VIND PRIVACY POLICY

Vind is firmly committed to the security and protection of personal information of our Users and their contacts. This Privacy Policy describes how Vind will collect, use, share and process personal information. Capitalized terms not defined in this Privacy Policy are defined in the Vind’s  Terms of Service.


By accepting the Vind Privacy Policy and/or using the Services You consent to the collection, use, sharing and processing of personal information as described herein. If You provide us with personal information about someone else, You confirm that they are aware that You have provided their information and that they consent to our use of their information according to our Privacy Policy. You may opt-out at any time to prevent further use of the information shared via the Services.

Please note that provision of information from the Vind database is constitutionally protected under applicable laws on Freedom of Expression, see the Terms of Service. Personal Information Collected


1.1 User Profile

When you create a user profile in the Services and confirm being the holder of a certain number, Vind will collect the information provided by You. In order to create a user profile, you must register your first name, last name and phone number. Additional information that may be provided at your option include, but is not limited to, photo, gender, street address and zip code, country of residence, email address, professional website, Facebook page, Twitter address and a short status message. Vind may supplement the information provided by you with information from third parties and add it to the information provided by you e.g. demographic information and additional contact information that is publicly available.


1.2 Installation and Use

When you install and use the Services, Vind will collect personal information from you and any devices you may use in your interaction with our Services. This information may include e.g.: geo-location; ID for advertising; ad data, operating system; access to device address book; device log and event information; call logs, keywords and meta data of incoming and outgoing calls and messages; version of the Services.


1.3 Third Party Services

You may provide us with Your user identifier information regarding, or to enable Your usage of, certain third party services (together with a mapped photo where applicable) e.g. social networking services and payment services, in order for the Services to interoperate with such third party services. You may use such third party services to create Your user profile or log in to our Services, share information with such third party services, or to connect Your user profile with the respective third party services. Such third party services may automatically provide us with access to certain personal information retained by them about You (e.g., your payment handle, unique identification information, content viewed by You, content liked by You and information about the advertisements You have been shown or may have clicked on) and You agree that we may collect, use and retain the information provided by these third party services in accordance with this Privacy Policy. You may be able to control the personal information You allow us to have access to through the privacy settings on the respective third party service. We will never store any passwords created for any third party services.


1.4 Contact Information

Where the Vind mobile applications (“Vind Apps”) are obtained from other sources than Apple App Store or Google Play, You may share the names, numbers, Google ID’s and email addresses contained in Your address book (“Contact Information”) with Vind by enabling the Vind Enhanced Search Functionality. Where the Vind Apps are obtained from Apple App Store or Google Play, we will only use permitted Contact Information to make our Services more relevant to You and Your engagement with the Vind community. In addition to Contact Information, if You choose to activate use of a third party service, such as social networks services, within the Services, Vind may collect, store and use the list of identifiers associated with said services linked to the Contact Information in order to enhance the results shared with other Users.

You acknowledge and agree that any Contact Information that You share with Vind is submitted for publication in the Vind database. Please note that no other contact information other than the phone numbers and thereto attached names, Google ID’s and email addresses will be collected and used from Your address book. Please also note that You can always choose not to share Contact Information with Vind and if You have shared such information and changed Your mind, You can  delist Your number or opt-out to render Your entire Contact Information unavailable for search in the Vind database.


1.5 Other Information You may provide

You may provide us with various information in connection with Your interaction with our Services. For example, You may through tagging functionality associate a phone number, that is not registered in the Vind database, with a business or name and You may report a phone number as spam or some other attribute to be included in spam blocking directories. Vind may also from time to time offer You the opportunity to provide information on Your experience from using the Services or to participate in contests, surveys or other promotions. Vind will collect the information You provide in connection therewith, as well as any other information You provide through the Services or when You communicate or interact with us.


2. Use of Personal Information
2.1 Provide, improve and personalize our Services

Vind may use the personal information collected to provide, maintain, improve, analyze and personalize the Services to its Users, partners and third party providers. More specifically, Vind may use such information to:

provide smart caller ID, dialer and messaging functionality that, among other features, allow for population of unidentified numbers and other data in call or message logs, display the name associated with a certain number for incoming or outgoing calls and messages or following a manual number search against the Vind database; display the number associated with a certain name following a manual name search against the Vind database, subject to that name searches will only produce a number linked to the name if the number is available for search in a public database or relates to a User who has made his or her name available for search, provide Your information to the person You reach out to when requesting a contact via the Vind name search service, in which case Your request will be forwarded to that person via an SMS and he/she may choose whether or not to share the phone number with You at his/her own discretion; display information based on connections a User may have in common, directly or indirectly, with other Users via a “social graph” algorithm, display the “who viewed my profile” and “availability” functionalities of the Services; send in application push notifications and reminders and deliver messages via the Services, in which case Your messages will be kept for a limited period of time in order to deliver the messages but Vind will not, unless specifically stated, monitor the content of Your messages; maintain User spam lists and build a community based spam blocking directory; share your last known location with other user which You can stop anytime from settings; enable You to use and share Your information in connection with Your registration, login or other use of third party services e.g. payment service providers, online services, social networking sites and other third party API’s; and otherwise improve our Services, business and operations.


2.2 Statistical data from the Services

We use aggregated or anonymized personal information for statistical and analytical purposes. We may come to share such data with third parties.

We do not consider personal information to include information that has been made anonymous or aggregated so that it can no longer be used to identify a specific person, whether in combination with other information or otherwise.


2.3 Personalize our advertising and communications

We may use any of the information collected, as set out above, to provide You with location and interest based advertising, marketing messaging, information and services. We may also use the collected information to measure the performance of our advertising and marketing services.

We may contact You for verification purposes or with information pertaining to the Services or special offers, e.g. newsletter e-mails, SMS and similar notifications about Vind’s and our business partners’ products and services. We also use the collected information to respond to you when you contact us.


2.4 Compliance with laws and prevention of fraudulent or illegal activities

We may use the collected information to comply with applicable laws and to enforce our agreements and protect and defend the rights or safety of Vind, its Users or any other person and verify provided User profile information with third party providers and ensure technical service functionality and data accuracy, perform trouble-shooting and prevent or detect fraud, security breaches or illegal activities.


3.1 Sharing and Disclosure of Personal Information

In addition to the sharing and disclosure of personal information that is included as part of the functionality of the Services as described in section 2 above, Vind may disclose personal information if we believe such action is necessary to comply with the law, or legal process served on us, protect and defend our rights and the enforcement of our agreements, or protect the security and safety of Users or members of the public or other aspects of public importance, provided, of course, that such disclosure is lawful.

We transfer information to trusted vendors, service providers, and other partners who support our business and Services, such as providing technical infrastructure services, bug testing, analyzing how our Services are used, measuring the effectiveness of ads and services and facilitating payments as well as potential partners who may wish to work with us to provide other services. Vind will always require these third parties to take appropriate organizational and technical measures to protect personal information and to observe applicable legislation. Vind may also share personal information with third party advertisers, agencies and networks. Such third parties may use this information for analytical and marketing purposes e.g. to provide measurement services and targeted ads and for improvement of products and services. The information may be collected by such third parties by use of cookies, or similar technologies.

We may disclose and transfer Your Information to our associated or affiliated organizations or related entities and to any third party who acquires, our business, whether such acquisition is by way of merger, consolidation or purchase of all or a substantial portion of our assets.


3.2 Delisting of Contact Information and Opt-Out of Ad Targeting

If a User chooses to disable the Enhanced Search Functionality, the Contact Information made available by that User is disabled and will thereafter not be available for search in the Vind database. If any persons do not wish to have their names and phone numbers made available through the Enhanced Search or Name Search functionalities, they can exclude themselves from further queries by notifying Vind via its website at www.vindapp.com or as set forth in the contact details below. You acknowledge and agree that Vind may keep and process personal information related to such request in order to be able to honor the request.

You can limit or opt-out of the collection and use of Your information for ad targeting by third parties via Your device settings.


3.3 Information Security and Transfer of Personal Information to Other Countries

In order to provide the Services, Vind will transfer, process and store personal information in a number of countries, including but not limited to India, and may also use cloud based services for this purpose. Vind may also subcontract storage or processing of Your information to third parties located in countries other than Your home country. Information collected within the European Economic Area (“EEA”) may, for example, be transferred to and processed in a country outside of the EEA, which may not provide the same level of protection for personal data as within the EEA. You acknowledge and agree that Vind may transfer Your personal information as described above for purposes consistent with this Privacy Policy. We take all reasonable precautions to protect personal information from misuse, loss and unauthorized access. Vind has implemented physical, electronic, and procedural safeguards in order to protect the information, including that the information will be stored on secured servers and protected by secured networks to which access is limited to a few authorized employees and personnel. However, no method of transmission over the Internet or method of electronic storage is 100% secure.


3.4 Accessing and Updating Personal Information

Vind may on its own initiative, or at Your request, replenish, rectify or erase any incomplete, inaccurate or outdated personal information retained by Vind in connection with the operation of the Services. When required by applicable law, You have the right to know what personal information is stored about You and to have any such information corrected or deleted on Your request. You can connect for the same with us at support@vindapp.com.


4. Minors

Services are not intended for or designed to attract anyone under the relevant age of consent to enter into binding legal contracts under the laws of their respective jurisdictions. Vind does not intentionally or knowingly collect personal information through the Services from anyone under that age. We encourage parentsand guardians to be involved in the online activities of their children to ensure that no personal information is collected from a child without their consent.


5. How We Collect and Use Information

5.1 Registration and Profile Information: When you create an account, we may collect your personal information such as your username, first and last name, email address, mobile phone number and a photo, if you chose to have a photo associated with your account.


5.2 Geolocation: We collect your unique user identifier and your location through GPS, WiFi, or wireless network triangulation in order to obtain your location for the purposes of providing our Service. We collect the location of your designated “Places” to provide alerts when family members arrive and leave. If you turn off location sharing in one or more of your circles, we will not share your location with such circles; however, we will continue to collect your location information in order to provide the Service (for example, to provide our emergency services or to share your location with the other circles you continue to allow to see your location, or to provide advertising). We maintain location information only so long as is reasonable to provide the Service and then delete location data tied to your personal information. We may maintain de-identified location data for a longer period of time in order to analyze aggregate trends and metrics. We may also share location information with third parties for advertising, research, and analytic purposes. If you want to opt-out of the collection of your location data, please adjust your settings in your mobile device to limit the app’s access to your location data. Please see “Your Choices About Your Information” below to learn more.


5.3 Driving Event Data: We collect, and may use a third party to collect, sensory and motion data from your smartphone or mobile device, including information from the gyroscope, accelerometer, compass and Bluetooth, in order to calculate and detect driving events such as speeding, hard braking, crash detection and other events. We maintain sensory and motion data as long as is reasonable to provide the Service and then delete or anonymize this data. If you want to opt-out of the collection of your sensory and motion, please adjust your settings in your mobile device to limit the app’s access to your sensory and motion data.


6. Sharing of Your Information

6.1 Personal Information:We share your personal information, including name, email, location and driving event data, with others within your Vind Family and other Vind circles. We may share your personal information with our third-party business partners, vendors and consultants who perform services on our behalf or who help us provide our Services, such as accounting, managerial, technical, marketing or analytic services. We may at any time buy or sell/divest the company, or any combination of its products, services, assets and/or businesses. Personal information such as customer names and email addresses, and other user information related to the Service will likely be one of the items transferred in these types of transactions. We may also share, transfer or assign such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions or similar transactions or proceedings. Except as described above, we will not disclose personal information to third parties (including law enforcement, other government entity, or civil litigant; excluding our subcontractors) unless required to do so by law or subpoena or if in our sole discretion, we determine it is necessary to (a) conform to the law, comply with legal process, or investigate, prevent, or take action regarding suspected or actual illegal activities; (b) to enforce our Terms of Use, take precautions against liability, to investigate and defend ourselves against any claims or allegations, or to protect the security or integrity of our site; and/or (c) to exercise or protect the rights, property, or personal safety of Vind, our Users or others.

6.2 Third Party Location Sharing: We may share your personal information, including location data, with third parties so that they may play or display ads that may be relevant to your interests, for example by sending you an ad for a local business, or so that they may conduct research, analyze trends and perform other analytics or reporting functions. We do not share your personal information and location data with third parties for advertising purposes if you have selected “Limit Ad Tracking” or “Opt-Out of Interest Based Ads” on your mobile device. You can opt-out of having your location data shared with these third parties by adjusting your settings on your mobile device to prohibit Vind from collecting your location data. For example, depending on your mobile device, you may be able to “Turn location services ‘off.’ You can also adjust your device settings to withdraw permission for the Vind app to access location data. Please note that your Vind app may not be able to provide all of our Services to you if you disable access to location data through your device settings. To continue to permit Vind to access your device location data but to opt-out of Vind sharing location data with third parties for advertising purposes.

6.3 Delete Your Account and Personal Information: We will retain your information for as long as your account is active or as needed to provide you services. If you wish to cancel your account, please contact us at support@vindapp.com.


7. Children’s Privacy

Our Service allows parents to keep track of their children’s location on mobile devices that the Parent has added to the Family account. The child will then be able to participate in the Vind Service as a member of that Family Account. The child’s personal information, including name, user name, email, and location, will be shared with other members of the Family account and the child user will be permitted to contact, and be contacted by, other members of the Family account through the Service. Vind may collect, use, disclose, and store the child’s personal information as described in this Privacy Policy. However, we do not use or share personal information collected from the accounts of children under 13 for marketing or advertising purposes, or permit our third party partners to collect and use such information for advertising purposes. The Parent may contact us to review and/or delete any personal information we have collected from the child, or to withdraw permission for Vind to collect any additional information from the child. Please contact us at support@vindapp.com if you have questions about your child’s account. If you believe that we might have inadvertently collected information from a child under 13 without parental consent, please contact us at support@vindapp.com.


8. How We Protect Your Information

Vind cares about the security of your information and uses commercially reasonable physical, administrative, and technological safeguards to preserve the integrity and security of all information we collect. However, no security system is impenetrable and we cannot guarantee the security of our systems 100%. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.


9.Your Choices About Your Information

You may, of course, decline to submit any personal information through the Service, in which case Vind may not be able to provide its Services to you.


10.Changes to this Privacy Policy

Vind may at any time with or without a separate notice change this Privacy Policy, and You are encouraged to review this Policy from time to time. In case of substantial changes, Vind will notify the Users by push notice or via notice in the Services. Your continued use of the Services after a notice of changes has been communicated to You or published on our Services shall constitute consent to the changed policy.


11.Contact

If You have any additional questions about Vind’s Privacy Policy or want to make a request regarding certain personal information, You are encouraged to contact Vind by sending your enquiries via email to support@vindapp.com.


Date Last Modified:

This Privacy Notice was last modified June 5th, 2018