Defy or Walfin Tech Private Limited
(“us“, “we“ or “Company“)
respect the privacy of our users (each, “you”
or “User“) and are committed to
protect the privacy of Users who access, download, install or register to our
mobile application (the “Application“),
our website or any other online services we provide (collectively: the “Services“). The Company has papered
this Privacy Policy to outline our practices with respect to collecting, using and disclosing your information when you use the
Services. We encourage you to read the Privacy Policy carefully and use it to
make informed decisions. By using the Services, you agree to the terms of this
Privacy Policy and your continued use of the Services constitutes your ongoing
agreement to the Privacy Policy. The Privacy Policy is a part of the Terms of
Service and is incorporated there in by reference. In this Privacy Policy you
will read about, among other things:
●
What type of
information we collect
●
Cookies and
Google Analytics
●
How we use the
information
●
With whom we
share the information and for what purpose
●
For how long we
retain the information
●
How we protect
your information
●
Advertisements
●
Advertising ID
and Advertising Identifier
●
How to contact
us
We may collect two types of data and
information from our Users. The first type of information is un-identified and
non-identifiable information pertaining to you, which may be made available or
gathered via your use of the Services (“Non-personal
Information“.We are not aware of the identity
from which the Non-personal Information is collected. Non-personal Information
which is collected may include your aggregated usage information and technical
information transmitted by your device, including certain software and hardware
information about your device (e.g., the device you use, the type of browser
and operating system your device uses, language preference, access time and the
website’s domain name from which you linked to the Services, etc.), in order to enhance the functionality of the Services. We
may also collect information about your activity on the Services (e.g., pages
viewed, online browsing, clicks, actions, timestamps, etc.). The second type of
information is individually identifiable information, namely information that
identifies an individual or may with reasonable effort identify an individual
(“Personal Information“. Such information may include:
● Account Information: When you sign-up and register to the Services, you will be asked to provide us certain details about yourself. You may register to the Services through your social network account or directly through the Application or our website (if applicable).
● Registering through social network account: When you register or sign-in to the Services via your social network account (e.g., Facebook, Twitter, etc.), we will have access to basic information from your social network account, such as your full name, home address, email address, birthdate, profile picture, friends list, personal description, as well as any other information you made publicly available on such account or agreed to share with us. At all times, we will abide by the terms, conditions and restrictions of the social network platform.
○ Registering through the Application or our website (if applicable): When you register to the Services through the Application or our website, we may collect from you the following information: full name, email address, home address, hometown, nationality, birthdate, phone number, as well as information required for our compliance with regulatory Know Your Customer requirements, such as passport or other identification number, and any other information you agreed to share with us.
● Voluntarily Information: We may collect information which you provide us voluntarily. For instance, when you respond to communications from us, communicate with us via email or share additional information about yourself through your use of the Services. We may also collect the feedback, suggestions, complaints and reports which you send to us. Please note that we may also collect complaints about you from other Users, which may include your Personal Information.
● Device Information: We may collect Personal Information from your device. Such information may include geolocation data, IP address, unique identifiers (e.g., MAC address and UUID) as well as other information which relates to your activity through the Services.
For the avoidance of doubt, if we combine
Personal Information with Non-personal Information, the combined information
will be treated as Personal Information as long as it
remains combined.
We may use cookies and other technologies or
methods of web and mobile analysis (e.g., pixels, Amplitude, Segment, Google
Analytics, etc.) to gather, store, and track certain information related with
your access to and activity through the Services, including when you visit our
website. A “cookie” is a small piece of information that a website assign to your device while you are viewing a website.
Cookies are very helpful and may be used for various
different purposes. These purposes include, among other things, allowing
you to navigate between pages efficiently, enabling automatic activation of
certain features, remembering your preferences and
making the interaction between you and the Services quicker, easier and
smoother. Our website may use the following types of cookies:
● Session Cookies which are stored only temporarily during a browsing session in order to allow normal use of the system and are deleted from your device when the browser is closed.
● Persistent Cookies which are saved on your device for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to identify who you are for repeated visits (for instance, to allow us to store your preferences for the next sign-in).
● Third-Party Cookies which are set by other online services that run content on the page you view on your browser (for example, by third-party advertising companies who monitor and analyze our website access).
You may remove the cookies by following the
instructions of your device preferences. However, if you choose to disable
cookies, some features of the Services may not operate properly
and your online experience may be limited. We also use a tool called Google
Analytics to collect information about your use of the Services. Google
Analytics collects information such as how often users access the Services,
what pages they visit when they do so, etc. We use the information we get from
Google Analytics only to improve our Services. Google Analytics collects the IP
address assigned to you on the date you visit sites, rather than your name or
other identifying information. We do not combine the information collected through the use of Google Analytics with personally
identifiable information. Google’s ability to use and share information
collected by Google Analytics about your visits to this site is restricted by
the Google
Analytics Terms of Service and the Google
Privacy Policy.
We use and share Personal Information in the
manners described in this Privacy Policy. In addition to the purposes listed
above, the information we collect, which may include your Personal Information,
is used for the following purposes:
● To set up your account and to provide the Services.
● To identify and authenticate your access to the Services.
● To authenticate your identity for the purpose of compliance with regulatory Know Your Customer requirements.
● To send you relevant push notifications, which are based on different activities offered by the Services.
● To communicate with you and to keep you informed of our latest updates and newsletters.
● To market our website, products, and the Services.
● To serve you personalized advertisements when you use the Services.
● To perform a research or to conduct analytics in order to improve and customize the Services to your needs and interests.
● To support and troubleshoot the Services and to respond to your queries.
● To investigate and resolve disputes in connection with your use of the Services.
● To detect and prevent fraudulent and illegal activity or any other type of activity that may jeopardize or negatively affect the integrity of the Services; and
● To investigate violations and enforce our policies, and as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process or respond to a government request.
We do not rent, sell, or share your Personal
Information with third-parties except as described in
this Privacy Policy. We may share Personal Information with the following
recipients: (i) our subsidiaries; (ii) affiliated companies; (iii)
subcontractors and other third-party service providers; (iv) auditors or
advisers of our business processes; and (v) any potential purchasers or
investors in the company. In addition to the purposes listed in this Privacy
Policy, we may share Personal Information with our recipients for any of the
following purposes: (i) storing or processing Personal Information on our
behalf (e.g., cloud computing service providers); (ii) processing such
information to assist us with our business operations; (iii) performing
research, technical diagnostics, personalization and
analytics. We may also disclose Personal Information or any information you
submitted via the Services if we have a good faith belief that disclosure of
such information is helpful or reasonably necessary to: (i) comply with any
applicable law, regulation, legal process or governmental request; (ii) enforce
our policies, including investigations of potential violations thereof; (iii)
investigate, detect, prevent, or take action regarding illegal activities or
other wrongdoing, suspected fraud or security issues; (iv) to establish or
exercise our rights to defend against legal claims; (v) prevent harm to the
rights, property or safety of us, our affiliates, our Users, yourself or any
third-party; (vi) for the purpose of collaborating with law enforcement
agencies; and (vii) in case we find it necessary in order to enforce
intellectual property or other legal rights.
Our policy only addresses the use and
disclosure of information we collect from you. To the extent that you disclose
your information to other parties via the Services (e.g., by clicking on a link
to any other website or location) or via other sites throughout the Internet,
different rules may apply to their use or disclosure of the information you
disclose to them. You acknowledge that we are not responsible for the products,
services, or descriptions of products or services that you receive from third-party
sites or to the content or privacy practices of those sites, and that this
Privacy Policy does not apply to any such third-party products and services.
You are knowingly and voluntarily assuming all risks of using third-party sites
to purchase products and services. You agree that we shall have no liability
whatsoever with respect to such third-party sites and your usage of them.
We respect your privacy rights and therefore
you may contact us at any time and request: (i) to access, delete, change or
update any Personal Information relating to you (for example, if you believe
that your Personal Information is incorrect, you may ask to have it corrected
or deleted); or (ii) that we will cease any further use of your Personal
Information (for example, you may ask that we will stop using or sharing your
Personal Information with third-parties) or that we shall remove your Personal
Information (subject to any other legal obligation that may require us to keep
the information). Please note that unless you instruct us otherwise
we retain the information we collect for as long as needed to provide the
Services and to comply with our legal obligations, resolve disputes and enforce
our agreements. We may rectify, replenish or remove
incomplete or inaccurate information, at any time and at our own discretion. If
you wish to raise a complaint on how we have handled your Personal Information,
please contact us directly at hello@defy.club
If you are not satisfied with our response or believe we are collecting or
processing your Personal Information not in accordance with the laws, you can
complain to the applicable data protection authority. If you want to delete
your information with us, please write us at hello@defy.club
We take great care in implementing and
maintaining the security of the Services and your information. We employ
industry standard procedures and policies to ensure the safety of your
information and prevent unauthorized use of any such information. Although we
take reasonable steps to safeguard information, we cannot be responsible for
the acts of those who gain unauthorized access or abuse the Services, and we
make no warranty, express, implied or otherwise, that
we will prevent such access. If you feel that your privacy was treated not in
accordance with our policy, or if any person attempted to abuse the Services or
acted in an inappropriate manner, please contact us directly at hello@defy.club
We may use a third-party advertising technology
to serve advertisements when you use the Services. This technology uses your
information with regards to your use of the Services to serve advertisements to
you (e.g., by placing third-party cookies on your web browser). We may also use
our third-parties and share with them Users’
information to assist us in evaluating the success of our advertising campaigns
and help us retargeting our Users. You may opt-out of many third-party ad
networks, including those operated by members of the Network Advertising
Initiative (“NAI”) and the Digital Advertising Alliance (“DAA”). For more
information about this practice by NAI and DAA members, and your choices
regarding having this information used by these companies, including how to
opt-out of third-party ad networks operated by NAI and DAA members, please
visit their respective websites: http://optout.networkadvertising.org/#!/ and http://optout.aboutads.info/#!/.
We may share information, including Personal
Information, in the event of a corporate transaction (e.g., sale of a
substantial part of our business, merger, consolidation or asset sale of an
asset or transfer in the operation thereof) of the Company. In the event of the
above, the acquiring company or transferee will assume the rights and
obligations as described in this Privacy Policy.
The Services are not designated to individuals
under the age of 18 If you are under 16 years old, you should not download the
Application, use the Services, or provide any Personal Information to us. We
reserve the right to access and verify any Personal Information collected from
you. In the event that we become aware that an
individual under the age of 16 has shared any information, we will discard such
information. If you have any reason to believe that a minor has shared any
information with us, please contact us at hello@defy.club
The Google Advertising ID is an anonymous identifier,
provided by Google Play services. If your device has an Advertising ID, we may
collect and use it for advertising and user analytics purposes. We may also use
Apple’s Advertising Identifier (IDFA), which is a non-permanent device
identifier provided by Apple, and any information obtained through
the use of the Advertising Identifier, for the purpose of advertising.
By downloading the Application or using the Services you explicitly agree that
we may associate your Advertising ID and your Advertising Identifier with your
applicable persistent device identifier. This will facilitate our ability to
improve your personalized experience. Further, we may use other persistent
identifiers for non-advertising purposes. If your device does not have Advertising
ID or Advertising Identifier respectively, we will use other identifiers.
We may revise this Privacy Policy from time to
time, in our sole discretion, and the most current version will always be
posted on our website or Application (as reflected in the “Last Revised”
heading). In the event of a material change to the Privacy Policy, we will
notify you through the Services or via email, or you may be notified within the
Application. We encourage you to review this Privacy Policy regularly for any
changes. Your continued use of the Services, following the notification of such
amendments, constitutes your acknowledgement and consent of such amendments to
the Privacy Policy and your agreement to be bound by the terms of such
amendments.
If you have any general questions regarding the
Services or the information that we collect about you and how we use it, please
contact us at hello@defy.club