Privacy Policy

Minglr Privacy Policy

Welcome to the Minglr Privacy Policy (“Policy”)! This Policy explains how Minglr processes and puts you in control of your Personal Information. We also 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

The App and Sites are operated by Minglr Company (also referred to in this policy as “we” or “us”) controller of personal information collected and processed through the Minglr App and Site.

1. COLLECTION OF INFORMATION.

Registration Information

When you download the App and create an account (“Account”), we may collect certain information (“Registration Information”) about you, such as:

• Name;

• Username;

• Email address;

• Mobile number;

• Gender identity;

• Date of birth;

• Sexual preference;

• Photographs;

• Location; and

• Login information for social media accounts that you connect to your Minglr Account (this could include, for example, your Facebook and Instagram accounts). Once you register, you will be able to review and change this information at any time just by logging in to Minglr (other than your date of birth and location (which, if you have given Minglr access to your location in your device settings, is automatically updated based on the location of your device)). It is your responsibility to ensure that your account details are kept up to date. If your phone number changes, please ensure that you update this in your account.

The information we collect helps to enhance the App and verify our Users. Registration Information such as your sexual preference, name and username may be visible to other Users who view your profile page.

Profile Information

We recommend and encourage you (and all our members) to think carefully about the information you disclose about yourself. We also do not recommend that you put email addresses, URLs, instant messaging details, phone numbers, full names or addresses, credit card details, national identity numbers, drivers’ licence details and other sensitive information which is open to abuse and misuse on your profile.

Profile Verification Information (Including Biometric Information)

For safety and security and to ensure you have the best possible user experience, we require Users to verify their accounts and might ask for your phone number and, in some instances, we might also ask that you carry out photo verification. We want to make sure you are not a robot! And we also want to avoid fake Minglr accounts being created which can be used for malicious activities and cybercrime – they threaten the Minglr network and spoil things for everyone. This verification might be required by us for the prevention of fraud. You can also verify your photo on a voluntary basis (to add the blue ‘verified’ badge to your profile).

If you choose to verify your profile photo, we will scan each photo that you submit. The scan may include the use of facial recognition technology so that we can compare the photo you submit to your profile photo, to help ensure that you are who you say you are. Additionally, we conduct checks for nudity, reserving the right to prohibit the uploading or transmission of such images in our application. We do not add the verification photos to your profile. We retain the scans so that we can verify you in the future and for our record-keeping purposes until we no longer need them for such purposes or for three years after your last interaction with us, whichever occurs first. After the applicable retention period expires, we take commercially reasonable steps to permanently and securely delete the scans from our systems.

Purchases Information

If you decide to purchase any of our premium services, we will process your payment information and retain this securely for the prevention of fraud and for audit/tax purposes.

Minglr uses automated decisions to prevent fraudulent payment transactions being processed as part of its anti-fraud procedures. In order to do this, our systems check payment transactions for behaviour that indicates breaches of our Terms and Conditions of Use. If a transaction meets certain criteria that demonstrate that the Terms and Conditions of Use are likely to have been breached and the transaction is likely to be fraudulent, the relevant transaction may automatically be blocked. Where a transaction is blocked, the user will be notified that their transaction cannot be processed and affected Users can contact Minglr to contest the decision.

Geolocation Information

If you have given Minglr access to your location in your device settings, when you use your mobile, we will collect information about WiFi access points as well as other location information about your longitude and latitude and may save your device’s coordinates to offer certain features to you. This information helps us identify your physical location and we use it to personalise the App and make it easier for you to interact with other Users, by enabling the general locality information to be displayed to Users seeing your profile and showing you the profiles of other Users who are near you.

If you have given Minglr access to your location, but wish to turn this off, you can do so by the following methods:

1. iPhone app — settings, privacy, location services, Minglr

2. Android — settings, location, Minglr, permissions, location

Device Information

We may collect information about your device when you use the App including the unique device identifier, device model, and operating system, for a number of purposes, as set out in this policy. In addition, if you permit us to do so, the App may access your device’s address book solely in order to add someone to your contacts.

Links

We may keep track of how you interact with links available on Minglr including third party services by redirecting clicks or through other means. We may share aggregate click statistics such as how many times a particular link was clicked on.

Cookies and similar technologies

When you visit our Sites or when you use our App, we may collect personal data from you automatically by using cookies or similar technologies. A cookie is a small file that can be placed on your device or browser that allows us to recognise and remember you.

2. USE OF YOUR INFORMATION.

The main reason we use your information is to deliver and improve our services. Additionally, we use your info to help keep you and our community 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 for which we use your information, together with practical examples.

– To administer your account and provide our services to you.

– To help you connect with other users.

– To provide new Minglr services to you.

– To provide offers and operate advertising and marketing campaigns.

– To improve our services and develop new ones.

– To prevent, detect and fight fraud and other illegal or unauthorized activities.

– To ensure legal compliance.

To process your information as described in this Privacy Policy, we rely on the following legal bases:

3. DISCLOSURE OF INFORMATION.

The main reason we use your Personal Information is to enable the Minglr Properties, such as providing you with core features of the Services, providing you with support, and supporting platform safety. We only process your Personal Information in accordance with specific purposes and legal bases where required.

In general, we use your Personal Information to:

– Provide you with the Services associated with your Minglr account.

– Answer your inquiries and provide you with support.

– Improve our Properties and support user safety within the Services.

– Protect our interests as a company.

– Allow you to enjoy certain Service and Property features.

– Allow third-party ad / marketing partners to use cookies and other technologies for the purposes of serving ads to free users of the Services.

– Conduct surveys or obtain your voluntary feedback about our Properties.

– Respond to legal requests from law enforcement agencies, regulators, and other third-parties to comply with “Legal Obligations”.

4. HOW WE SHARE YOUR PERSONAL INFORMATION.

To enable you to make meaningful connections, Minglr allows you to share information about yourself with the Minglr Community and third-parties in connection with our providing you with the Minglr Properties as described in this Policy. In general, we share your Personal Information in the following ways:

The Minglr Community. The Minglr Services are intended to be a safe space where you can discover, navigate, and interact with others in the Minglr Community. As part of the Services, Minglr enables you to share your Profile Information, location, and other information with the Minglr Community.

Third-Party Partners. Minglr shares Personal Information with several third-party partners to bring you the Minglr Properties, such as Service Providers (e.g., Ad / Marketing Partners help facilitate advertising experiences, and Other Partners that support the Minglr Properties and with whom you may provide Personal Information to directly.)

Business Transactions. If another company acquires, or plans to acquire, our company, business, or assets, that company will possess the Personal Information collected by us and will assume the rights and obligations regarding your Personal Information as described in this Policy.

Legal Obligations. We may access, preserve and disclose Personal Information to investigate, prevent, or take action in connection with: (i) enforcement of the Minglr Terms and Conditions of Service; (ii) claims that any content or behavior violates our policies or the rights of third-parties; (iii) requests for customer service; (iv) technical issues; (v) protecting the rights, property or personal safety of Minglr, its users or the public; (vi) lawful legal requests including subpoenas, warrants, or court orders or in connection with any legal process; (vii) establishing or exercising our legal rights or defending against legal claims; (viii) tax and accounting purposes; or (ix) as otherwise required by law, collectively “Legal Obligations”.

5. SECURITY.

Here at Minglr, we pride ourselves on taking all appropriate security measures to help protect your information against loss, misuse and unauthorised access, or disclosure. We use reasonable security measures to safeguard the confidentiality of your personal information such as secured servers using firewalls.

Unfortunately, no website or Internet transmission is ever completely 100% secure and even we cannot guarantee that unauthorised access, hacking, data loss or other breaches will never occur, but here are some handy tips to help keep your data secure:

1. Please make sure you log out of your Account after use as you never know who may stumble onto your Account!

2. Please don’t share the password you use to access your Minglr Account with anyone else!

3. Change your password periodically.

User Monitoring: We actively track the frequency with which users are blocked by others. If a user reaches a threshold determined by us, we may either notify or suspend that account for the safety of our community.

Multi-Account Prevention: We detect if multiple accounts are being created from a single device and may block access to ensure genuine user interactions.

Screenshot Protection: Screenshots within the app are disabled to prioritize user privacy and protect sensitive information.

User Reporting: We take user reports seriously. When credible and substantial reasons are presented for reporting a user, we take swift measures to review and, if necessary, block the implicated account to maintain a safe and respectful environment.

6. YOUR RIGHTS AND CHOICES.

Privacy laws applicable in your country may give you the following rights:

1. Right to be informed: what personal data an organisation is processing and why (we provide this information to you in this Privacy Policy).

2. Right of access: you can request a copy of your data.

3. Right of rectification: if the data held is inaccurate, you have the right to have it corrected.

4. Right to erasure: you have the right to have your data deleted in certain circumstances.

5. Right to restrict processing: in limited circumstances, you have the right to request that processing is stopped but the data retained.

6. Right to data portability: you can request a copy of certain data in a machine-readable form that can be transferred to another provider.

7. Right to object: in certain circumstances (including where data is processed on the basis of legitimate interests or for the purposes of marketing) you may object to that processing.

8. Rights related to automated decision-making including profiling: there are several rights in this area where processing carried out on a solely automated basis results in a decision which has legal or significant effects for the individual. In these circumstances your rights include the right to ensure that there is human intervention in the decision-making process.

The particular rights which are applicable to you (which might include other rights not listed above) may vary depending on your country. You should make yourself aware of the rights you have under applicable privacy laws in your country.

7. DATA RETENTION AND DELETION.

We keep your personal information only as long as we need it for the legal basis relied upon and as permitted by applicable law.

When your Account is deleted, we make sure it is no longer viewable in the App. For up to 28 days, it is still possible to restore your Account if it was accidentally deleted. After 28 days, we begin the process of deleting your personal information from our systems, unless:

1. we must keep it to comply with applicable law (for instance, if you make purchases within the App, some personal data may be kept for tax and accounting purposes);

2. we must keep it to evidence our compliance with applicable law (for example, if an account is blocked, we keep some account information and a record of the behaviour that led to the block – this information is retained for evidential purposes in case of queries or legal claims concerning the block);

3. there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or

4. 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).

Warning: Even after you remove information from your profile or delete your Account, copies of that information may still be viewable and/or accessed to the extent such information has been previously shared with others, or copied or stored by others. We cannot control this, nor do we accept any liability for this. If you have given third party applications or websites access to your personal information, they may retain such information to the extent permitted under their terms of service or privacy policies.

8. CHANGES TO THIS POLICY.

As Minglr evolves, we may revise this Privacy Policy from time to time. If we make a change to this policy that, in our sole discretion, is material, we will notify you, for example, via an email to the email associated with your Account or by posting a notice within Minglr.

Effective date

This Privacy Policy was last updated on: December 29, 2023