Last modified: 08/02/2022
Effective date: 13/07/2020
2. Data We Collect
In order for us to provide you with the best possible experience when you use our Services, we need to collect and process certain data. Depending on your use of the Services, this may include:
1. Data you provide to us
For example, we collect your Personal Data, which may include but is not limited to your name, email address, login password, contact number, mailing address, birthdate, photos or videos of you, messages, government identification number and any other information relating to you which you may provide to us when you:
- create or update a user account or profile in our Services;
- create or share content in our Services;
- communicate in our Services;
- send us feedback, questions or comments, or report a problem;
- interact with our social media pages;
- participate in events or contests organized by us;
- provide us demographic data through surveys.
2. Data collected when our Services are used
- Location data: We may collect your general location data such as country you are located in, in form of an IP address from your device to provide to you some of the features or serve relevant content to you via our Services. We may use your precise geo-location data only if you have given your consent by enabling your device’s GPS service for the use of our Services.
- Communications data: We collect data while you use our communications features of our Services, including the date and time of the communications and the content of the communications.
- Usage data: We store and monitor how you use and interact with our Services. For example, we collect data about the date and duration of your access, the features, pages and content you viewed, the third-party sites or services from which you visited us, application crashes and issue logs, and other statistics. We process this usage data for statistical purposes, to improve our Services and fix issues, and to recognize and stop any misuse.
- Device data: We collect data about the devices you use to access and use our Services, including the device type, model and serial number, device IP address, screen resolution, language, web browser type, operating system and version, unique device identifier and advertising identifier.
- Transaction data: We collect transaction information including the type of services purchased, the date and time the services provided, amount charged and payment method.
3. Data from other sources
Those may include:
- feedback, reviews and ratings from third-party sources;
- our business partners, such as payment providers;
- publicly available sources;
- marketing services providers.
3. Use of Personal Data
Truffle Technologies uses and processes the data we collect for the following purposes:
1. Provide, maintain and develop our Services
This includes using data to:
- operate and deliver the Services you are using or have requested;
- create and update your user accounts;
- verify your identity;
- process payments for our Services;
- personalize our Services and make recommendations to serve more relevant content to you e.g. based on your previous interaction with content in our Services;
- enable communications features between our users;
- provide support, troubleshoot and resolve problems in our Services;
- maintain and improve the quality and develop our Services e.g. adding new features;
- provide general statistics regarding the use of our Services to monitor and analyze the usage and activity in our Services.
2. Promote safety and security
This includes using data to:
- verify accounts and activity;
- protect the security and safety of our Services and users;
3. Communicate with you
This includes using data to communicate with you through our Services e.g via push notifications, in-app communications features, website notices or other ways such as email to:
- engage with you via our Services;
- inform you about the availability of our Services, security, legal notices, updates and service-related issues;
- inform you of other products or services available from Truffle Technologies and its affiliates;
- provide offers and promotional communications.
You may opt out any time from receiving notifications and promotional communications from us.
4. Ensure legal compliance
This includes using data to:
- investigate or address claims or disputes;
- comply with law and legal, governmental or regulatory requirements.
4. Sharing and Disclosure of Personal Data
1. Sharing in our Services and affiliates
When you use Truffle Technologies’ Services, some of the Services and features require that we share data with other users or at a user’s request. For example:
- Other members of our Services can see your public profile that may include your name, your publicly shared content or other Personal Data you have made available for public. You can control some of the information that you want to be displayed and made available in your profile.
- When you use communications features of our Services, the recipients can see your name, photo of you and the content you send.
- Publicly shared content may be shared or re-shared outside our Services by you or other members and thus become available and can be viewed by everyone outside our Services.
- Feedback, questions or comments, including any Personal Data submitted by the user through public channels e.g. websites or social media pages, may be viewable by the public.
- We may share data with Truffle Technologies’ subsidiaries and affiliates to help us to provide our Services.
2. Sharing via third-party integrations in our Services
If you choose to use third party integrations in our Services e.g. social media login and authentication features, those third parties may need to access and process some of your Personal Data to provide the service. Third party services have their own privacy policies out of our control.
3. Sharing with our service providers and partners
Truffle Technologies does not sell, rent, lease, or release your Personal Data to third parties for commercial purposes. We use trusted partners who carry our various activities and services to help us deliver and improve our Services. They will have access to your information as reasonably necessary to perform these tasks on our behalf. All such third parties are prohibited from using or disclosing your Personal Data except to provide these services to Truffle Technologies, and they are required to maintain the confidentiality and security of your Personal Data. The partners we may share data with include:
- cloud storage and other technical infrastructure providers;
- data security service providers;
- data analytics providers;
- payment processors and facilitators;
- marketing platform providers where our Services are available;
- marketing partners e.g. social media and online marketing services;
- support and customer service providers;
- survey and feedback service providers.
4. Sharing with our advertising partners
Our free applications use advertising that allows us to offer the Services for free. The advertisements are provided by our advertising partners who may collect advertising identifiers (such as the Apple Identifier for Advertising (IDFA) and other Personal Data in order to enable and optimize their advertising, to provide you with ads based in your interests (“personalized advertising”), and to improve and measure the effectiveness of ads.
Advertising partners may place and collect Cookies and other anonymous identifiers to collect information as a result of ad serving on our Services.
Currently our ads are provided by Google’s AdMob. You can find more information on their ads here.
5. Sharing for legal purposes
Truffle Technologies may disclose or share your personal data if required to do so by law or in the good faith / belief that any such action is necessary to:
- comply with any legal requirements or comply with legal process served on Truffle Technologies or the Services;
- protect and defend the rights or property of Truffle Technologies;
- act under exigent circumstances to protect the personal safety of users of our Services, or the general public.
6. Sharing in case of re-organization or sale
We may disclose your personal data to new owners or re-organized entities and their advisors in the event of a business restructure, sale, purchase or joint venture affecting our business.
7. Sharing data with consent
We may share your Personal Data other ways than described above if we notify you and you give your consent to the sharing.
5. Security of Personal Data
Your privacy is very important to us and we take reasonable physical, administrative, and technological safeguards to protect your data from unauthorized access, use, disclosure and against unlawful processing, accidental loss, destruction and damage. For example, we:
- limit the access to the storage containing Personal Data to only authorized personnel or third parties that need the access to provide our Services;
- monitor and test our systems continuously for possible vulnerabilities and attacks;
- use encryption in all our Services as well as secure connections such as SSL and HTTPS where Personal Data is in transit or at rest;
- take encrypted backups of important data to prevent any data loss;
- maintain internal security policies and ensure those are reviewed and enforced by all Truffle Technologies personnel.
However, no security system is impenetrable, and despite such reasonable efforts, we cannot guarantee that your information is completely safe from intrusion.
In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and where appropriate, notify supervisory authorities and those individuals whose information may have been compromised and take other steps in accordance with any applicable laws and regulations.
6. International Transfers of Personal Data
Our Services are global by nature. Thus, your data collected through our Services may be stored, transferred, accessed or processed in another country than your home country, in which Truffle Technologies, our affiliates, or service providers maintain facilities for the purposes of providing to you the Services. Our primary data storage location is currently Singapore.
Countries where we process data may have laws which are different from, and possibly not as protective as, the laws of your home country. When transferring Personal Data outside of your jurisdiction, we take reasonable steps to ensure that the privacy and security of your Personal Data is according to the provisions of this Policy and the requirements of applicable law wherever the data is located.
7. Legal Bases for Processing Personal Data
We only collect and process Personal Data about you where we have legal bases for doing so. These include:
- Your consent: Generally, the processing of your Personal Datais voluntary. For the purposes where your explicit consent is needed to process the data, we only process your Personal Data when you have given consent e.g. to collect your data through voluntary surveys. You may withdraw your consent at any time, which will be effective from the withdrawal.
- Contractual obligations: Some of the purposes mentioned in this Policy to collect data are necessary to allow us to perform our contractual obligations to you e.g. to deliver you the Services you have requested.
- Legitimate interests: We may process your Personal Data if it is necessary for the purposes of the legitimate interests of Truffle Technologies or other parties. For example, we may process data to maintain and improve the security of our Services, including retaining data of users who have engaged in misconduct in our Services, or to improve our Services.
- Legal obligations: We may process or share some data for the purposes to fulfil our legal obligations to comply with applicable laws and regulations.
8. Retention of Personal Data
We will retain your personal data for the duration of your relationship with us, until you delete your account or for as long as needed to provide to you our Services. We may also retain and use some of your Personal Data as necessary and relevant to comply with our legal obligations, to resolve disputes and to enforce our agreements. Where we may retain data for improvement and development of our Services, we take steps to eliminate information that directly identifies you as an individual. We retain data derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created. Afterwards, we will remove your PersonalData from our systems and records or take steps to properly anonymize it so that you can no longer be identified from it.
9. Cookies and Similar Technologies
- Advertising cookies: These types of Cookies may be used to deliver advertisements on some of our Services and measure the performance of these advertisements. These Cookies may also be used to enable third-party advertising networks to deliver personalized ads that may be relevant to you based on your activities or interests, and to deliver non-personalized ads.
You may deactivate or restrict the transmission of Cookies by changing the settings of your web browser. Cookies that are already stored may be deleted at any time from your browser settings. Some mobile device operating systems enable you to choose whether to allow Cookies or share your mobile advertising IDs for advertisers through your mobile device settings. To learn more about Cookies, advertising practices and your choices, you can visit: YourAdChoices or Network Advertising Initiative.
However, please note that if you choose to delete Cookies or refuse to accept them, this could affect the availability and functionality of the Services, e.g. you may not be able to use all of the features of our Services, to store your preferences, and some of our Services might not display properly.
10. Your Rights
You have the following rights to your Personal Data:
- Access data: You have the right to request a copy of the data in electronic format that we possess about you by sending us an email. You have also right to transmit your data to another entity.
- Correct or delete data: In our Services where you possess an account, you can edit or delete any data you do not want us to process anymore including deleting your whole account via profile or account settings of the Services. After making a request to delete your account, your Personal Data will generally stop being visible to others on our Services with immediate effect or within 24 hours. We will permanently delete all the account data of the closed account within 30 days of account deletion request. When you do not possess an account with us, where you can control your own data, you may ask us to correct or delete Personal Data you think is inaccurate or you do not want us to process anymore by sending us an email. To ensure that your personal data that you have provided to Truffle Technologies is accurate and up to date, please let us know any changes in your details such as your email address, name or contact number. We may also ask you to correct information we think is inaccurate.
- Object or restrict use of data: You have the right to ask us not to collect, process, use, or disclose all or some of your Personal Data for any purpose described in this Policy unless we have legal basis e.g. required by applicable law to retain it as defined in this Policy. However, if you do not want us to collect, process or use your Personal Data, we may be unable to provide some of our Services to you.
- Withdraw you consent to use data: When consent is required, you can always withdraw your consent for our Services you have previously given such consent, for example by disabling GPS location sharing, push notifications, camera or microphone in your mobile device settings.
- Opt-out from marketing communications: You can choose whether you wish to receive marketing communications from us. If you receive marketing communications from us and would like to opt out, you can do so by following the directions in such communications.
11. Links to Third Party Websites or Services
Our Services may contain links to third parties’ websites or services e.g. Facebook, LinkedIn and Medium. If you access other websites or services using those links provided, the third parties’ websites or services may collect and use data from you in accordance with their own privacy policies and terms of service. Please note that Truffle Technologies is not responsible for the collection, use, maintenance, sharing, or disclosure of data and information by such third parties or their privacy policies.
Our Services are not intended for and we do not direct them for under the age of 16. Thus, we do not knowingly collect Personal Data about anyone under the age of 16 or knowingly allow such persons to use our Services. If we learn that we have collected Personal Data about a child under the age of 16, we will delete that data as quickly as possible.
If you feel you haven’t received a satisfactory response from us to your concerns, in addition, you have the right to lodge a complaint with the data protection authority in your jurisdiction.