Pal - Privacy Policy

Table of Contents

1. Scope and general information

2. Data processing - General information

3. Data processing - Pal account / profile

4. Data processing - External services

5. Amendment to our Privacy Policy

6. Other notes and provisions


1. Scope and general information

1.1. Welcome to Pal. For the purposes of this Privacy Policy “Pal” is our app and all its features, as well as our website and us (Pal App Limited) as the operator of the app. For more information, please visit our Imprint.

1.2. With Pal you have the possibility to make various interactions via the social network that Pal creates. Our Terms of Service and Privacy Policy apply to your usage of Pal. We explain in our Terms of Service how Pal works and which rules apply to Pal’s functions. We also explain to you in this Privacy Policy which data of yours we process at Pal and how we protect your data. You can view our Terms of Service, Privacy Policy and Imprint at any time from your profile. If you have any questions or comments, please do not hesitate to contact us.

1.3. By “personal data” we mean all information that you can imagine about yourself by which you can be identified as a person or which, when combined together with other information we hold, can be used to identify you. This includes your name and contact details. Some of this data is required to provide you with certain features of Pal. In this Privacy Policy we explain what data we collect and how we use it.

1.4. You can rely on us to process your personal data in accordance with applicable law, including but not limited to the Data Protection Act 1998. Without your permission, we do not pass on your data to third parties.

2. Data processing - General information

2.1. You can install and open Pal anonymously. As soon as you install and open Pal, we automatically record access data anonymously. We require this data to ensure that Pal can operate and this data also allows us to continually improve Pal. For example, this data allows us to determine how many users have Pal installed and access Pal at the same time. This data is always anonymous and hence is not personal data. We cannot draw any conclusions about you from the access data that we collect in accordance with this section.

2.2. We use cookies, tokens and filters to make your usage of Pal more streamlined. These are small data packages that are stored and managed by you. Use of these cookies makes your use of Pal more streamlined, improves the functionality of Pal and, for example, personalizes your access. You can manage the use of cookies via your device settings at any time, including choosing to delete them, or prevent them from being used. Please note, however, that your use of Pal may be restricted if you do decide to disable cookies and some of the features of Pal may not work properly.

2.3. When you open Pal for the first time, you will be asked if Pal is allowed to send push notifications. If you allow this feature, we will send you push notifications, for example, to inform you about our news updates. Such push notifications are controlled by the software components of your operating system (so-called “tokens”). You can configure and turn our push notifications off via your device settings at any time.

2.4. If you want to permit location settings via Pal, you will be asked if Pal is allowed to access your location. If you allow this feature, we will determine your location to provide you with site-specific functions of Pal. You can configure and turn location settings off via your device settings at any time.

2.5. If you want to use other features of Pal, such as your microphone input, your camera or photo and video upload function, you will be asked if you want to use this function before using it for the first time. If you allow any such feature, you can use the corresponding function to perform the desired interaction on Pal. You can enable or disable access to these functions at any time via your device settings.

2.6. If you contact us for questions or feedback, we will process the details of your request and for follow-up queries.

3. Data processing - Pal account / profile

3.1. If you want to use the features of Pal, you need to create a Pal account and create a profile. You cannot use the features of Pal anonymously. To create a Pal account, you must register with your name and email address, or via your Facebook or Google profile and password. Please make sure to enter your real name and valid email address, or choose the log-in via Facebook or Google profile and choose a secure password. You must keep your password safe, and change it at regular intervals. As soon as your Pal account is created, you must be willing to voluntarily enter certain mandatory and other voluntary information about yourself in the input fields, or, if you prefer/have selected that option, to import such information from one of your social media profiles.

Please note that you will have the option to submit certain specific (and sensitive) types of personal data to us (e.g., racial or ethnic origin, political opinions, religious or philosophical convictions, trade union membership, health or details about your sexual life). As a general rule, any information that you submit to Pal is made public to other users. Therefore, please be careful, at all times, to enter only the information and content that you really want to share with other users or make public. If you enter any sensitive personal data, you explicitly consent to the fact that we may also collect, store and process this information according to applicable data protection law.

You can, of course, always view, edit, or share with other users any information, or delete this information at any time. If you want to change your name or e-mail address, you can contact us.

3.2. Once you are logged in to Pal, you will be able to use the features of Pal. You may, however, have to provide us with certain additional details to use additional features, for example when you purchase Pal Coins. In this event, we will of course point out to you what further data we require.

3.3. When you use Pal, we collect, store, and process all of your information (whether it be the information that you must supply to us to use Pal, other voluntary information that you choose to submit to Pal, IP address, shared device information, etc.) to allow you to personalize Pal and for Pal to tailor Pal as appropriately as possible to you. In addition to your data and content, we will also collect information about your use of Pal (e.g., your requests to other Pals, your set events or activities) as well as your interactions with us (e.g., contact requests).

4. Data processing - External services

For us to offer you all the functions of Pal, we use certain third party and external service providers and provide your personal data to them as follows:

4.1. We host Pal via our hosting partner AWS (Amazon Web Services, Inc., 410 Terry Avenue North, Seattle WA 98109, United States). We will provide AWS with the data that you have entered into your Pal account (whether it be the information that you must supply to us to use Pal or other voluntary information that you choose to submit to Pal), as well as data (e.g., Facebook or Google integrations) from the services you use. This data is hosted by AWS on our behalf on an AWS server within the European Union, so we can provide Pal to you and other users. This data is not visible to AWS and does not allow AWS to draw conclusions about you and your usage behavior. Further information on AWS can be found at https://aws.amazon.com.

4.2. If you permit them, we will send you push notifications. For this, we use OneSignal's push service (OneSignal Inc., 2194 Esperanca Avenue, Santa Clara, CA 95054, USA). We provide OneSignal with our identification number and the content of the push notification so that we can send you the push notification via OneSignal. Our identification number for you does not allow OneSignal to access your data and your usage behavior. More information about OneSignal can be found at https://onesignal.com/privacy_policy.

4.3. When you purchase Pal Coins, your in-app purchase will be billed by your app store provider (such as Apple or Google), your payment method (such as your credit card), and according to the payment terms of the relevent app store. Please note that as a rule we do not have any direct influence on the extent of the data that is transferred or transferred to us during payment processing. For more information about Apple Store privacy, visit https://www.apple.com/privacy/privacy-policy/ and visit Google at https://www.google.com/intl/en/policies/.

4.4. We also incorporate integrations from Facebook (Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA) and Google (Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA). Among other things, these Connect-features are there so you can log into Pal with one of your social media profiles. Please note that we generally do not have a direct impact on the amount of data that is or will be transferred to or from us through these integrations, depending on your account settings on the applicable social media platform. As far as we do have influence on the structure of the integrations, we collect, save and process your personal data only according to applicable data protection law. The login integrations only transfer the public profile information (e.g., profile, name, e-mail address, age, occupation, place of residence, gender) specified by you, as well as your automatic account identification numbers that are stored on the applicable site. We do not have access to your Facebook or Google profile, and cannot post anything to your timelines. For more information on the terms and conditions of use and your account settings, please visit Facebook at https://www.facebook.com/policy.php and go to Google at https://www.google.com/intl/en /policies /.

4.5. We also include Google Maps so you can use Pal's location-specific features (such as location suggestions). If you use Google Maps on Pal, it means that Google is processing the IP address of your device because Google will not be able to display the map view without it. We have no influence on how Google processes the IP address. For more information on Google privacy, please visit https://www.google.com/intl/en/policies/.

4.6. We also include Google Analytics, a Google web analytics program. Google Analytics allows us to analyze your use of Pal. The information that is generated is generally transferred to a Google server in the USA and stored there. With the IP anonymisation process, which we have activated, the acquired IP addresses will by shortened in advance by Google within the European Union. On our behalf, Google will use this information to evaluate the use of Pal by you and other users. Your IP address will not be merged with other Google data. You can also prevent the collection and processing of the information generated by Google Analytics by setting an opt-out cookie on the site or by disabling Google Analytics from the app or terminal's menu. For more information about Google's Terms of Service and privacy, visit https://www.google.com/intl/en/policies/.

4.7. If you store data in the app through a backup service such as iCloud, we have no influence over such service. Please make sure you are aware of the content of your cloud provider's privacy policy.

4.8. You can recommend Pal to your friends, for example via social media integrations, e-mail, SMS and WhatsApp. We would like to point out to you, however, that if you do this, your respective contact details and the recipient of your choice as well as your recommended content will be transmitted to the selected service provider, over which we have no influence. Please inform yourself about the nature and extent of this data transfer with the corresponding service provider (e.g., your e-mail or mobile service provider, WhatsApp etc.)

5. Amendment to our Privacy Policy

We reserve the right to change our Privacy Policy at any time. We will notify you of changes in advance, endeavouring to give you four weeks’ prior notice. If you do not object to the validity of the amended Privacy Policy within four weeks or if you use Pal after the Privacy Policy has been updated, or otherwise confirm the amended Privacy Policy, you are deemed to have agreed to be bound by the updated Privacy Policy. If you do not wish to accept the updated Privacy Policy you should not continue to use Pal.

6. Other notes and provisions

6.1. We collect, store and process your personal data only for as long as we are legally permitted to do so or with your consent. Past the legal storage period, your personal data will be permanently and irretrievably deleted or destroyed by us.

6.2. We may, in the future, be a party to a sale of some or all of our business, our assets or as part of any business restructuring or reorganisation and in relation to which your data may be transferred to the third party acquirer. If such a transaction occurs, we will take steps with the aim of ensuring that your rights under applicable data protection law continue to be protected.

6.3. The transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to Pal; any transmission is at your own risk.. Once we have received your data, we maintain appropriate security measures to protect your personal data including use of as strong, up-to-date and secure encryption techniques as possible for all data transmissions. Nevertheless, you should be careful not to pass your login data to third parties.

6.4. You may at any time, and without charge, request information about your personal data that we process , ask us to correct erroneous personal data or ask us to terminate the processing of your personal data or delete it - subject to compelling conflicting legal regulations or obligations that prohibit us from doing so. You can contact us at any time in writing or by e-mail at: Pal App Limited, Kemp House, 152 City Road, EC1V 2NX London, United Kingdom, or support@palapp.co.uk.

© Pal App Limited – as of August 2017