Welcome to our inSync App. This policy applies to you and us Insync Corporation Ltd, of 20-22 Wenlock Road, London, England, N1 7GU, irrespective of your country of residence or location. The terms (“us,” “we” “Insync ”) refer to us Insync Corporation Ltd.
This Policy describes our privacy practices in plain language, keeping legal and technical jargon to a minimum to make sure you understand the information we collect, why we collect it, how it is used and your choices regarding your information.
Who We Are
Insync Corporation Ltd
20-22 Wenlock Road, London,
England, N1 7GU, UK
If you live in the European Economic Area, Regulation (EU) 2016/679 (General Data Protection Regulation) is the European Regulation and in the UK, it is the Data Protection Act 2018.
The Supervisory Authority
The Information Commissioner’s Office (ICO) in the UK is the for us relevant authority in matters of data protection. You have the right to make a complaint at any time to the ICO (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
What are the relevant legal bases for processing your data?
In accordance with Art. 13 GDPR the following informs you about the legal basis of us processing your data and unless the legal basis is not specifically mentioned, the following applies:
Consent – This is where we have asked you to provide explicit permission to process your data for a particular purpose. (Art. 6 Para. 1 lit. a and Art. 7 GDPR)
Contract – This is where we process your information to fulfil a contractual arrangement we have made with you. (Art. 6 Para. 1 lit. b GDPR)
Answering your business enquiries – This is where we process your information to reply to your messages, e-mails, posts, calls, etc. (Art. 6 Para. 1 lit. b GDPR)
Legitimate Interests – This is where we rely on our interests as a reason for processing, generally this is to provide you with the best products and service in the most secure and appropriate way. (Art. 6 Para. 1 lit. f GDPR). Of course, before relying on any of those legitimate interests we balance them against your interests and make sure they are compelling enough and will not cause any unwarranted harm.
Legal Obligation – This is where we have a statutory or other legal obligation to process the information, such as for the investigation of crime. (Art. 6 Para. 1 lit. b GDPR)
Vital interests – This is where we process your information for communications about security, privacy and performance improvements of our services. Or for establishing, exercising or defending our legal rights. (Art. 6 para. 1 lit. d GDPR)
Data Subject Rights
You have a number of ‘Data Subject Rights’ below is some information on what they are and how you can exercise them. There is more information on each right on the Information Commissioners (ICO) website and you can simply follow the links provided to learn more.
- The right of access
- The right to rectification
- The right to erasure
- The right to restrict processing
- The right to data portability
Where the processing of your personal information is based on consent, you have the right to withdraw that consent without detriment at any time by contacting us.
The above rights may be limited in some circumstances, for example, if fulfilling your request would reveal personal information about another person, if you ask us to delete information which we are required to have by law, or if we have compelling legitimate interests to keep it. We will let you know if that is the case and will then only use your information for these purposes. You may also be unable to continue using our services if you want us to stop processing your personal information.
We encourage you to get in touch if you have any concerns with how we collect or use your personal information. You do however also have the right to lodge a complaint directly with the ICO, their contact details can be found on their website.
Please direct all requests for information, requests for information or objections to data processing to us.
Information We Collect
To help you making meaningful connections, we collect basic profile details about you, such as your name, username, email, date of birth (all other data is voluntarily submitted)
We also collect information generated as you use our services, for example access logs, as well as information from third parties, like when you access our services through a social media account. If you want additional info, we go into more detail below.
Information you give us
You choose to give us certain information when using our services. This includes:
When you create an account, you provide us with at least your login credentials, as well as some basic details necessary for the service to work, such as your picture, date of birth and list your name.
When you complete your profile, you can share with us additional information, as well as content such as photos and text. Some of the information you choose to provide us may be considered “special” or “sensitive” in certain jurisdictions, for example your racial or ethnic origins, sexual orientation and religious beliefs. By choosing to provide this information, you consent to our processing of that information.
When you log in or sign up with your Social Media account we will receive certain information that is linked to your profile. Those details depend on your specific profile but may include your name, email address, friends list, profile picture. We do not control, and are not responsible for it and in no case will share the information received from your social media profile with third parties.
If you contact our customer care team, we collect the information you give us during the interaction. Sometimes, we monitor or record these interactions for training purposes and to ensure a high quality of service.
If you ask us to communicate with or otherwise process information of other people (for example, if you ask us to send an email on your behalf to one of your friends), we collect the information about others that you give us in order to complete your request.
Of course, we also process your chats with other users as well as the content you publish, as part of the operation of the services.
Information we receive from others
In addition to the information you provide us directly, we receive information about you from others, including:
Other users may provide information about you as they use our services. For instance, we may collect information about you from other users if they contact us about you.
We collect information about your activity on our services, for instance how you use them (e.g., date and time you logged in, features you’ve been using, searches, clicks and pages which have been shown to you, referring webpage address, advertising that you click on) and how you interact with other users (e.g., users you connect and interact with, time and date of your exchanges, number of messages you send and receive).
We collect information from and about the device(s) you use to access our services, including:
hardware and software information such as IP address, device ID and type, device-specific and apps settings and characteristics, app crashes, advertising IDs (such as Google’s AAID and Apple’s IDFA, both of which are randomly generated numbers that you can reset by going into your device’ settings), browser type, version and language, operating system, time zones, identifiers associated with cookies or other technologies that may uniquely identify your device or browser (e.g., IMEI/UDID and MAC address);
information on your wireless and mobile network connection, like your service provider and signal strength; information on device sensors such as accelerometers, gyroscopes and compasses.
How We Use Information
The main reason we use your information is to deliver and improve our services. Additionally, we use your info to help keep you safe and to provide you with advertising that may be of interest to you. Read on for a more detailed explanation of the various reasons we use your information, together with practical examples.
- To administer your account and provide our services to you
- Create and manage your account
- Provide you with customer support and respond to your requests
- Complete your transactions
- Communicate with you about our services
- To help you connect with other users
- Analyse your profile, activity on the service
- Show users’ profiles to one another
- Register you and display your profile on new features
- Communicate with you
- To improve our services and develop new ones
- Conduct research and analysis of users’ behaviour to improve our services and content (for instance, we may decide to change the look and feel or even substantially modify a given feature based on users’ behaviour)
- Develop new features and services
- To prevent, detect and fight fraud or other illegal or unauthorized activities
- Address ongoing or alleged misbehaviour
- Perform data analysis to better understand and design countermeasures against these activities
- Retain data related to fraudulent activities to prevent against recurrences
- To ensure legal compliance
- Comply with legal requirements
- Assist law enforcement
- Enforce or exercise our rights, for example our Terms
To process your information as described above, we rely on the following legal bases:
Provide our service to you
Most of the time, the reason we process your information is to perform the contract that you have with us. For instance, as you go about using our service to build meaningful connections, we use your information to maintain your account and your profile, to make it viewable to other users and recommend other users to you.
We may use your information where we have legitimate interests to do so. For instance, we analyse users’ behaviour on our services to continuously improve our offerings, we suggest offers we think might interest you, and we process information for administrative, fraud detection and other legal purposes.
How We Share Information
Our goal is to help you make connections, the main sharing of users’ information is, of course, with other users. We also share some users’ information with service providers and partners who assist us in operating the services, and, in some cases, legal authorities. Read on for more details about how your information is shared with others.
With other users
You share information with other users when you voluntarily disclose information on the service. Please be careful with your information and make sure that the content you share is stuff that you’re comfortable being publicly viewable since neither you nor we can control what others do with your information once you share it.
If you choose to limit the audience for all or part of your profile or for certain content or information about you, then it will be visible according to your settings.
With our service providers and partners
We use third parties to help us operate and improve our services. These third parties assist us with various tasks, including data hosting and maintenance, analytics, customer care, marketing, advertising, payment processing and security operations.
We may also share information with partners who distribute and assist us in advertising our services. For instance, we may share limited information on you in hashed, non-human readable form to advertising partners.
We follow a strict vetting process prior to engaging any service provider or working with any partner. All of our service providers and partners must agree to strict confidentiality obligations.
For corporate transactions
We may transfer your information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control.
When required by law
We may disclose your information if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government / law enforcement investigation or other legal requirements; (ii) to assist in the prevention or detection of crime (subject in each case to applicable law); or (iii) to protect the safety of any person.
To enforce legal rights
We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.
With your consent or at your request
We may ask for your consent to share your information with third parties. In any such case, we will make it clear why we want to share the information.
We may use and share non-personal information (meaning information that, by itself, does not identify who you are such as device information, general demographics, general behavioural data, geolocation in de-identified form), as well as personal information in hashed, non-human readable form, under any of the above circumstances. We may also share this information with third parties (notably advertisers) to develop and deliver targeted advertising on our services and on websites or applications of third parties, and to analyse and report on advertising you see. We may combine this information with additional non-personal information or personal information in hashed, non-human readable form collected from other sources.
Our main operations are based in the UK and your personal information is generally processed, stored and used within in the UK and other countries in the European Economic Area (EEA). In some instances, your personal information may be processed outside the European Economic Area. If and when this is the case we take steps to ensure there is an appropriate level of security so your personal information is protected in the same way as if it was being used within the UK and the EEA.
Where we need to transfer your data outside the UK or the EEA we will use one of the following safeguards:
- The use of approved standard contractual clauses in contracts for the transfer of personal data to third countries.
- Transfers to a non-EEA country with privacy laws that give the same protection as the UK and the EEA.
Updating your information
If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion or object to its processing, please contact us at firstname.lastname@example.org.
For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer the above requests.
Keep in mind, we may reject requests for certain reasons, including if the request is unlawful or if it may infringe on trade secrets or intellectual property or the privacy of another user. If you wish to receive information relating to another user, such as a copy of any messages you received from him or her through our service, the other user will have to contact us to provide their written consent before the information is released.
Also, we may not be able to accommodate certain requests to object to the processing of personal information, notably where such requests would not allow us to provide our service to you anymore. For instance, we cannot provide our service if we do not have your date of birth.
You can stop all information collection by an app by uninstalling it using the standard uninstall process for your device. If you uninstall the app from your mobile device, the unique identifier associated with your device will continue to be stored. If you re-install the application on the same mobile device, we will be able to re-associate this identifier to your previous transactions and activities.
In certain countries, including in the European Union, you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how we process your personal information. The data protection authority you can lodge a complaint with notably may be that of your habitual residence, where you work or where we are established.
How We Protect Your Information
We work hard to protect you from unauthorized access to or alteration, disclosure or destruction of your personal information. As with all technology companies, although we take steps to secure your information, we do not promise, and you should not expect, that your personal information will always remain secure.
We regularly monitor our systems for possible vulnerabilities and attacks and regularly review our information collection, storage and processing practices to update our physical, technical and organizational security measures.
We may suspend your use of all or part of the services without notice if we suspect or detect any breach of security. If you believe that your account or information is no longer secure, please notify us immediately at email@example.com.
How Long We Retain Your Information
We keep your personal information only as long as we need it for legitimate business purposes and as permitted by applicable law. To protect the safety and security of our users on and off our services, we implement a safety retention window of three months following account deletion. During this period, account information will be retained although the account will of course not be visible on the services anymore.
In practice, we delete or anonymize your information upon deletion of your account (following the safety retention window) or after two years of continuous inactivity, unless:
- we must keep it to comply with applicable law (for instance, some “traffic data” is kept for one year to comply with statutory data retention obligations);
- there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or
- the information must be kept for our legitimate business interests, such as fraud prevention and enhancing users’ safety and security. For example, information may need to be kept to prevent a user who was banned for unsafe behaviour or security incidents from opening a new account.
- Keep in mind that even though our systems are designed to carry out data deletion processes according to the above guidelines, we cannot promise that all data will be deleted within a specific timeframe due to technical constraints.
Our services are restricted to users who are 18 years of age or older. We do not permit users under the age of 18 on our platform and we do not knowingly collect personal information from anyone under the age of 18. If you suspect that a user is under the age of 18, please contact us at firstname.lastname@example.org.
To enable push notifications to be sent, a “Firebase Cloud Messaging Registration Token” is created when the app is first launched.The “token is created when the app is first started, which uniquely identifies the app installation on your device and is used to recognise the message destination. The messages are sent via the Google Firebase Cloud Messaging service, which is provided by Google, Inc. Mountain View, USA. Further information on Google Firebase Cloud Messaging can be found here and in Google’s
Cookies And Similar Tracking Technologies
Economic Analyses and Market Research
In order to run our business economically, to identify market trends, customer and user wishes, we analyse the data available to us on business transactions, contracts, enquiries, etc. In doing so, we process inventory data, communication data, contract data, payment data, usage data, metadata on the basis of Art. 6 para. 1 lit. f. GDPR, whereby the persons concerned include customers, interested parties, business partners, visitors and users of the online offer. The analyses are carried out for the purposes of business management evaluations, marketing and market research.
In doing so, we may take into account the profiles of registered users with details, for example, of their purchasing transactions. The analyses serve us to increase user-friendliness, to optimise our offer and business efficiency and are not disclosed externally, unless they are anonymous analyses with summarised values.
If these analyses or profiles are personal, they will be deleted or made anonymous upon termination by the user, otherwise after two years from conclusion of the contract. In all other respects, the macroeconomic analyses and general trend determinations are prepared anonymously wherever possible.
Collection of access data and log files
On the basis of our legitimate interests within the meaning of Article 6 paragraph 1 letter f. GDPR, we collect data about every access to the server on which this service is located (so-called server log files). The access data includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the website previously visited), IP address and the requesting provider.
For security reasons (e.g. to clarify acts of abuse or fraud), log file information is stored for a maximum of seven days and then deleted. Data whose further storage is required for evidential purposes are excluded from deletion until the respective incident has been finally clarified.
Communication by mail, e-mail, fax or telephone
We use means of distance communication, such as post, telephone or e-mail, for business and marketing purposes. We process inventory data, address and contact data as well as contract data of customers, participants, interested parties and communication partners.
The processing is based on Art. 6 para. 1 lit a, Art. 7 GDPR, Art. 6 para. 1 lit f GDPR in connection with legal requirements for advertising communications. Contact shall only be established with the consent of the contact partners or within the scope of the statutory permissions and the processed data shall be deleted as soon as they are not required and otherwise with objection/ revocation or discontinuation of the basis for authorisation or statutory archiving obligations.
Online presences in social media
We maintain online presences on the basis of our legitimate interests within the meaning of Art. 6 Para. 1 lit. f. GDPR. We maintain online presences within social networks and platforms in order to communicate with customers, interested parties and users who are active there. Unless otherwise stated in this policy, we process the data of users if they communicate with us within the social networks and platforms, e.g. write articles on our online presences or send us messages.
Because we’re always looking for new and innovative ways to help you build meaningful connections, this policy may change over time. We will notify you before any material changes take effect so that you have time to review the changes.
How To Contact Us