PEERBIE PRIVACY POLICY Introduction Protecting your privacy is of the utmost importance to us. We want to make your online experience satisfying and safe. As we try to maintain a safe environment on the PeerBie platform, please also be vigilant as you would in real life, after all, we are humans, and we have feelings. To carry out our business, PeerBie collects, holds, uses and discloses certain types of personal information about you (as a User of our website or specialized apps), so it’s important to confirm we respect your rights to privacy, and how we do so. When our information handling practices change, we will update this Privacy Policy and publish it on this page. Collection and Storage of Personal Information Why do we collect your personal information? At all times we try only to collect the information we need to carry out the particular functions or business activities you’ve asked us to, while providing the highest quality customer service. Reasons for collecting your personal information may include (but aren’t limited to): providing services or communications; answering enquiries, assessing the performance of the Services, with a view to improving them where required; giving you access to protected areas of the Services; conducting business processing functions, including with related bodies corporate, contract service providers and other third parties; to update our records; to reply to any complaint you may make; and to comply with any Government law, rule, regulation or direction. Your information will not be shared, sold, rented or disclosed other than as described in this Privacy Policy. What personal information do we collect and hold? You provide your mobile phone number to create a PeerBie account. You provide us the phone numbers in your mobile address book on a regular basis, including those of both the users of our Services and your other contacts. You confirm you are authorized to provide us such numbers. You may also add other information to your account, such as a profile name, profile picture, and status message. The personal information we collect and store depends on why you contact us and which PeerBie services you inquire about or want to use. The information may include: your name; mailing or street address; email address; website address; telephone number; fax number; age or date of birth; profession, occupation or job title;, and any additional information required to deliver the Services or reply to your enquires; and any additional personal information you provide us from time to time through the Services, services team or representatives. How do we collect personal information? Direct Collection We usually collect your personal information directly from you. There are several ways we may seek this information, including: through your access and use of the Services; when you complete an online application or form (e.g., “Registration Form” or “Contact Us” forms); during conversations between you and our representatives; through your interaction with us via email; through your interaction with us via our social media channels (which have their own Privacy Policies). Indirect Collection We may also collect personal information indirectly from third parties including: publicly available sources; third-party companies such as law enforcement agencies and other Government entities; our network of partners, and affiliates; or your authorized representative, if you have one. Automatically Collected Information Usage and Log Information We collect service-related, diagnostic, and performance information. This includes information about your activity (such as how you use our Services, how you interact with others using our Services, and the like), log files, and diagnostic, crash, website, and performance logs and reports. Transactional Information If you pay for our Services, we may receive information and confirmations, such as payment receipts, including from app stores or other third parties processing your payment. Device and Connection Information We collect device-specific information when you install, access, or use our Services. This includes information such as hardware model, operating system information, browser information, IP address, mobile network information including phone number, and device identifiers. We collect device location information if you use our location features, such as when you choose to share your location with your contacts, view locations nearby or those others have shared with you, and the like, and for diagnostics and troubleshooting purposes such as if you are having trouble with our app’s location features. Aggregate Information, Cookies, and Other Tracking Technologies Regularly, we may collect general, non-personal, statistical information about the use of PeerBies’s such as tallying page views by users, the length of time they spend on each page and tracking user traffic patterns generally. We collect this information through the use of “cookies” and other tracking technologies. A cookie is a small text file we may place in the browser files of your computer. The cookie itself does not contain personal information (although it will enable us to relate your use of the site to information you’ve specifically and knowingly given). The only personal information a cookie can have is information you submit yourself. A cookie can’t read data off your hard disk or read cookie files created by other sites. We use tracking information to determine which parts of our app users like and don’t like based on traffic to those parts. We don’t track what individual users read, but rather how well each page performs generally. This enables us to enhance the Services for Users and continue building better services for you. We may also group this information into aggregate user data to, for example: analyze trends and track user movements, then present that data to our existing or potential business partners, sponsors, other third parties; or in reply to a Government request. However, we assure you, this aggregate data will not personally identify you or any other Users. Since we don’t track the usage patterns of individual users, an advertiser or sponsor won't know that a particular user clicked their ad. Tracking technologies may record information such as: internet domain and host names; internet protocol (IP) addresses; browser types; and the time and date pages on our Services are accessed. PeerBie does break down overall usage statistics according to a user’s domain name, browser type and MIME type by reading this information from the browser string (information contained in every user’s browser). Disclosure When do we disclose personal information? Your privacy and the protection of your personal information are very important to us. We may share your personal information with associated bodies corporate and our employees who have a “need to know” that information. We may also disclose your personal information to our contracted service providers for the purposes of operating our website or PeerBie’s business (including marketing), fulfilling your requests or otherwise providing our services to you. Our service providers include (but aren’t limited to) website hosting providers, IT system administrators, and professional advisors, e.g., accountants, lawyers, and consultants. We will take reasonable steps to ensure our service providers are required to protect personal information on our behalf. PeerBie never shares personal information with unaffiliated third parties, such as marketing, advertising, sponsors or partners. In the event PeerBie or its assets are sold, it’s likely our customer, and user information (including personal information) will be one of the assets transferred, and by using our Services, you consent to this. We may disclose your personal information to any person or organization for any authorized purpose with your express consent. We reserve the right to use IP addresses and other tracking technologies to identify a user and disclose their personal information only when reasonably necessary to protect our app, users or the public from damage, injury or harm (either intentionally or not); to enforce compliance with our Terms and Conditions, or to comply with the law or valid legal process. Quality of Your Personal Information To ensure the personal information we collect is accurate, up-to-date and complete we: record information in a consistent format; where necessary, confirm the accuracy of information we collect from a third party or public source; promptly add updated or new personal information to existing records; and verify our contact lists to check their accuracy. We also review the quality of personal information before we use or disclose it. Storage and Security The security of your personal information is a high priority for us. We may hold your information in either electronic or hard copy form. We take all reasonable technical and secure physical measures to protect it from accidental or unlawful destruction, misuse, interference and loss, and from unauthorized access, modification or disclosure. Steps include: conducting internal audits to assess whether we have adequately complied with security requirements; imposing physical security measures to prevent unauthorized access to rooms or systems storing personal data; requiring all employees to sign a confidentiality clause as a condition of their employment; and electronic security measures in our system including firewalls and data encryption. Direct Marketing We may send you direct marketing communications and information about our services and special promotions we think you’ll be interested in. Communications may be sent via email, telephone, SMS, mail or any other electronic means. You are free to opt-out of receiving our marketing communications at any time, simply by emailing us or using the opt-out facilities provided in the communications. We’ll ensure your name is removed from our mailing list. Accessing and Correcting Your Personal Information You have the right to ask for access to personal information that we hold about you, and ask that we correct that personal information. You can ask for access or correction by contacting us, and we must respond within 30 days. If you ask, we must give you access to your personal information, and take reasonable steps to correct it if we consider it is incorrect, unless there is a law that allows or requires us not to. We will ask you to verify your identity before we give you access to your information or correct it, and we’ll try to make the process as simple as possible. If we refuse to give you access to, or correct, your personal information, we must notify you in writing setting out the reasons. If we make a correction and we have disclosed the incorrect information to others, you can ask us to tell them about the correction. We must do so unless there is a valid reason not to. If we refuse to correct your personal information, you can ask us to associate with it (for example, attach or link) a statement that you believe the information is incorrect and why. The accuracy and retention of personal information We endeavor to ensure that any Personal Information in our possession is as accurate, current and complete as necessary for the purposes for which we use and/or disclose such Personal Information. If we become aware that your Personal Information in our possession is inaccurate, out-of-date or incomplete, we will endeavor to revise such Personal Information accordingly. We will retain your Personal Information only for so long as it is required for the purposes it was collected or to comply with applicable laws. This period may extend beyond the end of your relationship with us, but it will be only for so long as it is reasonably necessary for us to have sufficient information to respond to any issues that may arise after the end of your relationship with us or as required by applicable laws. When your Personal Information is no longer required, we will destroy, delete or convert it into an anonymous form. Protection of personal information We endeavor to maintain appropriate physical, procedural and technical safeguards with respect to our offices and information storage facilities in order to prevent any loss, misuse, or unauthorized access, disclosure, or modification of Personal Information. We further protect Personal Information by restricting access to Personal Information to those employees, contractors, advisers, affiliates and service providers that the management of PeerBie has determined reasonably require access to such information for any of the purposes stated in this Privacy Policy. Despite these efforts, please note that no data transmission or storage efforts can be guaranteed to be 100% secure. As a result, we cannot guarantee or warrant the security of any information you disclose or transmit to us. PLEASE NOTE: Some or all of your Personal Information that we collect may be stored or processed on servers located in the United States of America and in other areas outside your jurisdiction of residence, whose data protection laws may differ from the jurisdiction in which you live. As a result, this information may be subject to disclosure to governments, courts, or law enforcement agencies in those jurisdictions according to the laws in those jurisdictions and without notice to us or you. Subject to applicable laws in such other jurisdictions, we will use reasonable efforts to ensure that appropriate protections are in place to require the data processor in that jurisdiction to maintain protections of your Personal Information that are equivalent to those that apply in the jurisdictions in which you live. Third party websites and services The Sites or Services may provide access to websites or services owned and operated by third parties. Our Sites and Services also enable you to integrate and connect your PeerBie account to third-party services. These third-party websites and services may have their own privacy policies and are not governed by this Privacy Policy. Furthermore, when you connect a third party service to your PeerBie account, those connections may allow the third party to collect or share data about you. We are not responsible for the privacy practices or the content of any third party websites or services. Third party websites and services may collect, use and disclose Personal Information differently than us, so we encourage you to carefully read and review the privacy policy for each third party website and service that you access or use. General data protection regulation (“gdpr”) PeerBie is committed to protecting our customer’s data in compliance with GDPR. If you are situated in the European Union or European Economic Community, this section applies to our collection, use and disclosure of your personal data and describes additional rights you have under applicable law. If you have any complaints regarding our privacy practices, you have the right to make a complaint at any time to your local supervisory authority. We would, however, appreciate the chance to deal with your concerns before you approach your supervisory authority so please contact us in the first instance. Furthermore, in addition to your right to withdraw consent, and the rights to access, correction, and deletion as set forth in this Privacy Policy, you also have the right (subject to applicable law) to object to and/or request restriction of the processing of your personal data, and to obtain a copy of your personal data. If you would like to exercise any of your rights under GDPR, you can contact our Privacy Officer at the email address set forth below. Please note that in order for you to assert these rights, we may need to verify your identity to confirm your right to access your personal data. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. In order to verify your identity, we may need to gather more personal data from you than we currently have. Changes to the Policy We retain the right, based on our sole discretion, to modify, change, add or remove sections of this privacy policy at any time. Any changes should be notified to you via the email address you have provided to us or via the app. Your continued use of the Services, after the posting of such changes to this privacy policy, will be considered as your acceptance of these changes.