mobifriends - Legal information

Privacy Policy for mobifriends
Effective May 25, 2018

1. Introduction

Identification of the person responsible:
Mobifriends Solutions, S.L. C/Escorial 180, Bajos exterior, 08024 Barcelona. Spain.

Data protection delegate:
Elsa Carreras Ruiz Collegiate Lawyer 27223 ICAB
[email protected]

Thanks for choosing mobifriends!
At mobifriends we want to offer you the best experience possible when using our services and thus guarantee that you will enjoy them today, tomorrow and in the future. For this, we need to collect your personal data, in order to make your profile to allows us to connect with the people who are looking for someone as special and unique as you. Without these data this would be impossible. That said, the privacy and security of all your personal data are, and always have been, of great importance to us.

For this reason, we want to explain in a simple, clear and transparent way how and why we collect, store and use your personal data, in addition to showing you the controls you have on them.

Thus, the objective of this Privacy Policy is:

1. Ensure that you understand what personal information we collect about you and the reasons why we do it;
2. Explain the way in which we use the personal information you share with us in order to offer you the best experience when you use the service; And
3. Explain your rights and options in relation to the personal data we collect and process about you;
4. And how we protect your privacy.

We hope this helps you understand our commitment to your privacy. Likewise, if you do not agree with the content of this Policy, remember that you always decide if you want to use the service.

2. Where this privacy policy applies.

This Privacy Policy applies to the websites, applications, events and other services offered by mobifriends. We refer to all of these as our "services". 3. How do we collect your personal data?

We collect your personal data in the following ways:
1. By registering on mobifriends: when you register with mobifriends we collect certain personal information so you can use the mobifriends Service, such as your email address, date of birth and gender.
2. When you complete your profile: when you complete your profile, you share with us additional information, such as your physical details, the details of your personality, lifestyle, hobbies, interests, etc .; also content like your photography and videos.
3. Through the use of the free service: when you use the platform of mobifriends, we collect personal information about the use you make of the service, such as which profiles you have visited, with whom you have contacted, as well as your chats with other users or the content you publish.
4. When you subscribe to a paid service: in order to process the payment with our payment service provider, we collect information such as your debit or credit card number or paypal account. 4. What personal data do we collect?

Personal information collected when you register on mobifriends or complete your personal information.

These are the personal information you provide to us to register and use mobifriends Service. Your name or alias is included, date of birth, province and city, sex, email address.

Additionally, when you complete your profile, you provide us and we collect other personal information about your physical characteristics, aspects of your personality, hobbies and interests and your preferences for searching for people.

Other data that you can provide us when filling in your profile are data considered by the legislation "specially protected" such as sexual orientation, "ethnic origin" or "religion". By accepting the general terms and conditions of use, the User provides his/her express consent to mobifriends in order to process this information.

Personal information collected through use of mobifriends

When you use our services, we collect information:

About your activity in our services; for example, how you use them (eg the date and time you start the session, the features you use, your searches, the clicks and the pages that were shown to you, the addresses of the reference websites, and how you interact with other users (eg with which users you interact, the date and time of your exchanges, the number of messages you send and receive)).

About your communications data (messaging and chat). They will be treated in order to be able to offer the internal messaging service between registered users. Likewise, the chat conversation data will also be processed. This data will be kept for a period of one year, in order to be able to access this data in case of a serious incident such as a complaint by a User that is threatened or attacked in any way. In the case of conservation of chat data, the data of the videos will not be included if the chat is done through this medium.
The conservation periods will be counted by years and calendar months. Mobifriends will delete the month of January all information related to internal messages and chat conversations held during the year preceding the previous one.

About devices you use to access our services (eg information about hardware and software such as IP address, device identification and type, device specific characteristics and preferences and application failures, advertising identifiers (such as Google's AAID, Apple's IDFA or DAA of Digital Advertising Alliance, which are randomly generated numbers you can reset in 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, IMEI/UDID and MAC address).

If you prefer not to be a part of Mobifriends' digital marketing campaigns with advertisements, you can exercise your choice of opting out using the tool provided by the DAA or Digital Advertising Alliance in this link here.

Personal information collected in the «VIP» service or «credit purchase»

When you subscribe to a payment service, in order to process the payment with our payment service provider, we collect information about your debit or credit card (name of the cardholder, number, expiration date and security code) or paypal account .

5. What do we use your personal information for?

1. To be able to offer you our service and connect with other users.
One of the most important aspects of the service is precisely the collection and processing of personal data of users so that when you perform a search for other users you will be shown the users who have a more compatible profile with you. Therefore, the more data you enter, and the more consistent these are with reality, the greater the possibility that the results we offer you in the searches are relevant to you.
Given that the essential purpose of entering the data in your profile is that other users can see them, it is inevitable that these other users access to said data through the platforms of the subject. In addition to communicating the data to registered Users who perform the searches, access will also be given to unregistered Users. However, the data that will be offered to non-registered Users when they perform a search will be a summary of the profile data. The data considered by the legislation "specially protected" as the "racial origin" or the "religion" will not be offered in the summary searches that will be shown to the unregistered Users.
2. Communicative purposes.
Likewise, we treat your data in order to offer you the internal messaging service between registered Users. We also treat the chat conversation data.
3. Provide customer service and respond to your requests.
4. Complete your transactions.
5. Communicate with you about our services, including order management and billing.
6. Communicate with you via email, telephone, social networks or mobile devices about the products and services that we believe may interest you.
7. Manage sweepstakes, contests, discounts or other offers.
8. Analyze the behavior of users to improve our services and content or develop new features and services.
9. To carry out analysis of bad behaviors in violation of the general conditions of use.
10. Comply with legal requirements.
11. Assist the police or judicial authorities. 6. Conservation of information

We keep your personal information only during the time necessary to provide the service to you.

Additionally, to safeguard the safety and protection of our users inside and outside of our services, we have implemented a one year security retention period, after the account deletion. In the case of conservation of chat data, the data of the videos will not be included if the chat is done through this medium. During this period the account information will be retained even though, obviously, the account will no longer be visible in the services.

If you request, we may delete or anonymize your personal data so that it is not identified, unless, legally, we can or are required to keep certain personal data, including the following cases:

If there is an unresolved problem related to your account, such as a pending credit in your account or an unresolved claim or dispute, we will retain the necessary personal information until the problem is resolved;
When we are obliged to retain personal data to comply with our legal, fiscal, accounting and auditing obligations, we will retain the necessary personal data during the period required by applicable law; and/or,
When necessary for our legitimate commercial interests, such as the prevention of fraud or maintaining the safety of our users.

7. Legal basis for the treatment of your personal data

To treat your information we use the following legal bases:

Fulfill our service contract: Most of the time, the reason we treat your information is in compliance with the contract we have with you to offer you meaningful relationships.

Legitimate interests: we also use your information when we have legitimate interests, such as, for example, analyzing the behavior of users about our services in order to improve our offers, suggesting offers that we think may interest you, and treating information for administrative issues, fraud detection and other lawful purposes.

Consent: From time to time, we may ask for your consent to use your information for specific reasons. You may withdraw your consent at any time if you write to us at the address provided at the end of this Privacy Policy.

8. Sharing of your personal data.

With other users. Since our goal is to help you create meaningful relationships, it is clear that user information is shared with other users. Please be careful with your information and make sure that the content you share is material that you do not care that is publicly seen.
With our service providers. We use third parties to help us with our services. These third parties assist us in various tasks, such as hosting and maintaining data, analytics, customer service and payment processing.
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, divestment, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control.
Collaboration with authorities. To comply with a legal process, such as a court order, subpoena or search warrant, government / police investigation or other legal requirement; assist in the prevention or detection of a crime; or to protect the safety of anyone.

9. Your rights.

The new General Regulation of Data Protection (GDPR for its acronym in English) gives people certain rights related to their personal data. Therefore, with this new privacy policy we inform you in detail and with the greatest transparency of your rights and how to exercise them.

These are your rights in relation to your personal data:

Right of access: the right to be informed and request access to personal data that we process about you;
Right of rectification: the right to request that we correct or update your personal data, when they are inaccurate or incomplete;
Right to delete: the right to request that your personal data be deleted;
Right to restrict: the right to request that the processing be stopped temporarily or permanently of all or some of your personal data;
Right to object:

the processing of your personal data for reasons related to your particular situation;
to have your personal data processed for direct marketing purposes;

Right to data portability: the right to request a copy of your personal data in electronic format and the right to transmit said data for use in the service of a third party; and
The right not to be subject to automated decision making: the right not to be subject to decisions that are based solely on automated decision making, including the creation of profiles, when the decision may have a legal effect on you or produce a similar important effect.

10. How to exercise them.

If you want to exercise any of these rights related to your personal data you can do so using the "Contact us" form or by postal mail to:
Mobifriends Solutions, S.L.
C/Escorial 180, Bajos exterior, 08024 Barcelona. Spain. 11. Security measures.

MF, in accordance with current legislation on data protection, undertakes to adopt those technical and organizational measures necessary to ensure the security of personal data and avoid their alteration, loss, or unauthorized access, taking into account the state of the technology, the nature of the stored data and the risks to which they are exposed, whether they come from human action or from the physical or natural environment.

All the team of mobifriends who can access the personal data of the Users scrupulously respects the duty of professional secrecy imposed by the legislation regarding this information.

In addition, in the event that mobifriends should subcontract the services of third parties in order to be able to provide her services, it guarantees its Users that it will include clauses relating to the duties that these third parties must comply with in order to guarantee the confidentiality of the personal data of the Users, as established by legislation.

Online payments are protected by the https protocol in order to guarantee the encryption of the data when transmitting them to the bank and during its processing by the latter.

Mobifriends also wants to alert Users that despite adopting all security measures legally established security on the Internet and electronic communications networks is vulnerable, which is why it is recommended that the User also maintain high levels of security in the devices of access to the platform As an example, it is recommended to keep an antivirus program active and updated to protect against possible attacks on the User's system, the use of firewalls and antispam filters, as well as the use of strong and secure passwords, which are not easy to deduce, and not use the same password for different Internet services.

12. 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 a minor. If you suspect that a user is under 18, please use the complaint mechanism available in our service.
13. Changes to the privacy policy

Occasionally, we may make changes to this Privacy Policy.
If we make material changes to this Privacy Policy, we will provide you with a prominent notice in accordance with the circumstances, for example, by displaying a prominent notice in the Online Service or sending you an email. We can notify you in advance.

Therefore, be sure to read any notice carefully.

14. How to contact us

Thank you for reading our Privacy Policy. If you have any questions about this Policy, you can contact us using the "Contact Us" form or by writing to the following address:
Mobifriends Solutions, S.L.
C/Escorial 180, Bajos exterior, 08024 Barcelona. Spain.

We hope you enjoy mobifriends!

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