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Privacy Policy

SLOWLY is owned and operated by Slowly Communications Limited. If you have any questions or comments about this Privacy Policy, please contact us at [email protected].

By downloading or using SLOWLY you agree to this Privacy Policy and our Terms of Service.

If you are under the age of 12, you may not download or use SLOWLY. We do not knowingly collect or maintain information from children under age 12. If you are between the ages of 12 and 17, you must get your parent or guardian to read and agree to our Privacy Policy and our Terms of Service.

1. What This Privacy Policy Covers

This Privacy Policy describes how our mobile applications, websites and products collect, store, use, and share your personal information. It also describes how you can control and protect your privacy on our Service.

This Privacy Policy does not apply to the practices of companies that we do not own or control, such as companies that advertise on our Service. For example, companies that advertise on our Service may tag your device or computer with cookies. We do not control these third party cookies and their privacy policies may differ from ours.

2. Controlling and Protecting Your Privacy

Personal Safety:

After getting to know someone online, you may choose to meet him or her in-person. If so, be careful and use common sense. Never meet someone in private for the first time; choose a public place, and take a friend.

Account Settings:

You can change your account settings at any time, including how you share your location information with other users. You should review these settings regularly.

Deleting Your Account:

You can delete your Account at any time by going to the ‘Settings’ page when you are logged in and clicking on the ‘Remove Account’’ link. Your Account will be deactivated immediately but it may take a little while for Your Content (defined below) to be completely removed from the App. We will save your profile information in case you decide to restore your Account (which you can do within 30 days of deactivating your Account). We reserve the right at our sole discretion to terminate or suspend any Account, or make use of any operational, technological, legal or other means available to enforce the Terms (including without limitation blocking specific IP addresses), at any time without liability and without the need to give you prior notice.

Deleting Your Information and Content:

If you are under the age of 18, you can request us to delete your posted information and content. To do so, send an email to [email protected] with the account information, including nickname and login information associated with your SLOWLY account requesting deletion. We make reasonable efforts to comply, but we cannot guarantee we will be able to delete all of your information everywhere from our systems.

Location Information:

We collect your geolocation when you first register with Slowly, if you grant us permission to do so. We do not “track” your location, but we do collect location information from your device or browser when you log in or use Slowly, such as when you visit a particular feature that uses location (such as unlocking location-based stamps). To protect your privacy and security, we do not share your precise location with other users. Your geo-location showed by your account is randomly shifted for protection. We may still use your location (such as for security or advertising purposes) even if you choose not to display it to other users.

Password:

Store your password in a safe place, and do not share it with anyone. If you think someone has your password, you should change it immediately.

Posting Information:

Posting personal information on your public profile on SLOWLY, including About Me, Birthday and Last Online etc.will make it publicly available. The letters you send to your pen friends may in turn be shared by them with others. Do not post or send information that you want to keep private.

Third Parties:

We are not responsible for (and don’t have any control over) the privacy policies of third party websites, apps and ad servers. We encourage you to read the privacy policies of each and every website and app you visit.

Opting Out of Receiving Cookies:

You may set your browser to block some or all cookies. However, our Service might not fully function if you disable cookies. If you use multiple devices, browsers or computers, you will need to opt out of receiving cookies on each one. Also, if you change devices or computers you will need to repeat this opt-out process. You may also be able to opt-out of receiving cookies from some advertisers. Many Internet browsers automatically accept cookies. You can instruct your browser, by editing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. You may click on the following links: http://www.networkadvertising.org/choices/ and http://www.aboutads.info/choices/ for information on how to opt-out of the use of cookies or Web beacons. You may also be able to opt-out of receiving cookies through the Digital Advertising Alliance in the USA, the Digital Advertising Alliance of Canada in Canada, or the European Interactive Digital Advertising Alliance in Europe.

Limit Mobile Ad Tracking:

You may set your mobile device to limit ad tracking, in which case we will not be able to see your AdID or IDFA. However, we will still share other personal information to our advertising partners as described in this Privacy Policy.

Do Not Track Signals:

Some Internet browsers include the ability to transmit “Do Not Track” signals, but there are no uniform standards for this. We do not process or respond to “Do Not Track” signals.

3. Information We Collect

We collect different types of personal information about you and your activities. We collect personal information when you register, log into, and use our Service, including the features you use, the pages and screens you visit, and the information you enter, such as birthday or demographic information that you share in your profile on our Service. The specific examples in the following bullets are not meant to be exhaustive.

Email Address And Phone Number:

We may require a valid email address or phone number to register for our Service. These email and phone number will be stored in our servers while you have an account with our Services. We will use this email address to contact you, but you may opt out of promotional email contact inside our email. We may use your phone number to verify your account, but will generally not otherwise contact you by phone.

Profile Information You Provide:

We collect the personal information that you provide to create your profile on our Service, including gender, age, date of birth, interested topics and current location.

Automatically Collected Device Information:

We receive and record information from your device or browser, including your mobile device identification (AdID (Google), IDFA (Apple), device ID, etc.), IP address, cookie and beacon information, and geographic location. We collect information from and about the computers, phones, and other web-connected devices you use that integrate with our Services, and we combine this information across different devices you use. Unless you have disabled location collection at the device level, we will continue to collect location information even if you have opted out of sharing location information on your profile.

Activity and Usage Information:

We collect information about the features you use, the pages and screens you visit, and your transactions with us and with our partners and vendors, including information about your use of products or features offered through our Service.

Third Party Platform Registration (e.g. Facebook, App Store, Google Play):

When you download or register for our Service by or through a third party platform, we may also access and/or collect certain information from your third party platform account. For example, if you create your account on our Service using Facebook, we may use your user ID from Facebook to establish your account. In addition, in the course of providing our Service on third party platforms, such as Apple App Store or Google Play Store, the platforms may collect information about you or receive information from us in order for that platform to provide and analyze their services. Please note that these platforms are developed and administered by people or companies not affiliated with us or any of our Services and that we are not responsible for the actions of those people or companies. You should carefully review the terms of service and privacy policies of the platforms that you use to access our Service.

Advertisers

Third party advertising companies may collect information using cookies, AdID, IDFA and other sources. Advertisers may use these and other sources in connection with our Service in order to collect and use data regarding advertisement performance and your interests for the purpose of delivering relevant advertising.

4. How We Use and Disclose the Information We Collect

We process personal information:

  • to execute transactions that you request;
  • when you provide your explicit consent;
  • for our legitimate business interests such as maintaining our books and records, securing and protecting the integrity of our Service, and for Service development; and
  • to meet applicable legal requirements.

Specifically, we use and disclose your information in the following ways:

To customize your experience:

It includes suggestions about features you may enjoy or people you may want to meet.

To provide customer service:

We use your information in response to questions or concerns you may bring to our attention.

For advertising purposes:

We share information with companies we do not own, including information collected from cookies and across the devices used to access the Service, such as your location, IP address, AdID or IDFA and certain demographic information, in order to allow these companies to deliver relevant ads.

For research:

To conduct research, including the numbers and types of visitors, and analyze traffic on our Service. We share some user data with companies we do not own to conduct this research.

For development and testing:

To develop and test new products and features, and improve our current ones, including by conducting surveys of our users, which might be conducted with or by companies we do not own.

Bug fixes and product improvement:

To find and fix technology problems. We send data to companies we do not own in order to analyze bugs in our websites and apps so that we can keep them running smoothly.

Policy enforcement:

To enforce our Privacy Policy and Terms of Service. We send data to companies we do not own for the following reasons:

  • To verify accounts and activity;
  • Combat harmful conduct, such as abusive behavior and other violations of our TOS;
  • Detect and prevent spam;
  • Detect and prevent fraud;
  • Maintain the integrity of our Service; and
  • Promote safety and security on our Service, such as monitoring for illegal activity and reporting to the appropriate authorities.

Contacting you:

To contact you, including to invite you to participate in surveys and contests, and provide you updates and information about the Service and our other products and services.

Cookies and mobile ad identification:

We may set and access cookies or use AdID or IDFA information on your device or computer to customize your experience. These files help us with the following:

  • Authentication: Cookies are used to keep you logged into our site as you navigate through different pages;
  • Analytics and performance: We use cookies to analyze platform performance and monitor how our visitors use the site. These help us to identify and fix bugs, understand and improve our services, and research and test new features.
  • Advertising: We use cookies and your AdID and IDFA to deliver relevant. Our ad partners use cookies to deliver relevant ads and monitor how you interacted with an ad.

Cooperation with law enforcement:

We cooperate with government and law enforcement officials to enforce and comply with the law. We report threats of violence or self-harm and other illegal activities proactively, and we may disclose information about you to government or law enforcement officials in order to:

  • protect the safety and security of our users and members of the public; or
  • satisfy subpoenas, court orders, or other governmental requests.

Business transfers:

We may share your personal information with another business entity in connection with a proposed or actual sale, assignment, merger or transfer of all or part of our business or the acquisition of all or part of another business. In such cases, we would require any such business entity to honor the terms of this Privacy Policy.

Management of our company:

We will process your information as needed to maintain our financial books and records, engage in sales of goods and services to members and advertisers, ensure the integrity and security of our systems and resources, operate our work environment, and respond to any potential compromise of anyone’s personal information.

Service providers:

We transfer information to vendors, service providers, and other partners who support our business, such as providing technical infrastructure services, analyzing how our services are used, measuring the effectiveness of ads and services, providing customer service, facilitating payments, or conducting research and surveys. These partners agree to adhere to confidentiality obligations consistent with this Privacy Policy and the agreements we enter into with them.

Advertisers:

We may share information with third parties for the purposes of delivering relevant, personalized advertisements or content on our Service and on the websites or applications of third parties. To achieve this purpose, our partners may use the shared information:

  • to evaluate the nature of the connection across your devices, browsers, or applications;
  • to assess the suitability of your desktop or mobile device for interest- or demographic-based content;
  • to provide information and inferences about user interests to third parties; and
  • to develop insights and reports relating to the presentation of customized advertisements or content, including statistical reports in connection with activity on a website, optimization of ad placement and performance, development of reach and frequency metrics, billing activities, and tracking ads served on a particular day to a particular account. Our partners may also combine shared information with additional non-identifying information collected from other sources to enhance these activities.

Personal Information:

Except for “Cooperation with Law Enforcement,” “Business Transfers” and “Service Providers” (all described above), in connection with account verification (and then only for that purpose), or to enforce our rights under this Privacy Policy and our Terms of Service, we do not share the following personal information with any third party not owned by Slowly Communications Limited for any reason: your exact date of birth, your first name, your last name, your address, your phone number(s), or your email address.

5. Data Security and Storage

We use industry standard security measures to prevent the loss, misuse and alteration of the information under our control. However, we cannot guarantee that our security measures will prevent “hackers” from illegally obtaining this information. We will store and maintain your personal information for as long as necessary:

  • for the purposes for which it was collected;
  • to meet our current and future legal obligations, including compliance with our records retention practices; and
  • as permitted to meet our legitimate interests.

6. Access to Your Personal Information

If you wish to obtain a copy of your personal information, please contact [email protected]. In order to protect the data of others, requests will only be honored that come from the email used to set up your account on our Service.

7. Deletion of Your Personal Information

You may delete your account at any time, and your personal information will be deleted in the normal course of business pursuant to our current data retention practices. You may request to have all your personal information deleted by contacting [email protected]. We will comply with all deletion requests to the extent permissible by law and will not delete data that we are legally required to maintain (such as data subject to a current and valid preservation order or transaction data required for audit or substantiation purposes).

8. California Resident Rights

  • California Privacy Rights. California Civil Code Section 1798.83 permits our users who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us by email at [email protected]. Please be advised that we are only required to respond to one request per user each year.
  • Our California Do Not Track Notice. We do not currently respond or take any action with respect to web browser “do not track” signals or other mechanisms that provide users the ability to exercise choice regarding the collection of personal information about that user’s online activities over time and across third-party websites or online services. We may allow third parties, such as companies that provide us with analytics tools, to collect personal information about your online activities over time and across different apps or websites when you use our Service.
  • Deletion of Content from California Residents. If you are a California resident under the age of 18 and a registered user of the Service, California Business and Professions Code Section 22581 permits you to remove content or information you have publicly posted. If you wish to remove such content or information and you specify which content or information you wish to be removed, please contact us at [email protected] and we will do so in accordance with applicable law. Please be aware that after removal you will not be able to restore removed content or information. In addition, such removal does not ensure complete or comprehensive removal of the content or information you have posted and there may be circumstances in which the law does not require or allow us to enable removal of the content or information.

9. European Economic Area Residents

If you are a resident of the European Economic Area, you have the following data protection rights:

  • If you wish to access, correct, update or request deletion, restrict processing, object to processing, or request porting of your personal information, you can do so at any time by contacting us at [email protected].
  • You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing emails we send you.
  • Similarly, if we have collected and processed your personal information with your consent (such as for advertising), then you can withdraw your consent at any time by contacting us at [email protected]. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent. Please note that if you opt-out of having your data shared with advertisers, you will still see ads, they just will not be tailored to your interests.
  • You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. Notwithstanding the foregoing, we reserve the right to keep any information in our archives that we deem necessary to comply with our legal obligations, resolve disputes and enforce our agreements.

10. Changes to this Privacy Policy

We may revise this Privacy Policy from time to time to reflect new or changed features and services, changes in the law, or changes in our use or collection of personal information. If you object to any terms and conditions of the Privacy Policy or any subsequent changes or you become dissatisfied with our Service in any way, your only option is to delete your account. Your continued use of our Service after we post a revised Privacy Policy means that you agree to the revisions.

11. Language

This Privacy Policy was written in English. If you are reading a translation and it conflicts with the English version, please note that the English version controls.

12. Our Contact Information

If you have questions regarding these Privacy Policy, please contact us.
Web: https://help.slowly.app
Email: [email protected]

Updated as of September 13, 2019


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