Privacy Policy

We at Trueflutter are committed to protecting your privacy. We have prepared this Privacy Policy to describe to you our practices regarding the personal data we collect from users of our Platform.

By signing up for Trueflutter and opting to use your email address or phone number, you are consenting to receive SMS and email communication from us regarding your account, updates, special offers, and promotions. You may opt-out of these communications at any time by updating your account settings or by following the unsubscribe instructions in the messages we send.

By using the Services, users consent to the collection and use of their Personal Data by us. You also represent to us that you have any and all authorizations necessary to use these Services including using them to process Personal Data. We collect and use the information you provide to us, including information obtained from your use of the Services. Also, we may use the information that we collect for our internal purposes to develop, tune, enhance, and improve our Services, and for advertising and marketing consistent with this Privacy Policy.

This privacy policy has been compiled to better serve those who are concerned with how their ‘Personal Data’ is being used online. Personal data means data which relate to a living individual who can be identified – (a) from those data, or (b) from those data and other information which is in the possession of, or is likely to come into the possession of, the data controller, and includes any expression of opinion about the individual and any indication of the intentions of the data controller or any other person in respect of the individual.

Please read our privacy policy carefully to get a clear understanding of how our Platform collects, uses, protects or otherwise handles users’ Personal Data.

This Privacy Policy is intended to inform users about how our Platform treats Personal Data that it processes about users. If users do not agree to any part of this Privacy Policy, then we cannot provide its Services to users and users should stop accessing our services.

By using the Services, You acknowledge, consent and agree that we may collect, process, and use the information that you provide to us and that such information shall only be used by us or third parties acting under our direction, pursuant to confidentiality agreements, to develop, tune, enhance, and improve the Services.

Although we may attempt to notify you when changes are made to this Privacy Policy, you are responsible for periodically reviewing any changes which may be made to the Policy. We may, in our sole discretion, modify or revise the Policy at any time, and you agree to be bound by such modifications or revisions.

1. 1. INFORMATION WE COLLECT: When you register with us, you provide us information about yourself – your full name email address, contact number, date of birth, other profile details, people you would like to meet and password. If you correspond with us by e-mail, we may retain the content of your e-mail messages, your e-mail address, and our responses. We also collect general information about your use of our services.
   2. INFORMATION WE COLLECT AUTOMATICALLY WHEN YOU USE OUR SERVICES: When you access or use our Services, we automatically collect information about you, including:
   3. Log Information: We log information about your use of our Platform, including your browser type and language, access times, pages viewed, your IP address and the Platform you visited before navigating to our Platform.
   4. 1. 1. Device Information: We may collect information about the device you use to access our Services, including the hardware model, operating system and version, unique device identifier, phone number, International Mobile Equipment Identity (“IMEI”) and mobile network information.
         2. Location Information: With your consent, we may collect information about the location of your device to facilitate your use of certain features of our Services, determine the speed at which your device is traveling, add location-based filters (such as local weather), and for any other purposes.
         3. Information Collected by Cookies and Other Tracking Technologies: We use various technologies to collect information, and this may include sending cookies to you. A “cookie” is a small data file transferred to your device’s hard drive that allows a Platform to respond to you as an individual, gathering and remembering information about your preferences in order to tailor its operation to your needs, likes and dislikes. Overall, cookies are safe, as they only identify your computer to customize your Web experience. Accepting a cookie does not provide us access to your computer or any Personal Data about you, other than the information you choose to share. Other servers cannot read them, nor can they be used to deliver a virus. Most browsers automatically accept cookies, but you can usually adjust yours (Microsoft Internet Explorer, Firefox or Google Chrome) to notify you of cookie placement requests, refuse certain cookies, or decline cookies completely. If you turn off cookies completely, there may be some Platform features that will not be available to you, and some Web pages may not display properly. To support the personalized features of our Platform (such as your country and language codes and browsing functions) we must send a cookie to your computer’s hard drive and/or use cookie-based authentication to identify you as a registered Platform user.

2. 4. INFORMATION SHARED DURING TRANSACTION:
3. 1. You agree that you will enter into transactions with third parties through our Platform and will share your personal data with them for easy completion of the transaction. You hereby expressly agree that we shall not be involved or held liable for any breach of the privacy or security of that data. The said breach, if any, shall be a matter of dispute between you and the third party and we shall not be held liable or be issued a notice for the same.
   2. We STRONGLY recommend that you should be careful and vigilant while disclosing your personal data with your transaction partner. Please do not disclose your bank and account details to anyone through our Platform or to any individual whom you have met through our Platform.
   3. We do not take credit card/debit card or other bank details on our Platform. For payment you will be directed to sign in through respective payment gateways and the transaction would be completed therein. It is to be noted that we will not be storing any Bank related information on our records and none of our staffs will hold or be exposed to this information.
   4. WE DO NOT ASK any user to share its personal information with another user. If you opt to do so, you shall solely be responsible for any damages or issues that accrue thereafter. WE SHALL IN NO CASE BE HELD LIABLE OR RESPONSIBLE IF YOU SHARE YOUR PERSONAL INFORMATION WITH ANY OTHER USER ON OUR PLATFORM.

1. 1. HOW WE USE YOUR INFORMATION:
      
      1. We use the personal information we collect to fulfill your requests for services, improve our services and contact you.
      2. By providing us your e-mail address, you consent to us using the e-mail address to send you our Platform and services related notices, including any notices required by law, in lieu of communication by postal mail. You also agree that we may send notifications of activity on our Platform to the e-mail address you give us, in accordance with any applicable privacy settings. We may use your e-mail address to send you other messages, such as newsletters, changes to our features, or other information. If you do not want to receive optional e-mail messages, you may modify your settings to opt out.
      3. Our settings may also allow you to adjust your communications preferences. If you do not wish to receive promotional email messages from us, you may opt out by following the unsubscribe instructions in those emails. If you opt out, you will still receive non-promotional emails from us about your account and our Services.
      4. Following termination or deactivation of your services, we may (but are under no obligation to) retain your information for archival purposes. We will not publicly disclose any of your personal data other than as described in this Privacy Policy.
      5. At our sole discretion, for any reason or no reason at all, we reserve the right to remove any content or messages, if we believe that such action is necessary (a) to conform to the law, comply with legal process served on us, or investigate, prevent, or take action regarding suspected or actual illegal activities; (b) to enforce this policy, to take precautions against liability, to investigate and defend ourselves against any third-party claims or allegations, to assist government enforcement agencies, or to protect the security or integrity of our Platform; or (c) to exercise or protect the rights, property, or personal safety of the Platform, our users, or others.

1. 1. HOW WE SHARE YOUR INFORMATION:
      
      1. As a matter of policy, we will not sell or rent information about you and we will not disclose information about you in a manner inconsistent with this Privacy Policy except as required by law or government regulation. We cooperate with law enforcement inquiries, as well as other third parties, to enforce laws such as those regarding intellectual property rights, fraud and other personal rights.
      2. We will not share the personal information we collect about you with any third party for their own marketing purposes without your consent. We have contract with third parties prohibiting them from sharing your personal data.
      3. If you do not agree with our Privacy Policy, Terms of Service or Cookie Policy, please discontinue use of our Service; your continued usage of the Service will signify your assent to and acceptance of our Privacy Policy and Terms of Use.
      4. WE CAN (AND YOU AUTHORIZE US TO) DISCLOSE ANY INFORMATION ABOUT YOU TO LAW ENFORCEMENT, OTHER GOVERNMENT OFFICIALS, ANY LAWSUIT OR ANY OTHER THIRD PARTY THAT WE, IN OUR SOLE DISCRETION, BELIEVE NECESSARY OR APPROPRIATE IN CONNECTION WITH AN INVESTIGATION OF FRAUD, INTELLECTUAL PROPERTY INFRINGEMENT, OR OTHER ACTIVITY THAT IS ILLEGAL OR MAY EXPOSE US, OR YOU, TO LIABILITY.

1. 1. ENSURING INFORMATION IS ACCURATE AND UP-TO-DATE
      
      1. We take reasonable precautions to ensure that the Personal Data we Collect, Use and Disclose is complete, relevant and up-to-date. However, the accuracy of that information depends to a large extent on the information you provide. That’s why we recommend that you:
      2. Let us know if there are any errors in your Personal Data; and
      3. Keep us up-to-date with changes to your Personal Data such as your name or address.

1. 1. HOW WE PROTECT YOUR INFORMATION:
      
      1. We are very concerned about safeguarding the confidentiality of your personal data. We employ administrative, physical and electronic measures designed to protect your information from unauthorized access.
      2. By using this Platform or the Services or providing Personal Information to us, you agree that we can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of this Platform or Services.
      3. We use commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your Personal Information. We cannot, however, ensure or warrant the security of any information you transmit to us and you do so at your own risk. Once we receive your transmission of information, we make commercially reasonable efforts to ensure the security of our systems. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. If we learn of a security systems breach, then we may attempt to notify you electronically so that you can take appropriate protective steps.
      4. Notwithstanding anything to the contrary in this Policy, we may preserve or disclose your information if we believe that it is reasonably necessary to comply with a law, regulation or legal request; to protect the safety of any person; to address fraud, security or technical issues; or to protect our rights or property. However, nothing in this Policy is intended to limit any legal defenses or objections that you may have to a third party, including a government’s, request to disclose your information.

1. 1. YOUR CHOICES ABOUT YOUR INFORMATION:
      1. You have several choices regarding use of information on our Services:
         
         1. Email Communications: We will periodically send you free newsletters and e- mails that directly promote the use of our Platform, or Services. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly. Despite your indicated e-mail preferences, we may send you service related communications, including notices of any updates to our Terms of Use or Privacy Policy.
         2. Changing or Deleting Your Personal Data: You may change any of your personal information by visiting the Platform and following the directions therein or by emailing us at hello@trueflutter.com . You may delete your personal information by following the steps (1). Login to the Trueflutter app (2) Click on your profile icon on the lower right of the screen (3) Click on the ‘Account’ tab (4) Scroll down and click on ‘Delete Account’. Once these steps are followed, all your data is permanently removed from our database. You may also email hello@trueflutter to request deletion of your personal data by us, and we will use commercially reasonable efforts to honor your request.
         3. You may, of course, decline to submit personal data through the Platform, in which case, we may not be able to provide our services to you. You can review and correct the information about you that we keep on file by editing your account settings or by contacting us directly at hello@trueflutter.com

1. 1. RIGHTS OF THE DATA SUBJECT
      1. Right of confirmation

Each data subject shall have the right granted by the European legislators to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact any employee of the controller.

1. 1. 1. Right of access

Each data subject shall have the right granted by the European legislators to obtain from the controller free information about his or her personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:

1. 1. 1. 1. the purposes of the processing;
         2. the categories of personal data concerned;
         3. the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;
         4. where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
         5. the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;
         6. the existence of the right to lodge a complaint with a supervisory authority;
         7. where the personal data are not collected from the data subject, any available information as to their source;
         8. the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.
         9. Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organization. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer. If a data subject wishes to avail himself of this right of access, he or she may, at any time, contact any employee of the controller.
      2. Right to rectification

Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement. If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact any employee of the controller.

1. 1. 1. Right to erasure (Right to be forgotten)

Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:

1. 1. 1. 1. The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
         2. The data subject withdraws consent to which the processing is based according to the point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.
         3. The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
         4. The personal data have been unlawfully processed.
         5. The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
         6. The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.
         7. If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by us, he or she may, at any time, contact us by emailing hello@trueflutter.com with the request for their data to be completely erased. Our team shall promptly ensure that the erasure request is complied with immediately.
         8. Where the controller has made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. Any of our employees will arrange the necessary measures in individual cases.
      2. Right of restriction of processing
         1. Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:
            
            1. The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data. The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead of the restriction of their use instead. The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims. The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject. If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by us, he or she may at any time contact any employee of the controller. Our Employees will arrange the restriction of the processing.
      3. Right to data portability
         1. Each data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
         2. Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.
         3. In order to assert the right to data portability, the data subject may at any time contact any of our employee.
      4. Right to object
         1. Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions. We shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the data subject, or for the establishment, exercise or defence of legal claims. If we process personal data for direct marketing purposes, the data subject shall have the right to object at any time to the processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects us to the processing for direct marketing purposes, we will no longer process the personal data for these purposes. In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by us for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
         2. In order to exercise the right to object, the data subject may contact us. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.
      5. Automated individual decision-making, including profiling
         1. Each data subject shall have the right granted by the European legislators not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is not based on the data subject’s explicit consent. If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject’s explicit consent, we shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision.
         2. If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may, at any time, contact any our employee.
      6. Right to withdraw data protection consent
         1. Each data subject shall have the right granted by the European legislator to withdraw his or her consent to the processing of his or her personal data at any time.
         2. If the data subject wishes to exercise the right to withdraw the consent, he or she may, at any time, contact any of our employees.
      7. Right to request access

You also have a right to access information we hold about you. We are happy to provide you with details of your Personal Information that we hold or process. To protect your personal information, we follow set storage and disclosure procedures, which mean that we will require proof of identity from you prior to disclosing such information. You can exercise this right at any time by contacting us on the above details.

1. 1. 1. Right to withdraw consent

Where the legal basis for processing your personal information is your consent, you have the right to withdraw that consent at any time by contacting us on the above details

1. 1. STORING PERSONAL DATA

We retain your information only for as long as is necessary for the purposes for which we process the information as set out in this policy. However, we may retain your Personal Data for a longer period of time where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

1. 1. CHILDREN’S PRIVACY:

Protecting the privacy of young children is especially important. Thus, we do not knowingly collect or solicit personal information from anyone under the age of 18 or knowingly allow such persons to register. If you are under 18, please do not attempt to register for the Service or send any information about yourself to us, including your name, address, telephone number, or email address. No one under age 18 may provide any personal data for accessing the Service. In the event that we learn that we have collected personal data from a child under age 18, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 18, please contact us.

1. 1. MERGER AND ACQUISITIONS:

In case of a merger or acquisition, we reserve the right to transfer all the information, including personal data, stored with us to the new entity or company thus formed. Any change in the Platform’s policies and standing will be notified to you through email.

1. 1. LINKS TO THIRD PARTY PLATFORMS:

Our Platform contains links to other Platforms. The fact that we link to a Platform is not an endorsement, authorization or representation of our affiliation with that third party. We do not exercise control over third party Platforms. These other Platforms may place their own cookies or other files on your computer, collect data or solicit personally identifiable information from you. Other Apps follow different rules regarding the use or disclosure of the personally identifiable information you submit to them. We encourage you to read the privacy policies or statements of the other Platforms you visit.

1. 1. NOTIFICATION PROCEDURES:

It is our policy to provide notifications, whether such notifications are required by law or are for marketing or other business related purposes, to you via e-mail notice, written or hard copy notice, or through conspicuous posting of such notice on the Platform, as determined by us in our sole discretion. We reserve the right to determine the form and means of providing notifications to you, provided that you may opt out of certain means of notification as described in this Privacy Policy.

1. 1. DO NOT TRACK:
      1. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform Platform and services that they do not want certain information about their webpage visits collected over time and across Platforms or online services.
      2. We are committed to providing you with meaningful choices about the information collected on our Platform for third party purposes, and that is why we provide the opt-out links. However, we do not recognize or respond to browser-initiated DNT signals, as the Internet industry is currently still working toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT.

1. 1. OPTING OUT OF INFORMATION SHARING
      1. We understand and respect that not all users may want to allow us to share their information. If you do not want us to share your information, please contact us through the Platform and we will remove your information as soon as reasonably practicable. When contacting us, please clearly state your request, including your name, mailing address, email address and phone number.
      2. However, under the following circumstances, we may still be required to share your personal information:
         
         1. if we are responding to court orders or legal process, or if we need to establish or exercise our legal rights or defend against legal claims.
         2. If we believe it is necessary to share information in order to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms of Use or as otherwise required by law.
         3. If we believe it is necessary to restrict or inhibit any user from using any of our App, including, without limitation, by means of “hacking” or defacing any portion thereof.

1. 1. PHISHING OR FALSE EMAILS:

If you receive an unsolicited email that appears to be from us or one of our members that requests personal data (such as your credit card, login, or password), or that asks you to verify or confirm your account or other personal information by clicking on a link, or to provide your personal information to any other user that email was likely to have been sent by someone trying to unlawfully obtain your information, sometimes referred to as a “phisher” or “spoofer.” We do not ask for this type of information in an email. Do not provide the information or click on the link.  Please contact us on the contact details provided on the Platform if you get an email like this.

1. 1. CHANGES TO OUR PRIVACY POLICY:
      1. We may update this Privacy Policy and information security procedures from time to time. If these privacy and/or information security procedures materially change at any time in the future, we will post the new changes conspicuously on the Platform to notify you and provide you with the ability to opt out in accordance with the provisions set forth above.
      2. Continued use of our Platform and Service, following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.

1. 1. BREACH OF PRIVACY POLICY

We reserve the right to terminate or suspend any account or delete certain contents from any profile or public domain within the ambit of this Platform if the said account or content is found to be in violation of our privacy policy. We sincerely request you to respect privacy and secrecy concerns of others. The jurisdiction of any breach or dispute shall be determined in accordance with the terms of use of the Platform.

1. 1. NO RESERVATIONS:

We do not accept any reservation or any type of limited acceptance of our privacy policy. You expressly agree to each and every term and condition as stipulated in this policy without any exception whatsoever.

1. 1. NO CONFLICT:

The policy constitutes a part of the user terms. We have taken utmost care to avoid any inconsistency or conflict of this policy with any other terms, agreements or guidelines available on our Platform. In case there exists a conflict, we request you to kindly contact us for the final provision and interpretation.

1. 1. CONTACT US:

If you have any questions about this Privacy Policy, our practices relating to the Platform, or your dealings with us, please contact us at hello@trueflutter.com