PRIVACY POLICY

1. Introduction

This Privacy Policy governs the collection, use, and protection of personal data by Togething B.V., a company incorporated under the laws of the Netherlands, with registered office in Amsterdam and registered at the Chamber of Commerce under number 91822602. As the developer of the Togething app, we prioritize the privacy and security of our users’ personal information in accordance with legal and regulatory standards.

Our Privacy Policy is structured to comply with the General Data Protection Regulation (GDPR) and other applicable privacy laws. By accessing or using the Togething app, whether through a mobile or web-based platform, you acknowledge and agree to the practices described in this policy.

We reserve the right to update this policy as needed to reflect changes in our data practices or relevant laws. Such modifications will be communicated through the Togething app, and your continued use of the app following any changes signifies your acceptance of our updated Privacy Policy.

This document outlines the types of personal data we collect, the purposes for its collection, and the measures we take to ensure its protection. Our goal is to provide a secure and trustworthy environment for our users while respecting their privacy and data rights.

2. Information We Collect

To provide and improve the Togething app, Togething B.V. collects various types of information, which are essential for the operation, personalization, and enhancement of our services. Our data collection practices are designed with the utmost respect for your privacy and in strict compliance with applicable laws. The types of data we collect include:

Identification Data: This includes your name (or pseudonym), email address, or phone number. These details are crucial for user authentication, account management, and ensuring a secure user environment. The collection of this information is mandatory for the use of our services.
User Internal ID: A unique identifier assigned to your account for internal purposes such as analytics, fraud prevention, personalization, and account management.
Age Verification: Your date of birth is collected to comply with age restriction laws and regulations, ensuring our services are not accessed by underage individuals.
Location Data: We collect approximate location data as necessary for the functionality of the app. This information is used to facilitate connections with nearby users and enhance the app’s functionality. You have the option to opt out of location data collection.
User Content: This encompasses posts, messages, shared media files (photos and videos), profile images, and other user-generated content. We collect this data to provide and personalize the app's services, and for internal operations such as service improvement and content moderation.
In-App Messages and Voice or Sound Recordings: Messages and recordings shared within the app are collected for functionality purposes and are stored securely. Access to this data is limited to what is necessary for providing our services.
Device and Usage Information: We collect data such as your device ID, Ad ID, operating system version, and app activities including in-app interactions and search history. This information is used for delivering personalized notifications, service optimization, crash analysis, diagnostics, and analytical purposes by trusted external services like Firebase. These identifiers are also used to understand app usage patterns and improve our services.
App Performance Data: Including but not limited to crash logs and diagnostics, this information helps us maintain the reliability and performance of our app, enhancing user experience.

All personal data is collected solely for the purpose of providing and enhancing the functionality of the Togething app. This includes essential operations such as user authentication, service delivery, and improvement, as well as ensuring the security and integrity of our services. We adhere strictly to data minimization principles, ensuring that only data necessary for these purposes is collected.

By engaging with the Togething app, you acknowledge and consent to the collection and use of your information in line with the objectives outlined above. We are dedicated to maintaining high standards of data protection and privacy in compliance with relevant legal frameworks.

3. Use of Information

The information collected through the Togething app is utilized in several ways to enhance user experience, ensure the effective operation of the app, and maintain high standards of service. Specifically, the use of your information includes:

Account Management and Service Provision: Your identification data, such as name, email address, or phone number, along with your unique user ID, are used for managing your account. This includes user authentication, account setup and maintenance, and enabling the basic functionalities of the Togething app.
Personalization of Content and Services: We use information about your app activities, in-app interactions, and user content to tailor the app experience to your interests and goals. This personalization enhances the relevance and quality of the content and services offered to you.
Analytical Purposes: Information regarding your app usage, device and performance data (including crash logs and diagnostics), and user interactions within the app are analyzed for internal statistical purposes. These analyses aid in optimizing app performance and improving service quality.
Security and Fraud Prevention: To ensure the integrity and security of our services, we employ your data in monitoring for and protecting against fraudulent activity, unauthorized access, and other security threats.
Regulatory Compliance: We may use your information to comply with applicable laws and regulations, including age verification processes to enforce age restrictions.
Enhancement of User Experience: Device and usage information, including device ID and operating system version, is utilized to ensure a seamless and optimized experience across different devices and platforms.

Each use of your information is grounded in our commitment to providing a secure, efficient, and personalized user experience within the Togething app. We handle your data responsibly and in accordance with applicable privacy laws.

By using the Togething app, you consent to the use of your information as outlined in this section. We remain dedicated to upholding your privacy and ensuring transparent and lawful use of your data.

4. Data Sharing and Disclosure

Togething B.V. upholds a strict policy regarding the sharing and disclosure of your personally identifiable information. Our practices are designed to protect your privacy while ensuring compliance with legal and regulatory requirements.

No Sale of Data: We firmly commit to not selling, trading, or otherwise transferring your personally identifiable information to third-party companies for their marketing or advertising purposes.
Third-Party Service Providers: We may share your information with trusted third-party service providers, solely for the purpose of operating our app, conducting our business, or serving our users, as long as those parties agree to keep this information confidential. This includes cloud storage providers for data hosting and IT service providers for maintenance and support.
Legal Compliance and Protection of Rights: There are circumstances where we may be required to disclose your information if it is necessary to comply with legal obligations, respond to legal requests, enforce our app policies, or protect the rights, property, or safety of Togething B.V., our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.
Analytics and Improvement: Anonymized or aggregated data, which cannot be used to identify you, may be shared with partners or used for analytics and improvement of our services.
Consent-Based Sharing: In cases other than those mentioned above, we will share your personal information with third parties only with your explicit consent.

This policy ensures that your data is shared responsibly and only under necessary circumstances. Our priority is to maintain the confidentiality and integrity of your personal information while complying with applicable laws and regulations.

By using the Togething app, you acknowledge and agree to the data sharing and disclosure practices as described in this section.

5. Data Storage and Security

Togething B.V. takes the security of your data seriously. We employ advanced measures and technologies to ensure the safe storage and protection of your personal information.

Secure Storage: Your data is stored on servers provided by reputable and trusted cloud service providers. These providers are selected for their robust security protocols and commitment to data protection.
Access Control: Strict access controls are in place to limit access to your data to authorized personnel only. Employees and contractors of Togething B.V. are subject to confidentiality obligations and may only access user data on a need-to-know basis.
Regular Security Audits: Our systems undergo regular security reviews and audits to identify and remedy potential vulnerabilities. This proactive approach helps us stay ahead of evolving threats.
Incident Response Plan: In the unlikely event of a data breach, we have an incident response plan in place to promptly address and mitigate any potential impacts on your data and privacy.
Acknowledgement of Limitations: While we strive to use commercially acceptable means to protect your personal information, we acknowledge that no method of electronic storage or transmission over the Internet is 100% secure. Therefore, we cannot guarantee its absolute security.

Our commitment to data security is a core aspect of our operations. We continuously update and refine our security practices to safeguard your information against unauthorized access, alteration, disclosure, or destruction.

By using the Togething app, you acknowledge our efforts in protecting your data and agree to our data storage and security practices as outlined in this section.

6. International Data Transfer

At Togething B.V., we are committed to complying with the General Data Protection Regulation (GDPR) and ensuring the highest level of data protection, regardless of where your data is processed.

Data Transfer Within the EU: Our primary servers and data storage facilities are located within the European Union. This ensures that your data is processed in regions with robust data protection laws.
Potential International Transfers: While most data processing occurs within the EU, there may be instances where your data needs to be transferred internationally, such as through global network infrastructure or for specific technical requirements.
Safeguarding International Transfers: In cases of international data transfer, we take appropriate measures to ensure that your personal information remains protected to the standards set forth by the GDPR. This includes implementing standard contractual clauses approved by the European Commission, ensuring that any data processors outside the EU adhere to equivalent data protection standards.
Transparency and Consent: We will maintain transparency regarding any international transfers of your data.
Continuous Compliance: We actively monitor changes in data protection regulations and adjust our practices as necessary to remain compliant with GDPR and other applicable laws.

By using the Togething app, you acknowledge and consent to the potential international transfer of your data as described in this section, under the safeguards and conditions set out by the GDPR.

7. Data Retention and Deletion

Togething B.V. adheres to principled data management practices, balancing the need to maintain app functionality with the privacy rights of our users.

Duration of Data Retention: We retain your personal data for as long as your account remains active. This retention is necessary to provide continuous and efficient service, and to ensure that your interactions within the app are preserved for the full duration of your use of our services.
Deactivation and Deletion: Upon your request to delete your account, there will be a brief deactivation period of 3 days. This period allows for the verification and processing of the deletion request.
Secure Erasure of Data: After the deactivation period, your personal and personally identifiable information will be securely and irreversibly erased from our systems, except where we are required to retain certain information by law.
Retention of Anonymized Data: For the purpose of maintaining app functionality and integrity, certain non-personal data, which cannot be used to identify you, may be retained. This data is crucial for the ongoing operation of the app and to ensure a seamless experience for remaining users.
Legal and Regulatory Compliance: In some cases, we may be required to retain certain information for longer periods as mandated by law, regulation, or for legitimate business purposes.
User Rights and Control: You may request the deletion of your personal data, subject to our data retention policies and legal obligations. We are committed to honoring such requests promptly and in accordance with legal requirements.

By using the Togething app, you acknowledge and agree to our data retention and deletion practices as outlined above. Our approach is designed to respect your privacy while ensuring the ongoing functionality and legal compliance of our services.

8. Your Rights

Togething B.V. recognizes your rights concerning your personal data under applicable data protection laws. We are committed to facilitating the exercise of these rights in a manner that is consistent with our legal obligations and our operational capabilities.

Right to Access: You have the right to request access to the personal information we hold about you. Upon such a request, we will provide you with a copy of your personal data in our possession, subject to verification of your identity and to the extent that it does not adversely affect the rights and freedoms of others.
Right to Rectification: If you believe that any personal information we hold about you is incorrect or incomplete, you have the right to request its correction. We will make the necessary amendments promptly, provided that we can verify the accuracy of the new data you provide.
Right to Deletion: You may request the deletion of your personal data. We will honor such requests in accordance with legal requirements and where it does not compromise the integrity of our service or our ability to conduct legitimate business activities.
Limitations and Obligations: Please note that these rights are not absolute and may be subject to limitations as provided by law. For instance, there may be circumstances where we are legally required to retain your data, or where the retention is necessary for the establishment, exercise, or defense of legal claims.
Exercising Your Rights: To exercise any of these rights, please contact us through the provided channels. We may request specific information from you to help confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights).

Your understanding and cooperation in respecting the balance between your individual rights and the operational requirements of the Togething app are greatly appreciated.

9. Changes to This Policy

Togething B.V. reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, legal landscape, or operational requirements.

Notification of Changes: Any modifications to this policy will be communicated to our users through an in-app notification. This is designed to ensure that all users are informed about any changes in a timely manner.
Review of Changes: It is the responsibility of the users to review the changes in the policy. We encourage regular review of the Privacy Policy to stay informed about how we are protecting your personal information.
Acceptance of Changes: Continued use of the Togething app after any changes to this Privacy Policy have been notified will be regarded as acceptance of our updated practices. If you do not agree with the changes, you should discontinue your use of the app.
Effective Date: Changes to the policy will be effective immediately upon their posting in the app, unless otherwise stated in the notification.

This approach to policy modification is designed to provide flexibility to adapt to evolving data protection practices and legal requirements, ensuring the ongoing compliance and operational effectiveness of the Togething app.

10. Governing Law and Jurisdiction

The Privacy Policy of Togething B.V., including all matters relating to the use of the Togething app, is governed exclusively by the laws of the Netherlands, without regard to its conflict of law principles.

Jurisdiction: Any disputes, claims, or controversies arising out of or in connection with this Privacy Policy, or the breach, termination, enforcement, interpretation, or validity thereof, shall be resolved exclusively in the competent courts of the Netherlands.
International Considerations: While the Togething app is accessible to users around the world, the laws and regulations of the Netherlands will be the sole governing body for all legal matters. This includes, but is not limited to, data protection practices, user rights, and any legal disputes.
User Acknowledgement: By using the Togething app, users outside of the Netherlands acknowledge and agree that the laws of the Netherlands will govern any legal proceedings or disputes that may arise.

This approach ensures a clear and consistent legal framework for the operation of the Togething app, and it provides certainty for both the company and its users regarding the legal jurisdiction that applies to their interactions.

11. Contact Information

Should you have any inquiries or concerns regarding this Privacy Policy, please reach out to us via email at the following address:

Email: [email protected]

We will endeavor to respond to your queries in a timely and efficient manner.

12. Limitation of Liability

Togething B.V. endeavors to ensure the highest standard of data protection and service quality. However, it is important to clarify the scope of our liability in relation to the use of the Togething app.

Exclusion of Certain Damages: Togething B.V. shall not be liable for any indirect, incidental, consequential, special, or punitive damages arising out of or in connection with your use of the Togething app. This includes, but is not limited to, damages for loss of profits, goodwill, use, data, or other intangible losses.
Scope of Liability: Our liability to you for any direct damages arising from or related to your use of the Togething app (regardless of the basis upon which liability is claimed) will not exceed the amount of fees actually paid by you for the app within the three months immediately preceding the event giving rise to such claim.
Basis of the Bargain: The limitations of liability reflected in this section are a fundamental element of the basis of the bargain between Togething B.V. and you as the user. They apply regardless of whether the alleged liability is based on contract, tort, negligence, strict liability, or any other basis, even if Togething B.V. has been advised of the possibility of such damage.
Jurisdictional Variations: The above limitations of liability will apply to the fullest extent permitted by the law of the jurisdiction in which you use the app. Certain jurisdictions do not allow the exclusion or limitation of liability for consequential or incidental damages, so the above limitations may not apply to you based on your local laws.

By using the Togething app, you acknowledge and agree to these limitations of liability, which are an integral part of our terms of service.

13. User's Responsibility

The security and confidentiality of your account on the Togething app are of utmost importance. As a user, you play a critical role in maintaining the security of your account.

Account Credentials: You are solely responsible for maintaining the confidentiality and security of your account credentials, including your password and any other authentication information.
Notification of Unauthorized Use: In the event of any unauthorized use of your account or breach of your account credentials, it is your responsibility to notify Togething B.V. immediately.
Consequences of Negligence: Togething B.V. shall not be held liable for any loss, damage, or other security issues that may arise from your failure to keep your account information secure. This includes any loss or damage resulting from unauthorized access to your account as a result of your own negligence.
Secure Practices: We encourage you to use strong, unique passwords for your account and to ensure that you log out of your account after each session, especially when accessing the app on a shared or public device.

By using the Togething app, you acknowledge and agree to accept responsibility for all activities that occur under your account and to take all necessary steps to ensure the security of your account.

14. Children's Privacy

Togething B.V. is committed to protecting the privacy of young individuals. The Togething app is not designed for, nor intentionally targeted at, children under a certain age.

Age Requirement: Currently, our services are not intended for individuals under the age of 16. We do not knowingly collect or solicit personal information from anyone under this age. This age limit may be subject to change in the future, and any such change will be clearly communicated in this Privacy Policy.
Self-Certification of Age: Users are required to confirm their age upon registration. We rely on the accuracy of the information provided by users for age verification.
Protection of Minors: In the event that we learn that we have collected personal information from a child under the age of 16 without verification of parental consent, we will take steps to remove that information from our servers.
Parental Consent: For jurisdictions where parental consent is required for users under a specific age, it is the responsibility of the user and their legal guardians to ensure such consent is given and can be verified.
User Responsibility: If you are a parent or guardian and believe that your child under the age of 16 has provided us with personal information, please contact us immediately to request the removal of the data.

By using the Togething app, users affirm they meet the age requirement as stipulated in this policy. It is the responsibility of each user to provide accurate information regarding their age.

15. Third-Party Links

The Togething app may provide links to external websites or resources for your convenience and information.

External Content: Please be aware that these external sites are not under the control of Togething B.V. We do not endorse and are not responsible for the content, privacy policies, security practices, or data handling procedures of these external websites.
User Discretion Advised: Your interaction with any third-party websites, including the submission of personal information, is solely between you and such third parties. We encourage you to read the privacy policies of any website you visit via links provided in the Togething app.
No Liability: Togething B.V. shall not be liable for any harm or damages related to the purchase or use of goods, services, resources, content, or any other transactions made in connection with any third-party websites.

By using the Togething app, you acknowledge and agree that Togething B.V. is not responsible for the risks associated with accessing or using third-party content and that such use is subject to the terms and conditions and privacy policies of those external sites.

Here's a draft for Section 16 of your Privacy Policy, focusing on camera access:

16. Camera Access and Data Usage

The Togething app may request access to your device's camera. This access is designed to enhance the user experience and enable specific functionalities within the app.

Purpose of Camera Access: Camera access is utilized for features such as capturing and sharing photos and videos within the app. This allows users to engage more fully with the app's social networking functionalities.
Consent for Camera Access: Access to the camera is granted only after explicit user consent. Users will be prompted to grant permission for camera access, and this permission can be modified or revoked by the user at any time through their device settings.
Data Security and Privacy: We are committed to ensuring that any images or videos captured using the camera feature are stored securely. These media files are treated in accordance with our stringent data protection protocols.
Limited Use: The camera is used strictly for the functionalities as described and does not involve any undisclosed or unauthorized data collection or processing.
User Control and Management: Users have full control over their camera data. You can choose when to use the camera feature and have the ability to delete any photos or videos shared within the app at your discretion.

By granting the Togething app access to your camera, you consent to the use of your camera as outlined in this policy. We ensure that the camera access is utilized solely for the purposes stated and with full respect for your privacy and data security.

17. Complaints Procedure

At Togething B.V., we are committed to providing a high-quality service to all our users. If you have any concerns about our service or the way we handle your personal data, we encourage you to contact us directly so we can address your concerns.

Contact for Complaints: If you have any complaints or feedback, please reach out to us via our dedicated email: [email protected]. We take your concerns seriously and will endeavor to resolve them promptly.
Internal Review Process: Upon receiving a complaint, it will undergo an internal review process. Our team will investigate the matter thoroughly and provide you with a response outlining our findings and any actions we may take.
Resolution: Our goal is to resolve complaints to your satisfaction within a reasonable timeframe. However, please be aware that some issues may require more time to investigate thoroughly.
Feedback Appreciation: Your feedback is valuable to us, as it helps us improve our services. We appreciate your time and effort in providing us with your concerns.

By using the Togething app, you acknowledge and agree that our process for handling complaints is fair and reasonable. We strive to ensure that all concerns are addressed appropriately and efficiently.

18. GDPR Compliance

In compliance with the General Data Protection Regulation (GDPR), Togething B.V. adheres to stringent data protection standards for users within the European Union.

Legal Basis for Processing: Our processing of personal data under GDPR is based on several legal grounds, including:
- Contractual Necessity: We process personal data as necessary for the performance of our contract with users, such as providing the Togething app's services.
- Compliance with Legal Obligations: We may process personal data to comply with legal requirements applicable to our business.
- Legitimate Interests: We process personal data on the basis of legitimate interests, such as improving our services, preventing fraud, and ensuring the security of our app and user data. These interests are balanced against the rights and freedoms of our users.
Data Subject Rights: Users have rights regarding their personal data, including the right to access, correct, and in certain cases, delete their information. Requests related to these rights can be directed to our contact point provided in the Privacy Policy.
Data Protection Measures: We are committed to implementing appropriate technical and organizational measures to ensure a high level of security for personal data.
Transborder Data Flow: If personal data is transferred outside the EU, we ensure adequate safeguards are in place to protect the information in accordance with GDPR requirements.

This section of our Privacy Policy reflects our commitment to comply with GDPR while managing personal data responsibly and efficiently for the provision of our services.