Privacy Statement

Introduction

This privacy statement describes how we use data in our application, browsers and services. Some of the data we use is considered “personal data” under applicable law. However, even when we use personal data, we generally have no way of actually identifying you as an individual, and our users are essentially anonymous to us.

The specific categories of data that we collect, use, or otherwise process can vary from product to product, from one purpose to another, and in some cases based on your location. This privacy statement sets out when, how, and why we process your data (including but not limited to personal data), as well as your rights under applicable law.

Definitions

First, let’s define some key terms. Many of these definitions are adapted (with changes) from the Data Protection Regulation, the data privacy law which applies in the India as well as in Indian Sub-Continent. We use the Data Protection Regulation as a guidepost because it applies directly to our companies as per Indian Information Technology Act, 2000 (IT Act) and Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011. And because we believe it sets the highest legal standard for user privacy. However, in some cases we have simplified definitions here for the purpose of clarity.

Personal data: “any information relating to an identified or identifiable natural person” as the Data Protection Regulation says. This includes data such as your IP address, device IDs, advertising IDs, and location. Below where we describe how we process personal data, we also list the specific purpose for doing so, as well as our legal basis under the Data Protection Regulations (as those terms are defined below). Personal data that a user may include in the text they write when sending feedback through an app store or any other means

What data/Information is collected

The Company may collect the following two types of information:

1. "Personal Information" which shall mean information which could reasonably be used to identify You personally including without limitation, Your name, phone number, OTP, language preferences, date of birth, gender, location, IP Address, device information. username, password, Other profile information, such as social media account information and profile image, information about your computer hardware and software and such other information as may be required for your interaction with the services and from which your identity is discernible. When you create your account.

2. "Non-Personal Data/Information" which shall mean information that does not identify You or any other individual, and includes session, cookies, web beacons and usage data, log data and aggregate information.

3. When you visit the Service, we (and our third-party partners) will send cookies — small text files containing a string of alphanumeric characters — to your device that uniquely identifies your browser and lets us do things like help you log in faster, enhance your navigation through the site, remember your preferences and generally improve the user experience. Cookies also convey information to us about how you use the Service (e.g., the pages you view, the links you click and other actions you take on the Service), and allow us or our business partners to track your usage of the Service over time. They also allow us to measure traffic and usage trends for the Service, deliver personalized advertisements that may be of interest to you and measure their effectiveness, and find potential new users of the Service.

4. You can control or reset your cookies and similar technologies through your web browser, which will allow you to customize your cookie preferences and to refuse all cookies or to indicate when a cookie is being sent. However, some features of the Service may not function properly if the ability to accept cookies is disabled. For more information on how we use cookies and other technologies and how you can control them, please read our Cookies Policy.

5. We may also collect certain information about the use of our Site by you, such as the services you access/use or areas you visit. We use this information to deliver our web pages to you upon request, to tailor our Site to the interests of our Site users, to measure traffic on the Site. This information may also be used by our advertisers / third party companies/ Service Providers to personalize content, ads etc.

6. . We will directly collect or generate certain information about your use of the Service (such as user activity data, analytics event data and clickstream data), for data analytics and machine learning, and to help us measure traffic and usage trends for the Service. We may also use third party analytics tools that automatically collect information sent by your browser or mobile device, including the pages you visit and other information that assists us in improving the Service. For more information, please see the paragraphs below on cookies information, log file information, device identifiers, and location data.

7. We may collect personal information in content you upload to the Service (such as photos or videos you upload and the metadata about your content). We use this information to operate, maintain, and provide the features and functionality of the Service, to correspond with you, and to address any issues you raise about our services. You must not upload photos or other content containing any personal data of third parties without their express consent.

You represent that the information or data You provide from time to time is and shall be correct, current and updated and You have all the rights, permissions and consents to provide such information or data. Your provision of the information or data to the Company and the Company’s consequent storage, collection, usage, transfer, access or processing or deletion of the same shall not be in violation of any third-party agreement, laws, judgments, orders or decrees.

How we use your information

We use the information we collect about you for the purposes set out below:

Providing you with the Service: We use the information that you directly give us to provide the Service to you. This includes allowing you to log in to the Service, operating and maintaining the Service and giving you access to your Content. We may also use information we collect about you automatically to remember information about you so that you will not have to re-enter it during your visit or the next time you visit the site.

For data analytics: We use information about you to help us improve the Service and our users’ experience, including by monitoring aggregate metrics such as total number of visitors, traffic, and demographic patterns.

For analytics and machine learning: We may analyze your activity, Content, and related data activity in your account to provide and customize the Service, and to train our algorithms, models, products and services using machine learning to develop, improve and provide our Service. If you don’t want your Content to be used for machine learning, you can opt out by updating your preferences in your account settings at any time.
These activities include, but are not limited to:

labeling and detecting components in images (e.g., background, eyes);
labeling raw individual data (e.g., “man with dog”);
detecting content prohibited by our Terms for moderation and security purposes (e.g., pornographic or copyright protected material);
translating audio soundtracks;
predicting the most relevant product offerings for a user to tailor communications and advertising; and
search terms and corresponding search results interaction data to build an algorithm to deliver the most relevant content result.

Customizing the Service for you: We may use and combine the information you provide us and information about you that we collect automatically and receive from other sources (including information we receive on and off our Service) and combine it with information about the behavior of other users to make sure that your use of the Service is customized to your needs. For example, to recommend content that is likely to be useful to you, we may use information derived from your prior behavior on our Service, the use of content by other people and other inferred information.

To communicate with you about the Service: We may use your contact information to get in touch with you and to send communications about critical elements of the Service. For example, we may send you emails about technical issues, security alerts or administrative matters.

To promote and drive engagement with the Service: We may use your contact information to get in touch with you about taking part in our surveys or about features and offers relating to the Service that we think you would be interested in. We may also use information we collect about you to make sure that you get the most relevant offers and promotions based on your use of the Service, and your preferences.

To improve the Service: We analyze information about your use of the Service and your content to better understand how users are engaging with our Service and measure the effectiveness of the Service so we can make improvements and develop our services for users.

For advertising purposes: We may use information about you, including cookies information and other information we (and our third-party partners) collect from you automatically about your use of the Service, to serve, personalize and measure the effectiveness of advertising on the Service and third-party sites and platforms. This includes showing you advertising we think you might find interesting as well as displaying advertising to potential new users that have similar interests. For more information about how we use your information for advertising purposes, please see the section titled “Advertising” below.

Customer service: We use information about you, information that we collect from within your account, information that you provide to our customer service team, and information about your interactions with the Service to resolve technical issues you experience with the Service, and to ensure that we can repair and improve the Service for all users.

For security measures: We use information about you and from within your account to monitor activity that we think is suspicious or potentially fraudulent, and to identify violations of this Privacy Policy or our Terms.

For troubleshooting, error resolution and service improvement: : We may need to review your content or information to support your request for help, correct general errors with the Service or improve our services.

For matters that we are required to use your information by law: We will use or disclose your information where we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce our Terms or to protect the security or integrity of our Service; and/or (c) to exercise or protect the rights, property, or personal safety of ebombey, our users or others.

Legal basis for processing personal information

As per your location and its laws, we need a legal basis to collect, use and disclose your personal information. Our lawful basis will depend on the information concerned and the context in which it is processed.

Generally, ebombey will collect and use your information as follows:

Contractual necessity: We need it to provide the Service to you and fulfil our obligations to you under our Terms of Service. For example, this includes creating and maintaining your account, resolving issues you may experience with the Service and providing you with access to your Content.

Legitimate interests: It is necessary for our legitimate interests for example, providing a useful and customized Service, sending you relevant marketing messages, displaying advertising and tracking its effectiveness, using information we collect about you (like your platform usage and search terms) so that we can make more informed predictions, decisions and offers for our users, helping users connect with our community and enhancing our Service via research and development, data analytics, data labelling, machine learning and predictive analytics relating to your usage data. We do not rely on this lawful basis where our legitimate interests are overridden by your rights and interests.

Consent: You consent to us, and our third party partners, using your information in a certain way - for example, to hear about new features or offers, and for machine learning and predictive analysis relating to your Content.

Legal obligations: It is necessary for compliance with our legal obligations - for example, to disclose your information in response to law enforcement requests and to retain your information for our record keeping purposes.

If you consented to our use of your information, you can withdraw that consent at any time. Depending on the situation you can either withdraw your consent by emailing info@ebombey.com, or through your account settings page.

Data Retention:

The time period for which we will continue to store data. In general, we do not process or store personal data longer than needed and therefore delete it after a certain period of time.

We retain your Personal Information as long as necessary for providing you the services and as per the lawful basis of processing and to comply with our legal obligations. In particular, when determining how long we retain personal data, we take into account how long we need it to:

Maintain business records for analysis and/or audit purposes;
Comply with record retention requirements under the law;
Defend or bring any existing or potential legal claims; and
Deal with any complaints regarding the Platform/any services provided on the Platform.

The data that we collect to create a profile of you for the purpose marketing and advertising

Sharing your information

We respect and are committed to protecting your privacy as local law. However, we may disclose your personal information to our group companies, and to our services providers and partners who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our websites) or who otherwise process data for their own purposes (for example, to share your Content with our group companies) or for purposes that are described in this privacy policy or notified to you when we collect your data.

In the event of a proposed purchase, merger or acquisition of any part of our business, we may disclose your personal information to an actual or potential buyer (and its agents and advisers) provided that we inform the buyer it must use your personal information only for the purposes disclosed in this privacy policy.

We may also aggregate or otherwise strip data of all personally identifying characteristics and may share that aggregated such anonymized data with third parties.

We reserve the right to disclose your personal information as required by law (e.g., to comply with warrant, or court order) and when we believe that disclosure is necessary to protect our rights, avoid litigation, protect your safety or the safety of others, investigate fraud, and/or respond to a government request.

We may also disclose information about you if we determine that such disclosure should be made for reasons of national security, law enforcement, or other issues of public importance.

If you have consented to the disclosure of your personal information to any other third party, we may also share the data with them.

Data Controller & Internal Processing

ebombey application browser is developed and published by ebombey, a company registered under the Indian company Law and are promoting as per IT laws of the India. Therefore, ebombey Application Software acts as the primary data controller for ebombey Social Application Browser and its services.

The ebombey App/Application companies work together to develop our apps, and to market, distribute, and monetize them in India and Indian Sub-continent. In general, the other companies of the ebombey that may have access to personal data act as data processors for ebombey. As a matter of company policy, we apply the Indian Data Protection Regulation to our internal processing in general, even in contexts where it might not apply directly to our affiliated companies outside of India.

Security of Your Information

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unintentional disclosure.

We may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services, by mail or by sending an email to you.

Use of Cookies

We use cookies on our Application for session management and retaining your settings or preferences. We may also use third-party cookies to collect visitor statistics and measure our marketing campaigns. If you would like to reject third-party cookies, please configure your browser’s settings accordingly. Please refer to our Cookie Policy for more information.

Children’s Online Privacy Protection Act

There are no guarantees that children cannot enter our application or use our applications without parental consent or notification. Therefore, and as provided in our End User License Agreements, we require children to include their parents in the download process, and we encourage parents to read this privacy statement before allowing their children to use our applications and services.

Our services/Application are not directed to children under the age of 13 (or other age as required by local law), and we do not knowingly collect personal information from children. While individuals under the age of 13 may utilize our service, you must do so only with the involvement, consent and supervision of your parent or legal guardian.

If you are under the age of majority in your jurisdiction of residence, you may use the Services only with the consent of or under the supervision of your parent or legal guardian.

Consistent with the requirements of the Children’s Online Privacy Protection Act (COPPA) as per local jurisdiction, if we learn that we have received any information directly from a child under age 13, or other age as required by local law, without first receiving his or her parent’s verified consent, we will use that information only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use the Sites and subsequently we will delete that information.

International Data Transfers

As noted above, in different contexts we may share or make available data (including personal data) with other members of the ebombey App/Application, and sometimes with third parties, such as our marketing and monetization partners. Where applicable, we insist that a legally valid mechanism is used to protect such transfer, including for example the Indian Information Technology Act, 2000 (IT Act) and Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011. Model contracts for the transfer of personal data to third countries (also known as the “standard contractual clauses”) to ensure adequate protection of your personal data.

Email Communications

If you receive an advertising or marketing email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving such emails.

Your Rights & Statement Updates

You have the right to make a request to access or delete any of your personal data that we might possess. You can make a request via this online request form or by contacting our Data Protection Officer at the address below. You may be required to provide additional information to authenticate your request. You also have the right to lodge a complaint as per the Indian IT Data Protection Act, which can be contacted through their webpage.

When we post changes to this privacy statement, we will include the date when the statement was last updated. If we significantly change this statement, we will notify you about the upcoming change via our Application or using in-app notifications. We encourage you to review this statement periodically.

Your Privacy Rights:

In accordance with applicable law, you may have the right to:

Access personal information about you consistent with legal requirements. In addition, you may have the right in some cases to receive or have your electronic personal information transferred to another party, where technically feasible.
Request correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update personal information stored for your account, or for data we do not control, we may refer you to the controller who is able to make the correction.
Request deletion of your personal information, subject to certain exceptions prescribed by law. Subject to applicable law, you may request on support that ebombey delete information stored about you that is stored in our systems. However, if your data has been extracted from an external cloud-based service provider (e.g., G Suite, Office 365, Slack, etc.), the data will still be present in the cloud-based service provider’s system. To have this data deleted, contact the cloud-based service provider who hosts the data.
Request restriction of or object to processing of your personal information, if applicable, where such requests are permitted by law.

If you would like to exercise any of these rights, please log into your account, or contact us as detailed below. We will process such requests without undue delay and in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request. We will verify your request by asking you to send it from the email address associated with your account or to provide information necessary to verify your account.

You may be entitled, in accordance with applicable law, to submit a request through an authorized agent. To designate an authorized agent to exercise choices on your behalf, please select an agent registered with the Secretary of State of your state of residence and provide evidence that you have provided such agent with power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. We do not discriminate based on the exercise of any privacy rights that you might have.

Changes to this policy

We may update this privacy policy from time to time to reflect our current practice and ensure compliance with applicable laws. When we post changes to this policy, we will revise the “Last Updated” date at the top of this policy. If we make any material changes to the way we collect, use, store and/or share your personal data, we will take appropriate measures to notify you. We recommend that you check this page from time to time to inform yourself of any changes.

Delete Your Information

You can reach out to support team as mentioned in the “Contact Us” information point and choose to delete your account with us. users can choose to initiate the account deletion through their device as well

Deleting your account will delete your data with us including your email address, first and last name, profiles and all other attributes. It will also anonymize all your other information so that it is not associated to your phone number. You will also be unsubscribed to all our marketing campaigns going forward. We may retain some of your Personal Information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. We may retain data to be in compliance with local laws and auditing purposes

Contact us

If you have any questions about this statement or any privacy issues in our applications or services, feel free to contact our Data Protection Officer via this online request form or by post: at report@ebombey.com At ebombey, we're committed to giving people a justice and keeping their interest safe. We are using a roadmap of "Report, Verify, Inform, Remove" RVIR concept to manage content across ebombey platform.

We remove harmful content that goes against our policies, reduce the distribution of problematic content that doesn't violate our policies and inform people with additional context so they can decide what to click, read or share.

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