Last updated: Dec 3, 2021

This is the Privacy Policy of HoldUpro Video Chat App (“HoldUpro”, “us”, “we”, "Service" or “our”) and is incorporated into and is subject to our Terms of Use which can be found here. In this Privacy Policy, we refer to our products and services as the “Service.” Please read on to learn more about our data handling practices. We respect your privacy and want you to understand how we collect, use, and share data about you. This Privacy Policy covers our data collection practices and describes your rights to access, correct, or restrict our use of your personal data; in plain language, keeping legal and technical jargon to a minimum. Your privacy is at the core of the way we design and build our Services and products you know and love so that you can fully trust them and focus on building meaningful connections. Unless we link to a different policy or state otherwise, this Privacy Policy applies when you visit or use the Service. Your use of the Service signifies that you agree with the terms of this Privacy Policy. If you do not agree with the terms of this Privacy Policy, do not use the Service.

Table of Contents

1. Controller
2. What Data We Get
3. How We Get Data About You
4. What We Use Your Data For
5. How We Share Information
6. Your Rights
7. Data Retention
8. Data Protection and Security
9. Children’s Privacy
10. International Transfer Policy
11. Privacy Policy Changes
12. Contact Us

1. Controller

• Controller: The controller of data processing is HoldUpro. You can contact us via e-mail under the Email Address.
• Data Protection Officer: Our data protection officer can be contacted under the Email Address. Should you have any questions regarding the processing of your personal data, please do not hesitate to contact him/her.

2. What Data We Collect

This Privacy Policy applies to websites, apps, and other services operated by us. We process personal data that you as a user of the Products make available to us, for example by using our Products and that users provide to us (“Data”).We can’t help you develop meaningful connections without some data about you, such as basic profile details and the types of people you’d like to meet. 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. We also collect some data automatically, like information about your device and what parts of our Services you interact with or spend time using.

2.1 Data You Provide to Us

• Account Data: In order to use certain features (registering for an account), you need to create a user account. When you create or update your account, we collect and store the data you provide, like your name, gender, and date of birth, and assign you a unique identifying number (“Account Data”).
• Profile Data: You can also choose to provide profile information like a photo, info, name, sexual interests, or other data. Your Profile Data will be publicly viewable by others unless you delete your account. To add certain content, like pictures or videos, you may allow us to access your camera or photo album. Some of the information you choose to provide us may be considered “special” or “sensitive” in a certain jurisdiction, 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.
• Usage Data: When you use our Services and features, we collect certain data including; messages, follow information, photos, videos, and other user data. 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.
• Shared Content: Parts of the Services let you interact with other users or share content publicly, including by videos you post and the data you provided in your profile. Such shared content may be publicly viewable by others depending on where it is posted.
• Promotions: When you choose to participate in our promotions, events, or contests, we collect the information that you use to register or enter. If you won a prize, we would collect the financial information to reward you.
• Data About Your Accounts on Other Services: We may obtain certain information through your social media or other online accounts if they are connected to your account in our Services. If you login to our Services via Facebook or another third-party platform, we ask for your permission to access certain information about that other account. For example, depending on the platform or service we may collect your name, profile picture, gender, info, and birthday.
  Those platforms and services make information available to us through their APIs. The information we receive depends on what information you (via your privacy settings) or the platform or service decide to give us.
  If you access or use our Services through a third-party platform or service, or click on any third-party links, the collection, use, and sharing of your data will also be subject to the privacy policies and other agreements of that third party.
• Data About Paid Service: All our paid service is through iOS or Android platforms. We only receive a receipt of your transaction provided by these platforms. For security reasons, we do not collect or store sensitive cardholder data, such as full credit card numbers or card authentication data.
• Communications and Support: If you contact us for support or to report a problem or concern (regardless of whether you have created an account), we collect and store your contact information, messages, and other data about you such as your name, email address, location, operating system, IP address, and any other data you provide or that we collect through automated means (which we cover below). We use this data to respond to you and research your question or concern, in accordance with this Privacy Policy. 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.
• Sensitive Information: Please be careful about posting sensitive details about yourself on your Profile such as your religious denomination and health details. While you may voluntarily provide this information to us when you create your Profile, including your sexual preferences and ethnic background, there is no requirement to do so. Please remember that photographs or any video clips that you post on our Services may reveal these kinds of sensitive personal data. Where you do upload and choose to tell us sensitive data about yourself, you are explicitly consenting to our processing your information and making this public to other users.

* The data listed above is stored by us and associated with your account in our Services.

2.2. Data From Others

In addition to the information you provide us directly, we receive information about you from others or by automated means, including:

• System Data: Technical data about your computer or device, like your IP address, device type, operating system type and version, unique device identifiers, device language, browser, browser language, and other systems data, and platform types (“System Data”).
• Usage Data: 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, search preferences, clicks, and pages which have been shown to you, referring web page 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, number of content you post).
• Device Information: 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 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.
• Other information with your consent: If you give us permission, we can collect your precise geolocation (latitude and longitude) through various means, depending on the service and device you’re using, including GPS, Bluetooth or Wi-Fi connections. The collection of your geolocation may occur in the background even when you aren’t using the Services if the permission you gave us expressly permits such collection. If you decline permission for us to collect your geolocation, we will not collect it. Similarly, if you consent, we may collect your photos and videos (for instance, if you want to publish a photo, video or streaming on the Services).
• Approximate Geographic Data: An approximate geographic location, including information like country, city, and geographic coordinates, calculated based on your IP address.
• Other Partners: We may receive information about you from our partners, for instance where our ads are published on a partner’s websites and platforms (in which case they may pass along details on a campaign’s success).

3. How We Get Data About You

We use tools like analytics services, and advertising providers to gather the data listed below. Some of these tools offer you the ability to opt-out of data collection.

3.1 Analytics

The main reason we use your information is to deliver and improve our Services. Additionally, we use your info to help keep you safe. Read on for a more detailed explanation of the various reasons we use your information, together with practical examples.

• 3rd Party Conversion Tracking Tools: Adjust, Google Conversion Tracking APIs, and Facebook Conversion tracking APIs are used for user conversion tracking. Admost is a monetization tool used for analyzing the user preferences and ad data as well as conversion tracking.
• Crash Detection Tools: We use Crashlytics tools owned by Fabric for crash detection. It facilitates the maintenance and improvement of the Services. All your crash data is collected anonymously.

3.2 Online Advertising

We use third-party advertising services like Google’s ad services(DFP, Admob, AdX), Facebook Audience Network to deliver online advertisements to our end users within our Services including mobile applications and websites. The ads may be based on information we know about you as detailed in Section 2.2  Data From Others and information that these ad service providers know about you based on their tracking data. The ads can be based on your recent activity or activity over time and across other services and may be personalized to your likes and interests. When using other services you may also receive personalized online advertisements. From time to time we also advertise our Services on some third-party platforms like Google’s Adwords, Apple’s Search Ads, Unity, Tiktok (Bytedance), Snapchat, Facebook, Google Ads.

Depending on the types of advertising services we use, cookies or other tracking technologies may be placed on your device to collect data about your use of our Services, and those tracking technologies may be accessed in order to serve these personalized advertisements to you. To help deliver personalized advertising, we may provide these service providers with a hashed, anonymized version of your personal information in a non-human-readable form and content that you share publicly on the Services.

We also use third-party tools to analyze and track ad and user data. They are used for statistical purposes. We use Adjust and Admost which are GDPR compliant tools.

Only irreversibly anonymized data is used during all advertising processes including personalized advertising thus this does not allow any conclusions to be drawn about the identity of the person concerned.

• If you access or use our Services through a third-party platform or service, or click on any third-party links, the collection, use, and sharing of your data will also be subject to the privacy policies and other agreements of that third party.
• All 3rd Party tools are GDPR compliant.
• You may change your personalized ads preferences from settings if you are located in a territory that is protected by the CCPA & the GDPR.

4. What We Use Your Data For

The main reason we use your information is to deliver and improve our Services. Additionally, we use your info to help keep you safe. 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, including order management and billing

To help you connect with other users

• Analyze your profile and that of other users to recommend meaningful connections
• Show users’ profiles to one another

To improve our Services and develop new ones

• Administer focus groups and surveys
• Conduct research and analysis of users’ behavior 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’ behavior)
• Develop new features and services (for example, we may decide to build a new interests-based feature further to requests received from users).

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

• Address ongoing or alleged misbehavior on and off-platform
• Perform data analysis to better understand and design countermeasures against these activities
• Retain data related to fraudulent activities to prevent 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.

Legitimate interests: We may use your information where we have legitimate interests to do so. For instance, we analyze users’ behavior 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.

• Marketing:Push Message Marketing: With your explicit consent, we will send you marketing push messages.
• Retargeting: You might see marketing messages on the platforms listed below. In addition, other users who have similar characteristics to you on those platforms could see marketing messages on those platforms as well (i.e., Facebook Lookalike audience). An opt-out is possible at any time via our customer support. It may take a few days after the opt-out until you are removed from all audiences.
• List of other platforms: Facebook, Google, Twitter, UnityAds, Snapchat, and Bytedance

Consent: From time to time, we may ask for your consent to use your information for certain specific reasons. You may withdraw your consent at any time by contacting us at the address provided at the end of this Privacy Policy.

5. How We Share Information

5.1 With Other Users:

You share information with other users when you voluntarily disclose information on the service (including your public profile). Please be careful with your information and make sure that the content you share is the stuff that you’re comfortable being publically viewable since neither you nor we can control what others do with your information once you share it.

5.2 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. These service providers may access your personal data and are required to use it solely as we direct, to provide our requested service.

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.

5.3 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.

5.4 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.

5.5 Monitor:

Moderators to monitor activity on the site/apps and approve content. Fraud prevention and anti-spam providers to protect the service from criminal activity.

5.6 Change of Control:

In the event that our Services or any of its affiliates undergoes a business transition or change of ownership, such as a merger, acquisition by another company, reorganization, or sale of all or a portion of its assets, or in the event of insolvency or administration, we may be required to disclose your personal data.

6. Your Rights

You have certain rights around the use of your data, including the ability to opt-out of cookies, and the collection of your data by certain analytics providers. You can update or terminate your account from within our Services, and can also contact us for individual rights requests about your personal data. We want you to be in control of your information, so we have provided you with the following tools:

• Access / Update tools in the service: Tools and account settings that help you to access, rectify or delete information that you provided to us and that’s associated with your account directly within the service.
• Device permissions: Mobile platforms have permission systems for specific types of device data and notifications, such as phone book and location services as well as push notifications. You can change your settings on your device to either consent or oppose the collection of the corresponding information or the display of the corresponding notifications. Of course, if you do that, certain services may lose full functionality.
• Deletion: You can delete your account by using the corresponding functionality directly on the service.

We want you to be aware of your privacy rights. Here are a few key points to remember:

• Reviewing your information: Applicable privacy laws may give you the right to review the personal information we keep about you (depending on the jurisdiction, this may be called right of access, right of portability or variations of those terms). You can request a copy of your personal information by sending us an email at customerdesk@HoldUpro.mobi.
• 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 via customerdesk@HoldUpro.mobi.

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 our Privacy Officer 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.

• Uninstall: You can stop all information collected 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.
• Accountability: 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.

If you want to exercise any of your rights listed above please visit our feedback form or email us at customerdesk@HoldUpro.mobi.

7. Data Retention

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 six months following account deletion unless there is a technical difficulty. During this period, some of your 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 the deletion of your account (following the safety retention window) or after 5 years of continuous inactivity. An account is considered inactive when the Application of the Member has not established contact with HoldUpro’s servers (including due to deactivation of the geolocation process), and the Member has not used the Application. In any event, the Account of a Premium Member is not considered inactive.

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) as well as to prevent bot systems that are abusing the system;
• we must keep it to evidence our compliance with applicable law (for instance, records of consents to our Terms, Privacy Policy, and other similar consents are kept for five years);
• 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 behavior or security incidents from opening a new account.

Correspondence with our Customer Support team will be retained for longer to allow us to deal with any subsequent queries you may have but will usually be deleted within 6 years if there are no queries.

Anonymized information about activity on our Services is retained for longer periods of time for statistical and product research purposes but this is not attributable to an individual once the profile has been deleted.

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 time frame due to technical constraints.

8. Data Protection and Security

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. Your password is an important part of our security system, and it is your responsibility to protect it. You should not share your password with any third party, and if you believe your password or account has been compromised, you should change it immediately and contact customerdesk@HoldUpro.mobi with any concerns.

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. We are not responsible for virus protection outside our service network. We are also not responsible for the damage or destruction of user data. We will pursue every detected attack by hackers, etc. under civil law and, if necessary, by the prosecution.

In case of a breach, we will notify; the EU representatives, our DPO and our users who were or potentially were affected by the breach within 72 hours of the attack. We will announce it on our webpage.

9. Children’s Privacy

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 use the reporting mechanism available through the service. If we become aware that a child, minor or anyone under the age of 18 has registered with us and provided us with personal data, we will take steps to terminate that person’s registration and delete their profile information from our Services. If we do delete a Profile because you violated our no children rule, we may retain basic account and profile information to ensure that you do not try to get around our rules by creating a new profile.

10. International Transfer Policy

In order to provide the Services to you, we must transfer your data to our servers and process it there. By visiting or using our Services, you consent to the storage of your data on servers. If you are using the Services, you consent to the transfer, storage, and processing of your data. Specifically, personal data collected in Switzerland and the European Economic Area (“EEA”) is transferred and stored outside those areas.

That data is also processed outside of Switzerland and the EEA by our HoldUpro companies, or our service providers, including to process transactions, facilitate payments and provide support services as described in Section 4 & 5. We have entered into data processing agreements with our service providers that restrict and regulate their processing of your data on our behalf. By submitting your data or using our Services, you consent to this transfer, storage, and processing by HoldUpro and its processors. We operate a global network of servers including in Germany, Netherlands, Turkey, and Canada. We ensure that the data is adequately protected by ensuring that valid, legal mechanisms are in place. If you want more information relating to the nature of the safeguards we have in place please email customerdesk@HoldUpro.mobi.

11. Privacy Policy Changes

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.

12. Contact Us

If you have any questions regarding this privacy statement, the processing of your personal data, you can contact us directly. We are also available to you in the case of requests for information, requests or complaints:

E-MAIL: HoldULive@outlook.com