Welcome to the Fingle Privacy Policy (“Policy”)! This explains how we collect, store, protect, and share your
information, and with whom we share it.
Whilst you’re enjoying the Fingle mobile application (including the desktop version) (“App”), our websites and
microsites (such as fingle.in) or using our digital products and services (such as our competitions or surveys)
(together, referred to in this Privacy Policy as our “Sites”), we collect some information about you. In
addition, you may choose to use the App or Sites to share information with other users, including your friends
and contacts (“Users”). We may also need to share your information sometimes.
The App and Sites are global, and your information will be sent to and used in the United States and the UK
regardless of the country you reside in. This Policy explains how we protect your personal data when we transfer
it overseas, so please read very carefully!
Who we are
The App and Sites are operated by the “Fingle Group” (also referred to in this policy as “we” or “us”) which
includes Fingle Holding Limited, Badoo Trading Limited and Fingle Trading LLC, all of which are controllers of
personal information collected and processed through the Fingle App and Sites.
The Fingle Group has designated a Data Protection Officer and they can be reached by emailing
DPO@team.fingle.in or by post at the following address: The Broadgate Tower Third Floor, 20 Primrose Street,
London, United Kingdom, EC2A 2RS.
1. COLLECTION OF INFORMATION.
Registration Information
When you download the App and create an account (“Account”), we may collect certain information (“Registration
Information”) about you, such as:
• Name;
• Username;
• Email address;
• Cell number;
• Gender identity;
• Date of birth;
• Sexual preference;
• Photographs;
• Location; and
• Login information for social media accounts that you connect to your Fingle Account (this could
include, for
example, your Facebook and Instagram accounts). For more information about this, see “Linking other Accounts to
Fingle” in section 7 below.
Once you register, you will be able to review and change this information at any time just by logging in to
Fingle (other than your date of birth and location (which, if you have given Fingle access to your location in
your device settings, is automatically updated based on the location of your device)). It is your responsibility
to ensure that your account details are kept up to date. If your phone number changes, please ensure that you
update this in your account.
The information we collect helps to enhance the App and verify our Users (robots are not welcome!). Registration
Information such as your sexual preference, name and username may be visible to other Users who view your
profile page.
For Users who are California residents, the data we may collect falls within the following categories of
“personal information”, as defined by the California Consumer Privacy Act (CCPA):
• A. Identifiers, such as name and location;
• B. Personal information, as defined in the California customer records law, such as contact
(including email and
telephone number) and financial information;
• C. Characteristics of protected classifications under California or federal law (if you choose to
provide them),
such as age, gender identity, marital status, sexual orientation, race, ancestry, national origin, religion, and
medical conditions;
• D. Commercial information, such as transaction information and purchase history;
• E. Biometric information;
• F. Internet or network activity information, such as browsing history and interactions with our
Sites and App;
• G. Geolocation data, such as mobile device location;
• H. Audio, electronic, visual and similar information, such as photos and videos;
• I. Professional or employment-related information, such as work history and prior employer;
• J. Non-public education information; and
• K. Inferences drawn from any of the personal information listed above to create a profile or
summary about, for
example, an individual’s preferences and characteristics.
Profile Information
We recommend and encourage you (and all our members) to think carefully about the information you disclose about
yourself. We also do not recommend that you put email addresses, URLs, instant messaging details, phone numbers,
full names or addresses, credit card details, national identity numbers, drivers’ license details and other
sensitive information which is open to abuse and misuse on your profile.
When you post information about yourself or use the messaging function to communicate with other Users, the
amount of personal information you share is at your own risk. Please see Section 4 below for more information on
who can access what you post on Fingle.
Profile Verification Information (Including Biometric Information)
For safety and security and to ensure you have the best possible user experience, we require Users to verify
their accounts and might ask for your phone number and, in some instances, we might also ask that you carry out
photo verification. We want to make sure you are not a robot! And we also want to avoid fake Fingle accounts
being created which can be used for malicious activities and cybercrime – they threaten the Fingle network and
spoil things for everyone. This verification might be required by us for the prevention of fraud. You can also
verify your photo on a voluntary basis (to add the blue ‘verified’ badge to your profile).
If you choose to verify your profile photo, we will scan each photo that you submit. The scan may include the
use of facial recognition technology so that we can compare the photo you submit to your profile photo, to help
ensure that you are who you say you are. We do not add the verification photos to your profile. We retain the
scans so that we can verify you in the future and for our record-keeping purposes until we no longer need them
for such purposes or for three years after your last interaction with us, whichever occurs first. After the
applicable retention period expires, we take commercially reasonable steps to permanently and securely delete
the scans from our systems.
Purchases Information
If you decide to purchase any of our premium services, we will process your payment information and retain this
securely for the prevention of fraud and for audit/tax purposes.
Fingle uses automated decisions to prevent fraudulent payment transactions being processed as part of its
anti-fraud procedures. In order to do this, our systems check payment transactions for behavior that indicates
breaches of our Terms and Conditions of Use. If a transaction meets certain criteria that demonstrate that the
Terms and Conditions of Use are likely to have been breached and the transaction is likely to be fraudulent, the
relevant transaction may automatically be blocked. Where a transaction is blocked, the user will be notified
that their transaction cannot be processed and affected Users can contact Fingle to contest the decision.
Please note that if your account is blocked for any reason, any account(s) that you have on other Fingle Group
platforms/applications, such as Badoo, may also be blocked as part of our anti-spam and anti-fraud procedures.
Geolocation Information
If you have given Fingle access to your location in your device settings, when you use your cell, we will
collect information about WiFi access points as well as other location information about your longitude and
latitude and may save your device’s coordinates to offer certain features to you. This information helps us
identify your physical location and we use it to personalize the App and make it easier for you to interact with
other Users, by enabling the general locality information to be displayed to Users seeing your profile and
showing you the profiles of other Users who are near you.
If you have given Fingle access to your location, but wish to turn this off, you can do so by the following
methods:
1). iPhone app — settings, privacy, location services, Fingle
2). Android — settings, location, Fingle, permissions, location
Device Information
We may collect information about your device when you use the App including the unique device identifier, device
model, and operating system, for a number of purposes, as set out in this policy. In addition, if you permit us
to do so, the App may access your device’s address book solely in order to add someone to your contacts.
Links
We may keep track of how you interact with links available on Fingle including third party services by
redirecting clicks or through other means. We may share aggregate click statistics such as how many times a
particular link was clicked on.
Messages
We review the content of messages sent in the App to identify topics, sentiments, and trends across our Users.
We will take steps to remove personally identifying information from such messages, prior to reviewing them. We
will not share the content of User messages or information we derive from them with any third party.
Fingle Success Stories, Surveys and other Contributions
From time to time, we run surveys for research purposes and we may contact you to find out if you would like to
take part. We may also contact you to find out if you would like to provide feedback, a testimonial or take part
in marketing campaigns (for example, if you let us know that you have found a match on the App, we may contact
you to ask if you would be happy to feature in advertising for Fingle). Such surveys and marketing campaigns are
optional and more information will be provided at the point of contact. If you do not wish to be contacted to
take part in a survey or marketing campaign, please contact our Customer Support Team via our Feedback Page.
When you Contact Customer Support
If you contact our Customer Support team via our Feedback Page, we will receive your email address, and may
track your IP address, as well as the information you send to us to help resolve your query. We will keep
records of our communications with you, including any complaints that we receive from you about other Users (and
from other Users about you) for 6 years after deletion of your account.
Cookies and similar technologies
When you visit our Sites or when you use our App, we may collect personal data from you automatically by using
cookies or similar technologies. A cookie is a small file that can be placed on your device or browser that
allows us to recognize and remember you.
If you would like to find out more about cookies, including how we use them and what choices are available to
you, please refer to our Cookie Policy.
2. USE OF YOUR INFORMATION.
Our main goal is to ensure your experience on Fingle is an enjoyable one and you don’t end up getting stung! In
order to deliver an enjoyable experience to you, we may use your Registration and other information to:
• offer you our services and features;
• contact you with information about the App (e.g., updates and new features);
• personalize the App/Sites and the content we deliver to you;
• conduct research and analytics about how you use and interact with the App/Sites;
• to test new technologies and processes designed to enhance and improve the App/Sites;
• resolve disputes, troubleshoot problems and to enforce our Terms & Conditions;
• investigate fraud, protect our legal rights, and to enforce our Terms & Conditions.
• to send you information about the promotions and offers we have available (e.g., specify the
types of
goods/services/offers to be provided via direct marketing) by direct marketing or other modes of communication -
if you’ve signed up for our communications or otherwise told us it’s OK. We will not use your information in
email direct marketing unless you give us your consent during the Account creating process or via Settings in
the App (you can withdraw from marketing at any time via Settings in the App or by using the opt-out mechanisms
and links provided in each message); and
• protect our Users and third parties from harm.
Our Matching Algorithms
We have developed matching algorithms to predict your compatibility with other users and so we can show you
people we think are a good match for you. Our matching algorithms use the following data about you to predict
your compatibility with others and generate profile recommendations: the things you tell us about yourself in
your profile; information about your activity in our apps; whether you are a photo verified user; and your
device coordinates, which are necessary to understand your proximity to other members. The legal basis for
processing profile and proximity information is that this is necessary for the provision of our contractual
services to you pursuant to Article 6(1)(b) GDPR. Where we process information about your app activity, this is
based on our legitimate interests pursuant to Article 6(1)(f) GDPR, and specifically our legitimate interest in
generating more personalized and relevant recommendations for who you can match with in our App. If you have
chosen to include sensitive information in your profile, such as information about your beliefs, the processing
of this information is based on your voluntary and explicit consent.
Moderation Practices
We use a combination of automated systems and a team of moderators to monitor and review accounts (including
photos and any other information uploaded onto user profiles) and messages for content that indicates breaches
of our Terms and Conditions of Use. If an account or message meets certain criteria that demonstrate that the
Terms and Conditions of Use are likely to have been breached, the relevant account will be subject to a warning
and the user’s access restricted and/or blocked. Affected Users can contact Fingle to contest the decision.
If you post anything that is inconsistent with our Terms and Conditions of Use, we reserve the right to
terminate or restrict access to your Account.
Processing We Perform To Improve Services For Students
What we’re doing. We process personal data to understand which of our users may be in college or university. To
do this, we look at historic location data to understand whether your device’s coordinates match to a general
university or college area. For this activity, we use recent historic data regarding where you opened the Fingle
app and we’ll keep a simple “at campus yes/no” result based on our findings. What we don’t do. We do not track
your real-time movements as part of this activity and we do not identify or store information about where you
are studying. To protect your privacy, we do not retain any of the location data used for this activity and it
is permanently deleted once the results are generated. Why we’re doing this. We’ll combine the results of this
processing with other relevant information we hold for the following purposes: so we can send the right offers,
events and features to the right users; to understand which Fingle events are popular with the student
demographic and which aren’t working so well; and to improve the design of the App to meet the needs of
students. The legal basis for this processing is our legitimate interests. We have a legitimate interest in
providing a more tailored app experience for student users and in optimizing their chances of finding the right
connections. Please note this processing only affects Fingle App users who identified the United States or
Canada as their location when registering for the App (we exclude users in Quebec) and who are in the 18 to 24
age group.
3. DISCLOSURE OF INFORMATION.
Our policy is to not disclose your Registration Information or personal data, except in the limited
circumstances described here:
Circumstances where data may be disclosed Disclosed data
Service Providers – We engage certain trusted third parties to perform functions and provide services to us. We
may share your Registration Information or personal data with these third parties, but only for the purposes of
performing these functions and providing such services. More information about this is available directly below.
This could include all data, including all CCPA Categories listed above
Moderators – To monitor activity on the App and approve content. Name and user registration details, profile
information, content of messages and photographs (CCPA Categories A, B, C, and H)
Payment Processing and Telecommunications Companies – To facilitate payments for our premium services.
Cardholder name, cardholder address, card number, payment amount, transaction date/time (CCPA Categories A, B,
and D)
Law and Harm – As we mentioned in the Terms & Conditions, we think it is very important that all Users behave
whilst using the App. We will cooperate with all third parties to enforce their intellectual property or other
rights. We will cooperate with lawfully made law enforcement requests for information from within or outside
your country of residence where we are required to by law. This may include where there is an investigation into
alleged criminal behavior or to protect the vital interests of a person. We may preserve or disclose any of your
information, including your Registration Information, if we believe in good faith that it is necessary to comply
with a law or regulation, or when we believe in good faith that disclosure is necessary:
to comply with a binding direction court order, or lawful request;
to protect the safety of any person;
to address fraud, security or technical issues e.g. through anti-spam providers to protect the service from
criminal activity; or
to protect our rights or property or those of third parties.
In such cases we may raise or waive any legal objection or right available to us. This could include any
personal data that Fingle holds about you, depending on the nature of the request or the issue that we are
dealing with, including all CCPA Categories listed above
Business Transfers – In the event that a Fingle Group entity or any of its affiliates undergoes a business
transition or change of ownership, such as a merger, acquisition by another company, re-organization, 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. This could include all personal data that Fingle holds about you, including all CCPA
Categories listed above
Marketing Services Providers – To help us serve marketing and advertising on third party websites and
applications and measure the effectiveness of our advertising campaigns. More information on this is available
below Advertising identifier associated with your device (Device ID), estimated location (based on your IP
address), age, gender and data about your visit to our Sites or App and action taken on those (for example if
you downloaded our App or created an account with our App), hashed email address (for ‘custom audiences’ only)
(CCPA Categories B, C, G, F and K)
Anti-Spam and Anti-Fraud – Your data may be shared with other Fingle Group companies, for example, to block
accounts and suspected fraudulent payment transactions as part of our anti-spam and anti-fraud procedures. Email
address, phone number, IP address and IP session information, social network ID, username, user agent string,
and transaction and payment data (CCPA Categories B, F and D).
Aggregated Information – We may share aggregated information with third parties that includes your personal data
(but which doesn’t identify you directly) together with other information including log data for industry
analysis and demographic profiling.
MORE INFORMATION ABOUT DISCLOSURES
Service Providers
We engage certain trusted third parties to perform functions and provide services to us (“Service Providers”).
The suppliers with which Fingle shares User personal data vary depending on a variety of factors, such as which
of our App, Sites and services a User engages with. For example, to provide our services to Users, we typically
use the following suppliers:
Billing services – to allow customers to purchase paid features of our App (for example, Google Play)
Authentication services – to allow customers to authenticate their account (for example, Twilio)
Social media providers – to allow customers to create/connect their Fingle account with their account(s) on such
platforms (for example Facebook, Instagram or Spotify)
Product improvement and market research – we use third party platforms (such as Typeform) and agencies (such as
Kantar) to carry out customer surveys and market research to improve our products and services
IT services – some of the third-party software providers used in the operation of our business may process
Users’ personal data (for example, if a User contacts us via social media with a support inquiry, their inquiry
is processed by our community management software provider Khoros)
We carry out due diligence on all Service Providers we engage to ensure they have adequate data protection and
information security measures in place and only provide them with the personal data necessary to the service
they are providing. Measures are taken to ensure that the data shared is non-attributable to the greatest extent
possible and our suppliers are also subject to extensive obligations under our contractual arrangements,
including strict data retention limits.
Marketing Services Providers
We partner with providers of marketing services (such as Facebook for example) (‘Marketing Services Providers’)
to help us market and advertise our App and services on third party websites and applications and measure the
effectiveness of our advertising campaigns. For example:
to exclude you from advertising campaigns aimed at finding new users, if you already have a Fingle account;
to show Fingle adverts to users who have visited the Fingle App/Sites but haven’t yet created a Fingle account;
to create an audience for our advertisements of other potential users who have similar characteristics to you
based on the information the Marketing Service Providers holds about you (also known as a Lookalike Audience);
or
to include you in a ‘custom audience’ that will receive Fingle advertising content (a custom audience is
essentially a list of people who we think are most likely to be interested in a particular advertisement).
We share a limited amount of your personal data with these Marketing Services Providers, such as:
the advertising identifier associated with your device (this is a random number assigned by your mobile device
manufacturer (for example Apple or Google) to your device to help advertisers (including the manufacturer) know
when an ad has been viewed or clicked in an app, and when an ad causes a ‘conversion’ (for example, downloading
the app advertised to you))
your estimated location (based on your IP address)
age and gender
data about your visit to our Sites or App and action taken on those (for example if you downloaded our App or
created an account with our App)
a hashed* version of your email address (to create ‘custom audiences’).
*Hashing is a way of encrypting information by turning it into a combination of random numbers and letters -
this code cannot be traced back to the email address. When hashed email addresses are sent to a Marketing
Service Provider, they’re then matched against the Provider’s own existing list of their own users’ hashed
information and our ads are served to those of our users who have successfully been matched with the Provider’s.
Matched and unmatched hashes are then deleted by the Provider.
For more information about how we use cookies and other tracking technologies, including how you can set and
manage your preferences with regards to such technologies, please see our Cookie Policy.
In some cases, these third parties will also use the data that they collect for their own purposes, for example
they may aggregate your data with other data they hold and use this to inform advertising related services
provided to other clients.
Facebook
Where we share data with Facebook as our Marketing Service Provider (including via the Facebook “Like”
function), we are Joint Data Controllers with Facebook Ireland for this processing. This arrangement means that
Fingle has to provide you this notice, but you should contact Facebook if you wish to exercise your data
protection rights. Further information, including how Facebook enables you to exercise your data protection
rights, and subsequently processes your information as independent data controller can be found in Facebook
Ireland’s Data Policy. If you want more information relating to the nature of the arrangement we have in place
with Facebook, please email DPO@team.fingle.in.
This data referred to above can include actions that you take on our website such as your interactions with our
Sites or other information collected from cookies or similar technologies including the Facebook pixel. This
allows us to measure the effectiveness of our advertising, improve our marketing practices, and helps us deliver
more relevant advertising to you and people like you (including on social media such as Facebook).
4. WHAT OTHERS MAY SEE ABOUT YOU.
We think our Users are awesome, and we want you to share how awesome you are with the world, so we have built
certain features to enable this. Our App is designed to make it easier for you to connect with other Users and
to interact with them.
When using the Fingle App, you should assume that anything you post or submit on the App may be
publicly-viewable and accessible, both by Users and non-users of the App. We want our Users to be careful about
posting information that may eventually be made public.
Please be careful about posting sensitive details about yourself on your profile such as your religious
denomination and health details. You may also choose to add sensitive information about yourself when you add
certain Fingle badges to your profile, such as your religion and political leanings. While you may voluntarily
provide this information to us when you create your profile, including your sexual preferences, there is no
requirement to do so. Please remember that photographs that you post on Fingle may reveal information about
yourself as well. Where you do upload and choose to tell us sensitive information about yourself, including
through the addition of badges to your profile, you are explicitly consenting to our processing of this
information and making it public to other Users.
Your Fingle profile and other information you make available via the App, including certain information added to
your profile through third party accounts (such as Facebook, Instagram or Spotify – see section 7 of this
Privacy Policy for more information about this) may be viewed and shared by Users with individuals who may or
may not be users of the App. For example, a User may recommend you as a match to his or her Facebook friend(s)
by taking a screenshot of your profile picture and sharing it, regardless of whether such friend(s) is also a
User of the App.
Please also note that in certain countries (currently, South Korea only), Users are provided with functionality
enabling them to download a copy of their conversation history (as this is required by local laws) and that
Fingle has no control over how users may then publish or use that information.
If you log in to or access the App through your Facebook account or another third-party account on a device
which you share with others, remember to log out of the App and the relevant third-party account when you leave
the device in order to prevent other users from accessing your Fingle account.
5. OUR POLICY TOWARDS AGE.
Although we want as many people as possible to enjoy our creation, you have to be at least 18 years old to use
the App - sorry kids, we know Fingle is cool, but you’ll have to come back when you’re old enough!
Fingle does not knowingly collect any information about or market to children, minors or anyone under the age of
18. If you are less than 18 years old, we request that you do not submit information to us. If we become aware
that a child, minor or anyone under the age of 18 has registered with us and provided us with personal
information, we will take steps to terminate that person’s registration.
6. SECURITY
Here at Fingle, we pride ourselves on taking all appropriate security measures to help protect your information
against loss, misuse and unauthorized access, or disclosure. We use reasonable security measures to safeguard
the confidentiality of your personal information such as secured servers using firewalls.
Unfortunately, no website or Internet transmission is ever completely 100% secure and even we cannot guarantee
that unauthorized access, hacking, data loss or other breaches will never occur, but here are some handy tips to
help keep your data secure:
Please make sure you log out of your Account after use as you never know who may stumble onto your Account!
Please don’t share the password you use to access your Fingle Account with anyone else!
Change your password periodically.
If you ever think someone has had access to your password or Account, please follow the steps set out here. We
cannot guarantee the security of your personal data while it is being transmitted to our site and any
transmission is at your own risk.
7. LINKING OTHER ACCOUNTS TO Fingle.
Using your social media details to sign in to Fingle
When you sign in to our App using your Facebook account, you give permission to Facebook to share with us your
name and profile picture. Unless you opt-out, you also give permission to Facebook to share with us your email
address (if there is one associated with your Facebook account), date of birth, profile photos, gender, Page
likes and current town/city.
If you register or sign in with your Apple ID, you give Apple permission to share your Apple login, a name (that
can be edited by you) and an email (you can choose to hide your email and Apple will create a random email
address so your personal email can stay private). This email address will be linked to your Fingle account and
will be used to retrieve your Fingle account.
We will then use this personal data to form your Fingle account. If you remove the Fingle app from your Facebook
settings, or from your Apple ID, we will no longer have access to this data. However, we will still have the
personal data that we received when you first set up your Fingle account using your Facebook or Apple ID (you
must delete your Fingle account entirely for us to no longer have access to this data).
Linking social media accounts to your Fingle account
You may link your Fingle account with your Instagram, Facebook or Spotify accounts. This allows you to share
some information from those accounts directly to your Fingle account (for example, Instagram photos, or your top
Spotify artists).
We only receive the limited information that Instagram or Spotify permits to be transferred (as detailed by
Instagram/Facebook/Spotify and agreed by you when you first connect your account from such platforms with your
Fingle account).
If you no longer want to link your Fingle account to your Instagram, Facebook or Spotify account, please visit
the settings in your Instagram, Facebook or Spotify account and follow the instructions to remove the Fingle app
access permissions. Please note that any information already added to your Fingle account from those platforms
will not be deleted unless you delete it within your Fingle account as well.
8. INFORMATION FOR BFF MEMBERS.
If you use BFF, you can populate your profile with information (like your beliefs and political leanings). You
can provide this information as part of your profile, but there’s no obligation to do so.
You should assume that whatever information you share in BFF, including which Hives you’ve joined, can be seen
by any BFF member. Please note BFF members will not be able to see chat discussions until they join the specific
chat and when they join, they’ll see the full chat history.
How we process personal data in BFF and our legal bases for processing
We offer the opportunity in BFF to join Hives built around locations or topics. We’ll automatically recommend
Hives you can join based on your location, activity, “my life” and “my interests” information.
The processing of your location data is necessary in order to perform our contract with you and deliver the
Hives service to you.
The processing of your profile and activity information in order to make Hive recommendations is based on our
legitimate interests. It is in our legitimate interests to use this information to recommend relevant Hives to
you.
Please note that if you upload and choose to share sensitive information (such as sexuality and beliefs), you
are explicitly consenting to sharing that information with other BFF members.
Profile Sharing on Our Fingle For Friends App
If you are a member of BFF, your BFF profile will automatically be visible both on BFF mode in Fingle and on our
separate app, Fingle For Friends. Fingle For Friends is a separate app for finding friendship and is owned by
Fingle Group. We automatically show BFF profiles both on BFF mode in Fingle and on our Fingle For Friends app to
provide you with a richer pool of potential friends to connect with. Please note that this profile sharing only
applies to BFF members in the jurisdictions where our Fingle For Friends app is available. If you object to your
BFF profile being shown on our Fingle For Friends app, please see this help page.
9. YOUR CALIFORNIA PRIVACY RIGHTS.
For Users who are California residents, you have the following rights (in addition to those listed at section 10
below) under the California Consumer Privacy Act, and you have the right to be free from unlawful discrimination
for exercising your rights under the Act:
You have the right to request that we disclose certain information to you and explain how we have collected,
used and shared your personal information over the past 12 months.
You have the right to request that we delete your personal information that we collected from you, subject to
certain exceptions.
California’s “Shine the Light” law, Civil Code section 1798.83, requires certain businesses to respond to
requests from California customers asking about the businesses’ practices related to disclosing personal
information to third parties for the third parties’ direct marketing purposes. If you wish to find out about any
rights you may have under California Civil Code section 1798.83, you can write to us at
feedback@team.fingle.in.
From time to time, as part of a joint promotion with a third party, we may, if you participate in such
promotion, disclose your contact information to the third party to allow them to market their products or
services to you. Where this is a condition for participation in a promotion, we will always let you know before
when you enter the promotion. Please follow the instructions provided to you by third parties to unsubscribe
from their messages.
In addition, under California law, operators of online services are required to disclose how they respond to “do
not track” signals or other similar mechanisms that provide consumers the ability to exercise choice regarding
the collection of personal information of a consumer over time and across third party online services, to the
extent the operator engages in that collection. At this time, we do not track our Users’ personal information
over time and across third-party online services. This law also requires operators of online services to
disclose whether third parties may collect personal information about their users’ online activities over time
and across different online services when the users use the operator’s service. We do not knowingly permit third
parties to collect personal information about an individual User’s online activities over time and across
different online services when using the App.
10. YOUR RIGHTS.
Privacy laws applicable in your country may give you the following rights:
Right to be informed: what personal data an organization is processing and why (we provide this information to
you in this Privacy Policy).
Right of access: you can request a copy of your data.
Right of rectification: if the data held is inaccurate, you have the right to have it corrected.
Right to erasure: you have the right to have your data deleted in certain circumstances.
Right to restrict processing: in limited circumstances, you have the right to request that processing is stopped
but the data retained.
Right to data portability: you can request a copy of certain data in a machine-readable form that can be
transferred to another provider.
Right to object: in certain circumstances (including where data is processed on the basis of legitimate
interests or for the purposes of marketing) you may object to that processing.
Rights related to automated decision-making including profiling: there are several rights in this area where
processing carried out on a solely automated basis results in a decision which has legal or significant effects
for the individual. In these circumstances your rights include the right to ensure that there is human
intervention in the decision-making process.
The particular rights which are applicable to you (which might include other rights not listed above) may vary
depending on your country. You should make yourself aware of the rights you have under applicable privacy laws
in your country.
If you want to exercise any of your rights listed above please visit our Feedback Page or email our Data
Protection Officer at DPO@team.fingle.in. You can also contact us by post at the following address: The
Broadgate Tower Third Floor, 20 Primrose Street, London, United Kingdom, EC2A 2RS. For your protection and the
protection of all of our Users, we may need to request specific information from you to help us confirm your
identity before we can answer the above requests.
If you have a concern about how we have processed your request or your personal data, you should contact us in
the first instance via the contact details listed above.
If you feel we have not resolved your concern, you have the right to make a complaint at any time to the
Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues
(www.ico.org.uk). If you live in a country or territory located in the European Union (EU) or European Economic
Area (EEA), you may also get in touch with your local Data Protection Regulator. If you live in a country
outside the EU, you may have the right to lodge a complaint with your local privacy or data protection
regulator.
EU Representative
Pursuant to Article 27 of the General Data Protection Regulation (GDPR), Fingle has appointed Borlux Ltd as its
GDPR representative in the EU. If you usually reside in an EU Member State you can contact Borlux Ltd regarding
matters pertaining to the GDPR by:
Using the online request form at https://services.nathantrust.com/privacycontact
Postal address: 1st Floor, 6 Lapps Quay, Cork, Ireland
11. DATA LOCATIONS.
We want you to be able to access Fingle wherever you happen to be in the world. To enable us to provide that
service, we operate a global network of servers including in the US, UK, EU, and (for Users located in Russia)
Russia. The hardware is located in third-party data centres but is owned by the Fingle Group. Data collected by
Advertising Partners and other Service Providers may also be held outside the UK and the European Economic Area.
We ensure that the data is adequately protected by ensuring that valid, legal mechanisms are in place such as:
EU approved model clauses (which can be found here), and implementing robust contractual standards. If you want
more information relating to the nature of the safeguards we have in place, please email DPO@team.fingle.in.
12. DATA RETENTION AND DELETION.
We keep your personal information only as long as we need it for the legal basis relied upon (as set out in
Section 2 above) and as permitted by applicable law. Please see “Profile Verification Information (Including
Biometric Information)” in Section 1, above, to learn about our retention policy with respect to biometric
information.
When your Account is deleted, we make sure it is no longer viewable in the App. For up to 28 days, it is still
possible to restore your Account if it was accidentally deleted. After 28 days, we begin the process of deleting
your personal information from our systems, unless:
we must keep it to comply with applicable law (for instance, if you make purchases within the App, some personal
data may be kept for tax and accounting purposes);
we must keep it to evidence our compliance with applicable law (for example, if an account is blocked, we keep
some account information and a record of the behavior that led to the block - this information is retained for
evidential purposes in case of queries or legal claims concerning the block);
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).
Warning: Even after you remove information from your profile or delete your Account, copies of that information
may still be viewable and/or accessed to the extent such information has been previously shared with others, or
copied or stored by others. We cannot control this, nor do we accept any liability for this. If you have given
third party applications or websites access to your personal information, they may retain such information to
the extent permitted under their terms of service or privacy policies.
Thanks for reading, we hope we didn’t drone on for too long!
13. CHANGES TO THIS POLICY.
As Fingle evolves, we may revise this Privacy Policy from time to time. The most current version of the policy
will govern our use of your information and will always be at fingle.in/privacy-policy. If we make a change to this
policy that, in our sole discretion, is material, we will notify you, for example, via an email to the email
associated with your Account or by posting a notice within Fingle.
Effective date
This Privacy Policy was last updated June 21st, 2023.