This Privacy Policy applies to Pixllove, our iOS and Android mobile application (our “App”). In the below policy, we inform you about the scope of the processing of your Personal Data.

GENERAL INFORMATION

a) What law applies?
Our use of your Personal Data is subject to the UAE`s Federal Decree Law No. 45 of 2021 (“Law No. 45”) and the EU General Data Protection Regulation (“GDPR”), and of course we process your Personal Data accordingly.

b) What is Personal Data?

Personal Data is any information relating to personal or material circumstances that relates to an identified or identifiable individual. This includes, for example, your name, date of birth, e-mail address, postal address, or telephone number as well as online identifiers such as your IP address and device ID.

c) What is Special Category Data?

Special category data is Personal Data that needs more protection because it is sensitive. This includes Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data. As well as, data concerning health, a person’s sex life; and a person’s sexual orientation. In order to lawfully process Special Category Data, it is necessary to consent to the processing

d) What is processing?

Processing means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means. The term is broad and covers virtually any handling of data.

e) Who is responsible for data processing?

The responsible party within the meaning of Law No. 45 and the GDPR is Pixllove Social Media Applications Development And Management L.L.C of Office no 1 F01, Al Murar, Dubai, United Arab Emirates (“Pixllove”, “we”, “us”, or “our”).

If you have any questions about this policy or our data protection practices, please contact us using info@pixllove.com, call us on +971 52 993 7054 or write to us at the above address.

f) The Legal Bases for processing Personal Data

In accordance with the above-mentioned laws, we have to have at least one of the following legal bases to process your Personal Data: a) you have given your consent, b) the data is necessary for the fulfillment of a contract / pre-contractual measures, c) the data is necessary for the fulfillment of a legal obligation, or d) the data is necessary to protect our legitimate interests, provided that your interests are not overridden.

PROCESSING OF AUTOMATICALLY COLLECTED DATA

a) Downloading our App
The App can be downloaded from the “Google Playstore” a service offered by Google LLC, or the Apple App service “App Store” a service of Apple Inc., to install our App. Downloading it may require prior registration with the respective App store and/or installation of the respective App store software.

b) Installing our App
As far as we are aware, Google collects and processes the following data: License check, network access, network connection, WLAN connections, and location information. However, it cannot be ruled out that Google also transmits the information to a server in a third country. We cannot influence which personal data Google processes with your registration and the provision of downloads in the respective App store and App store software. The responsible party in this respect is solely Google as the operator of the Google Play Store.

As far as we are aware, Apple collects and processes the following data: device identifiers, IP addresses, location information, it cannot be excluded that Apple also transmits the information to a server in a third country. We cannot influence which personal data Apple processes with your registration and the provision of downloads in the respective app store and app store software. The responsible party in this respect is solely Apple as the operator of the Apple App Store.

c) Device information
Google and Apple may collect information from and about the device(s) you use to access our App, including hardware and software information such as IP address, device ID and type, device-specific and App settings and properties, App crashes, advertising IDs (AAID), information about your wireless and mobile network connection such as your service provider and signal strength; information about device sensors such as accelerometer, gyroscope, and compass and Payment Data and Billing confirmations.

d) Authorizations and Access
We may request permission to store your App data including your Internet Connection and Network, Location, Push Notifications, Gallery, Image Storage and Camera. The legal basis for data processing is our legitimate interest, the provision of contractual or pre-contractual measures and your consent. You can deny access on your device via the Settings/Notifications/ options of your device; however, this means that our App may not function as intended.

e) Push messages
When you use our App, you will receive so-called push messages from us, even if you are not currently using our App. These are messages that we send you as part of the performance of the contract. You can adjust or stop receiving push messages at any time via a) the device settings of your device or b) or by enabling or disabling specific types of notifications within the App. Insofar as you consent to the use of push messages, consent is the legal basis for the processing.

f) Firebase
We use the Google Firebase developer App and related features and services provided by Google. We use the following Google Firebase services in our App: a) Firebase Analytics, b) Firebase Crashlytics, c) Firebase Cloud Messaging for Push Notifications. By integrating Google services, Google may collect and process information (including personal data). It cannot be excluded that Google also transfers the information to a server in a third country. We cannot influence which data Google collects and processes. Firebase’s key security and privacy information can be found here: https://firebase.google.com/support/privacy The legal basis is the implementation of the user contract for the use of the App.

g) Crashlytics
The app uses the tool Crashlytics to log crashes of our App. No personal data is transmitted. Only real-time crash reports with precise details of code locations and device information are sent, which is intended to simplify maintenance and improve the resulting stability of our App. The legal basis for data processing is our legitimate interest. In the settings under data services, you can select whether you want to send crash reports or not.

h) Google Analytics for Firebase
Our App uses the web analytics service Google Analytics for Firebase, which uses tracking technologies to track your use of our App. In this respect, information is generated about, among other things, the number of users and their sessions, the session duration, the operating system used by the users, their device model, the region from which our App is accessed, the first start of our App, our App execution and any updates.

In order to provide the relevant data for analysis, Firebase Analytics uses your a) device’s advertising ID, b) an App instance ID (a randomly generated number that identifies a single app installation), c) and the IP address, which is shortened (IP masking) before being processed on Google’s servers (which may be located outside the UAE/EEA) to generate the usage analysis. You can object to the use of Firebase Analytics at any time by disabling the sending of usage statistics in your device settings (Reset Advertising ID). We have no influence on these data processing operations.The basis for processing is our legitimate interest and your consent.

i) Advertising
Advertisers and third parties also may collect information about your activity on our app, on devices associated with you, and on third-party sites and applications using tracking technologies. Tracking data collected by these advertisers and third parties is used to decide which ads you see both on our app and on third-party sites and applications. If you do not wish to participate in our advertising personalization or retargeting/tracking you can object to behavioral advertising at the following websites: Your Online Choices, Digital Advertising Alliance of Canada, Network Advertising Initiative, AdChoices and the European Interactive Digital Advertising Alliance (Europe only). In addition, you may also choose to control targeted advertising you receive within applications by using the settings and controls on your devices.

DATA PROCESSING BY US

a) Contacting us
Personal data is processed depending on the contact method. In addition to your name and email address, IP address or phone number, we usually collect the context of your message, which may also include certain Personal Data. The personal data collected when you contact us is used to process your request and the legal basis is your consent.

b) Providing our services
The protection of your data is particularly important to us in the performance of our services. We therefore only want to process as much Personal Data (for example, your name, address, e-mail address or telephone number) as is absolutely necessary. Nevertheless, we rely on the processing of certain Personal Data, to fulfill our contractual obligations to you or to carry out pre-contractual measures.

c) Registration
If you register, we will request mandatory and, where applicable, non-mandatory data in accordance with our registration form including your Location, Phone Number, age, gender, sexual orientation, preferences in relationships, language, physical activities, education level, profession, marital status, consumption habits, and more. The entry of your data is encrypted so that third parties cannot read your data when it is entered. We also send you a One-time password (OTP) per SMS using the services of Twilio. Twilio may collect and process information (including personal data). It cannot be excluded that Twilio also transfers the information to a server in a third country. We cannot influence which data Twilio actually collects and processes. Your data will remain stored for as long as the registration lasts, in particular if the storage is necessary for the fulfillment/execution of the contract, to enforce our rights or for our other legitimate interests or we are required by law to retain your data (e.g., within the framework of tax retention periods).

Alternatively, you are able to sign up using the convenience login and sign up from Apple. For both login and sign up, you will be asked to provide your basic information (i.e., name, email address, and display picture) linked to your account. When registering via a connect function, you agree to Apple’s terms and conditions and consent to certain data from your Apple account being transferred to us. The legal basis is your consent and the establishment and implementation of the user contract for the use of our App.

d)Profile
As a registered user, you have the opportunity to create a user profile with just a few clicks and details and the relevant profile data you provide will be posted on your profile. Of course, you can change the information at any time via the settings in your profile. You have choices about the information on your profile. It’s your choice whether to include sensitive information on your profile and to make that sensitive information public. Please do not post or add Personal Data to your profile that you would not want to be available. The legal basis for the processing of your Personal Data is the establishment and implementation of the user contract for the use of our App.

e) Using our App and providing Content
If you wish to use our App and its features, we process the Personal Data you voluntarily provide for the purpose of providing our App. Depending on how you use our services, you may provide contact information, location data etc. and upload content such as text, photographs and video etc. This content will be made public and may be viewed and otherwise accessed by others.
Some of the Personal Data you provide may be considered “special” or “sensitive”. This includes Personal Data concerning for example your racial or ethnic origins, sexual orientation, sexual preferences and gender. By choosing to provide this data, you consent to our processing of that data. You have choices about the data you provide and how you share it. You don’t have to provide Personal Data or Special Category Data. It’s your choice whether to include Personal Data or Special Category Data and to make that information available to us. Please do not share information that you would not want to be available. The legal basis for the processing of your Personal Data and Special Category Data is the establishment and implementation of the user contract for the use of the service as well as your consent.
In providing our App and publishing your content including video chats we may process images and facial-related information from our Users. Images and facial-related information are used and processed solely for the purpose explicitly consented to and we do not collect, use, or store any images and facial-related information for the purpose of recognising faces outside of this purpose. The legal basis is your consent.

Of course, we also process your chats and communications with other users as well as the content you publish, as necessary for the operation of our App. Doing so we use the services of Agora for real-time communication and Amazon Cloud Watch for monitoring (Agora and Amazon may collect and process information (including personal data). It cannot be excluded that Agora and Amazon transfer the information to a server in a third country. We cannot influence which data Agora and Amazon actually collect and process).

In addition to the information, you may provide us directly, we receive information about you from others. Users may provide information about you as they use our App, for instance as they interact with you. The legal basis is the fulfillment of the user contract for the use of the platform as well as your consent.

We also share some users’ information with service providers and partners who assist us in operating our App. You share information with other users when you voluntarily disclose information on the service (including your profile). Please be careful with your information and make sure that the content you share is stuff that you’re comfortable being visible. The legal basis for the data processing is the fulfillment of our contractual obligations and, in individual cases, the fulfillment of our legal obligations as well as your consent.

In addition to the information you provide to us directly, we receive information about you from others, including other users who provide us with information about you when they use our App. For example, we may receive information about you from other users when you contact them about us.

We also collect information about your activities on our App, such as how you use them (e.g., the date and time you logged in, features you used, searches you performed, clicks and pages you were shown, content you clicked on) and how you interact with other users (e.g., users you connect and interact with, the time and date of your exchanges). The legal basis is the fulfillment of the user contract for the use of the platform as well as your consent.

f) Administration, financial accounting, office organization, contact management
We process data in the context of administrative tasks as well as organization of our business, and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services and stored in our customer relationship management system provided by Hubspot. The processing bases are our legal obligations and our legitimate interest.

g) Payment Data
If you make a purchase or take out a subscription your payment will be processed via the payment service providers Google and Apple and payment will solely be processed through the payment systems of Google and Apple. The legal basis for the provision of a payment system is the establishment and implementation of the user contract for the use of the service.

h) Promotional use of your data
We use your data within the legally permissible scope for marketing purposes, e.g., to draw your attention to special promotions and discount offers. In addition, we may draw your attention to comparable offers by email, e.g., we may inform you about exclusive sales, promotions, or special events. The legal basis for processing is our legitimate interest.

GENERAL PRINCIPLES

What we do not do

• We do not request Personal Data from minors and children;
• We do not process special category data without obtaining prior specific consent;
• We do not use Automated decision-making including profiling; and
• We do not sell your Personal Data.

a) Sharing

We will not disclose or otherwise distribute your Personal Data to third parties unless this is a) necessary for the performance of our services, b) you have consented to the disclosure, c) or the disclosure of data is permitted by relevant legal provisions. In addition, we may disclose your Personal Data: in connection with law enforcement, fraud prevention or other legal proceedings; as required by law or regulation; if Pixllove (or a part of Pixllove) is sold to or merged with another company; or if we have reason to believe that disclosure is necessary to protect our business.

b) International Transfer

We may transfer your Personal Data to other companies as necessary for the purposes described in this Privacy Policy. In order to provide adequate protection for your Personal Data when it is transferred, we have contractual arrangements regarding such transfers. We take all reasonable technical and organizational measures to protect the Personal Data we transfer.

c) Storage

In the course of our business and App operations, we process data in our Ireland based headquarters. All data collected is generally transferred to our Amazon Web Services (AWS) Server and a MongoDB atlas Database. The legal basis for the data processing is our legitimate interest in providing our App.

d) Data Security

Our App uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of confidential content, such as login data or contact requests that you send to us. We have also implemented numerous security measures (“technical and organizational measures”) for example encryption or need to know access, to ensure the most complete protection of Personal Data processed through our App.

Nonetheless, databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised, and the notice will be accompanied by a description of the action being taken to reconcile any damage as a result of the data breach. Notices will be provided as expeditiously as possible after which the breach was discovered.

YOUR RIGHTS AND PRIVILEGES

a) Privacy rights

You can exercise the following rights:

• Right to information
• Right to rectification
• Right to object to processing
• Right to deletion
• Right to data portability
• Right to withdraw consent
• Right to complain to a supervisory authority
• Right not to be subject to a decision based solely on automated processing.

If you wish to exercise any of your rights, please contact us.

b) Updating your information

If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please do so by contacting us.

c) Withdrawing your consent

You can revoke consents you have given at any time by contacting us. The legality of the data processing carried out until the revocation remains unaffected by the revocation.

d) Access Request

In the event that you wish to make a Data Subject Access Request, you may inform us in writing of the same. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the respective legal regulations mentioned above).

e) What we do not do

• We do not request Personal Data from minors and children;
• We do not process special category data without obtaining prior specific consent;
• We do not use Automated decision-making including profiling; and
• We do not sell your Personal Data.

f) Complaint to a supervisory authority

You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection. However, we would appreciate the opportunity to address your concerns before you contact any supervisory authority.

VALIDITY AND QUESTIONS

This Privacy Policy was last updated on Friday, 19th of Juli, 2024, and is the current and valid version. However, from time to time changes or a revision to this policy may be necessary.

If you feel that the above is not sufficient or if you have any queries as regards the collection, processing or use of your information we are looking forward to hearing from you. We will make every effort to reply as soon as possible and take into consideration any suggestions from your end.