keep your personal information only as long as we need it for legitimate business purposes and as permitted by applicable law. To protect the safety and security of our users on and off our services, we implement a safety retention window of 6 months following account deletion unless there is a technical difficulty. During this period, account information will be retained although the account will of course not be visible on the services anymore.
In practice, we delete or anonymize your information upon the deletion of your account (following the safety retention window) or after 10 years of continuous inactivity. An account is considered inactive when the Application of the Member has not established contact with servers (including due to deactivation of the geolocation process), and the Member has not used the Application. In any event, the Account of a Premium Member is not considered inactive.
Anonymized information about activity on our Services is retained for longer periods of time for statistical and product research purposes but this is not attributable to an individual once the profile has been deleted.
Keep in mind that even though our systems are designed to carry out data deletion processes according to the above guidelines, we cannot promise that all data will be deleted within a specific time frame due to technical constraints. The deleted data may also be available for up to 72 hours due to caching systems and the interconnection of proxy servers. Some of your data like photos may be in cache for 30 days since the CDN service is renewed every 30 days.
We work hard to protect you from unauthorized access to or alteration, disclosure, or destruction of your personal information. As with all technology companies, 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. Your password is an important part of our security system, and it is your responsibility to protect it. You should not share your password with any third party, and if you believe your password or account has been compromised, you should change it immediately and contact email@example.com with any concerns.
We regularly monitor our systems for possible vulnerabilities and attacks and regularly review our 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 breach of security. If you believe that your account or information is no longer secure, please notify us immediately.
We are not responsible for virus protection outside our service network. We are also not responsible for the damage or destruction of user data. We will pursue every detected attack by hackers, etc. under civil law and, if necessary, by the prosecution.
In case of a breach, we will notify; the EU representatives, our DPO, and our users who were or potentially were affected by the breach within 72 hours of the attack. We will get in contact via email thus, it is important that you sign up with a valid email address that you often check so you are notified of any harmful attacks that may occur.
Data Protection Officer
Jurcom GRC Services B.V.
Address: World Trade Center, Prinses Margrietplantsoen 33, 2595 AM The Hague/Netherlands
Our Services are 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 information from anyone under the age of 18. If you suspect that a user is under the age of 18, please use the reporting mechanism available through the service. If we become aware that a child, minor, or anyone under the age of 18 has registered with us and provided us with personal data, we will take steps to terminate that person’s registration and delete their profile information from our Services. If we do delete a Profile because you violated our no children rule, we may retain basic account and profile information to ensure that you do not try to get around our rules by creating a new profile.
In order to provide the Services to you, we must transfer your data to our servers and process it there. By visiting or using our Services, you consent to the storage of your data on servers. If you are using the Services, you consent to the transfer, storage, and processing of your data. Specifically, personal data collected in Switzerland and the European Economic Area (“EEA”) is transferred and stored outside those areas.
That data is also processed outside of Switzerland and the EEA by our group companies, or our service providers, including to process transactions, facilitate payments and provide support services as described in Section 3 & 4. We have entered into data processing agreements with our service providers that restrict and regulate their processing of your data on our behalf. By submitting your data or using our Services, you consent to this transfer, storage, and processing by us and its processors. We operate a global network of servers including in Germany, the Netherlands, Turkey, and Canada. Data collected by advertising partners may also be held outside the European Economic Area. We ensure that the data is adequately protected by ensuring that valid, legal mechanisms are in place. If you want more information relating to the nature of the safeguards we have in place please email firstname.lastname@example.org.
Consumers residing in California have some additional rights with respect to their personal information under the California Consumer Privacy Act or (“CCPA”).
Your California Consumer Rights.
California consumers have the right to request access to the specific pieces of personal information we have collected about them in the last 12 months. You may make this request up to two times in a 12-month period. You may also request additional details about our information practices, including the categories of personal information we have collected about you, the categories of sources of such collection, the business or commercial purpose for collecting or selling personal information, the categories of third parties with whom we share and sell your personal information, the categories of personal information we have disclosed and sold about you in the preceding 12 months, and the categories of third parties to whom we sold personal information in the preceding 12 months. If you are a California consumer, you also have the right to request the deletion of your personal information (subject to certain exceptions), to opt-out of sales of personal information and to receive equal service and price and not be discriminated against even if you exercise any of your CCPA rights.
California consumers may make a rights request by emailing us at email@example.com. Your request must include sufficient information that allows us to reasonably verify you are the person about whom we collected personal information, which may include your email address, name, and username. If you have an account with us, you can find your account id on your main account page after you log in. To opt-out of the “sale” of your information as described above, you can find the option on app settings. We will not discriminate against you if you choose to exercise your rights under the CCPA.
Because we’re always looking for new and innovative ways to help you build meaningful connections, this policy may change over time. We will notify you before any material changes take effect so that you have time to review the changes.
If you have any questions regarding this privacy statement, the processing of your personal data, you can contact us directly. We are also available to you in the case of requests for information, requests, or complaints:
Our Data Protection Officer can be reached by firstname.lastname@example.org or by mail at the address below.
Address: VLMedia Inc. Universiteler Mahallesi Ihsan Dogramacı Bulvarı Gumus Blok NO:29 B K1-1 ODTU TEKNOKENT Cankaya\Ankara TURKEY