Privacy Policy

What information do we collect?

We collect the content, communications and other information you provide when you use our Services, including when you sign up for an account, create or share content, and message or communicate with others. This can include information in or about the content you provide (like metadata), such as the location of a photo or the date a file was created.

We collect information about the people, Pages, accounts, hashtags and groups you are connected to and how you interact with them across our Products, such as people you communicate with the most or groups you are part of. We also collect contact information if you choose to upload, sync or import it from a device (such as an address book or call log or SMS log history), which we use for things like helping you and others find people you may know and for the other purposes listed below.

Your usage. We collect information about how you use our Products, such as the types of content you view or engage with; the features you use; the actions you take; the people or accounts you interact with; and the time, frequency and duration of your activities. For example, we log when you're using and have last used our Products, and what posts, videos and other content you view on our Products. We also collect information about how you use features .

Information about transactions made on our Services.If you use our Services for purchases or other financial transactions (such as when you make an ad), we collect information about the purchase or transaction. This does not include payment information, such as your credit or debit card number and other card information; other account and authentication information; and billing, shipping and contact details.

Things others do and information they provide about you. We also receive and analyze content, communications and information that other people provide when they use our Products. This can include information about you, such as when others share or comment on a photo of you, send a message to you, or upload, sync or import your contact information.

How do we use personal information?

Describe in detail all the service- and business-related purposes for which you will process data. For example, this may include things like: personalisation of content, business information or user experience account set up and administration delivering marketing and events communication carrying out polls and surveys internal research and development purposes providing goods and services legal obligations (eg prevention of fraud) meeting internal audit requirements

Please note this list is not exhaustive. You will need to record all purposes for which you process personal data.

What legal basis do we have for processing your personal data?

Describe the relevant processing conditions contained within the GDPR. There are six possible legal grounds: consent contract legitimate interests vital interests public task legal obligation

Provide detailed information on all grounds that apply to your processing, and why. If you rely on consent, explain how individuals can withdraw and manage their consent. If you rely on legitimate interests, explain clearly what these are.

If you’re processing special category personal data, you will have to satisfy at least one of the six processing conditions, as well as additional requirements for processing under the GDPR. Provide information on all additional grounds that apply.

When do we share personal data?

Explain that you will treat personal data confidentially and describe the circumstances when you might disclose or share it. Eg, when necessary to provide your services or conduct your business operations, as outlined in your purposes for processing. You should provide information on: how you will share the data what safeguards you will have in place what parties you may share the data with and why

Where do we store and process personal data?

If applicable, explain if you intend to store and process data outside of the data subject’s home country. Outline the steps you will take to ensure the data is processed according to your privacy policy and the applicable law of the country where data is located. If you transfer data outside the European Economic Area, outline the measures you will put in place to provide an appropriate level of data privacy protection. Eg contractual clauses, data transfer agreements, etc.

How do we secure personal data?

Describe your approach to data security and the technologies and procedures you use to protect personal information. For example, these may be measures: to protect data against accidental loss to prevent unauthorised access, use, destruction or disclosure to ensure business continuity and disaster recovery to restrict access to personal information to conduct privacy impact assessments in accordance with the law and your business policies to train staff and contractors on data security to manage third party risks, through use of contracts and security reviews

Please note this list is not exhaustive. You should record all mechanisms you rely on to protect personal data. You should also state if your organisation adheres to certain accepted standards or regulatory requirements.

How long do we keep your personal data for?

Provide specific information on the length of time you will keep the information for in relation to each processing purpose. The GDPR requires you to retain data for no longer than reasonably necessary. Include details of your data or records retention schedules, or link to additional resources where these are published.

If you cannot state a specific period, you need to set out the criteria you will apply to determine how long to keep the data for (eg local laws, contractual obligations, etc)

You should also outline how you securely dispose of data after you no longer need it.

Your rights in relation to personal data

Under the GDPR, you must respect the right of data subjects to access and control their personal data. In your privacy notice, you must outline their rights in respect of: access to personal information correction and deletion withdrawal of consent (if processing data on condition of consent) data portability restriction of processing and objection lodging a complaint with the Information Commissioner’s Office You should explain how individuals can exercise their rights, and how you plan to respond to subject data requests. State if any relevant exemptions may apply and set out any identity verification procedures you may rely on. Include details of the circumstances where data subject rights may be limited, eg if fulfilling the data subject request may expose personal data about another person, or if you’re asked to delete data which you are required to keep by law.

Use of automated decision-making and profiling

Where you use profiling or other automated decision-making, you must disclose this in your privacy policy. In such cases, you must provide details on existence of any automated decision-making, together with information about the logic involved, and the likely significance and consequences of the processing of the individual.