Rilly Privacy Policy

 

Welcome to the Rilly Privacy Policy. This policy explains how we collect, store, protect, and share your information and with whom we share it. We recommend reading this alongside our Terms and Conditions of Use.

 

When you use the Rilly mobile application (including the desktop version), our websites and microsites (like Rilly.app), or our digital products and services (such as competitions or surveys), collectively referred to as our "Services," we collect some information about you. We provide a mobile application and a website featuring technology that enables users to share, bookmark, index, store, collect and showcase content in the nature of photos, videos, text, data, images. You can also choose to share information with other users, including your friends and contacts, while using our Services. At times, we may need to share your information.

 

Our Services are global, and your information will be transferred to and used in the United States and the UK, regardless of your country of residence. This policy explains how we protect your personal data when transferring it overseas, so please read it carefully.

 

1. COLLECTION OF INFORMATION

 

Registration Information

 

When you download the Rilly app and create an account ("Account"), we may collect certain information ("Registration Information") about you, including:

 

-       Name

-       Username

-       Email address

-       Phone number

-       Gender identity

-       Date of birth

-       Sexual preference

-       Photographs

-       Location

-       Login information for social media accounts connected to your Rilly Account (such as Facebook and Instagram). For more details, refer to "Linking other Accounts to Rilly" in section 7 below.

 

After registration, you can update most of this information by logging into Rilly. Note that your date of birth and location (if you've granted Rilly access to your location in your device settings) may be automatically updated based on your device's location. It's your responsibility to keep your account details current. If your phone number changes, please update it in your account.

 

The information we collect helps improve the app and verify our users (we're not fans of robots!). Some of your Registration Information, like your sexual preference, name, and username, may be visible to other users who visit your profile page.

 

For California residents, the data we collect falls into the following categories of "personal information" as defined by the California Consumer Privacy Act (CCPA):

 

·      Identifiers, such as name and location.

·      Personal information under California customer records law, like contact (email and telephone number) and financial information.

·      Characteristics of protected classifications under California or federal law (if provided), such as age, gender identity, marital status, sexual orientation, race, ancestry, national origin, religion, and medical conditions.

·      Commercial information, including transaction details and purchase history.

·      Biometric information.

·      Internet or network activity information, like browsing history and interactions with our app and sites.

·      Geolocation data, such as mobile device location.

·      Audio, electronic, visual, and similar information, such as photos and videos.

·      Professional or employment-related information, like work history and previous employers.

·      Non-public education information.

·      Inferences drawn from the above personal information, creating a profile or summary of individual preferences and characteristics.

 

Profile Information

 

We advise all our members to be cautious about the information they share. Please avoid disclosing sensitive details such as email addresses, URLs, instant messaging info, phone numbers, full names, addresses, credit card data, national identity numbers, driver's license details, and other personal information that could be misused.

 

When you post information or communicate through our messaging function, you're responsible for the amount of personal information you share. See Section 4 below for details on who can access your posts on Rilly.

 

Profile Verification Information (Including Biometric Information)

 

For safety and security, we require users to verify their accounts. This may involve providing your phone number or even undergoing photo verification to ensure you're not a robot and to prevent fake accounts and malicious activities. The verification process may include facial recognition technology to match your submitted photo with your profile picture. We do not display verification photos on your profile. We retain these scans for verification and record-keeping purposes, typically up to three years after your last interaction with us. After this period, we securely delete them.

 

Purchases Information

 

If you purchase our premium services, we process your payment information securely for fraud prevention and audit/tax purposes. We use automated decisions to identify potentially fraudulent payment transactions.

 

Geolocation Information

 

If you've allowed Rilly access to your device's location, we collect WiFi access point information and other location data like longitude and latitude. This helps personalize the app and enables you to interact with nearby users. You can disable location access in your device settings.

 

Device Information

 

We may collect device information, including unique identifiers, device model, and operating system, to enhance your Rilly experience. With your permission, the app may access your device's address book to add contacts.

 

Links

 

We monitor how you interact with links on Rilly, including third-party services, for statistical purposes. We may share aggregate click statistics, but not individual link interactions.

 

Messages

 

We review message content in the app to identify topics, sentiments, and trends among users. We take steps to remove personally identifying information before review and do not share message content or derived information with third parties.

 

Rilly Success Stories, Surveys, and Contributions

 

Periodically, we conduct surveys, request feedback, testimonials, and participation in marketing campaigns. Participation is voluntary, and we provide details when we contact you. If you don't wish to participate, please contact our Customer Support Team.

 

Contacting Customer Support

 

When you contact our Customer Support via the Feedback Page, we receive your email address and may track your IP address. We retain records of our communications for 6 years after account deletion.

 

Cookies and Similar Technologies

 

We collect personal data automatically using cookies or similar tech when you visit our Sites or use our App. Cookies are small files that help us recognize and remember you. For more info, refer to our Cookie Policy.                                                                                                                                                                                                                                                                                                                                                                      

 

Use of Your Information

 

Our priority is to ensure your experience on Rilly is enjoyable and hassle-free. To achieve this, we may use your Registration and other information for various purposes:

 

-       Offering Services: We use your data to provide you with our services and features.

 

-       App Communication: We may contact you with important information about the app, such as updates and new features.

 

-       Personalization: Your data helps us personalize the app and the content we deliver to you.

 

-       Research and Analytics: We analyze how you use the app to improve your experience and develop new technologies.

 

-       Problem Resolution: We use your information to resolve disputes, troubleshoot issues, and enforce our Terms & Conditions.

 

-       Fraud Prevention: Your data helps us investigate fraud, protect our legal rights, and enforce our Terms & Conditions.

 

-       Promotions and Offers: If you've opted in, we may send you information about our promotions and offers via direct marketing or other communication methods. You can opt out at any time.

 

-       User and Third-Party Protection: We use your data to protect our users and third parties from harm.

 

Matching Algorithms

 

We employ matching algorithms to predict your compatibility with other users and suggest potential matches. These algorithms consider data such as your profile information, app activity, photo verification status, and device coordinates to provide you with relevant recommendations. Processing this information is necessary for providing our services and is based on the GDPR Article 6(1)(b) and legitimate interests under Article 6(1)(f). If you include sensitive information in your profile, the processing is based on your explicit consent.

 

Moderation Practices

 

Our platform utilizes automated systems and moderators to monitor user accounts, photos, and messages for violations of our Terms and Conditions of Use. If an account or message breaches our terms, the account may receive warnings, and the user's access may be restricted or blocked. Users can contest these decisions.

 

Posting content inconsistent with our Terms and Conditions may result in the termination or restriction of your account.

 

Disclosure of Information

 

We take your privacy seriously and typically do not disclose your Registration Information or personal data, except in specific circumstances:

 

-       Service Providers: We may share your data with trusted third-party service providers who assist us in performing certain functions and services, but only for those specific purposes.

 

-       Moderators: We share necessary information with moderators to monitor app activity and approve content.

 

-       Payment Processing and Telecommunications Companies: Your payment-related data may be shared with these companies to facilitate transactions for our premium services.

 

-       Law and Harm: We cooperate with law enforcement and third parties to enforce legal rights, protect individuals, and address fraud, security, or technical issues. This may include complying with court orders or lawful requests and protecting our rights or property.

 

-       Business Transfers: In the event of a business transition, such as a merger, acquisition, or sale, your personal data may be disclosed.

 

-       Marketing Services Providers: We work with marketing service providers to deliver advertising on third-party websites and apps and measure advertising effectiveness. This may involve sharing data like your device's advertising identifier, estimated location, age, gender, and information about your interactions with our app.

 

-       Anti-Spam and Anti-Fraud: Your data may be shared with other Rilly Group companies to prevent spam and detect fraudulent payment transactions.

 

-       Aggregated Information: We may share aggregated data with third parties, which includes your personal data but does not directly identify you. This information is used for industry analysis and demographic profiling.

 

Please note that the extent of data sharing varies depending on the specific situation and the nature of the request or issue involved.

 

More Information About Disclosures

 

Service Providers: We work with various service providers, depending on the specific functions and services they provide. These can include billing services, authentication services, social media providers, product improvement and market research agencies, and IT services. We perform due diligence on these providers to ensure they meet data protection and security standards. They receive only the necessary personal data and are bound by strict data retention limits.

 

Marketing Services Providers: We collaborate with Marketing Services Providers (e.g., Facebook) to market and advertise our app and services on third-party platforms. Data shared with them includes your device's advertising identifier, location, age, gender, actions taken on our app or sites, and a hashed version of your email address for custom audiences. Hashing encrypts your email address, making it untraceable. These providers may also use your data for their own purposes.

 

Facebook: In cases involving Facebook as our Marketing Service Provider, we are Joint Data Controllers with Facebook Ireland. If you have data protection inquiries, contact Facebook directly. Facebook processes actions you take on our website and provides insights for advertising purposes.

 

What Others May See About You:

 

-       Assume that anything you post or submit on the Rilly App may be publicly viewable, both by users and non-users of the app.

 

-       Avoid posting sensitive information, such as religious beliefs and health details, on your profile. This includes sensitive information added through badges.

 

-       Be aware that photos you post may reveal information about you.

 

-       Your profile and other app information may be viewed and shared by both users and individuals who may not use the app.

 

-       In certain countries (currently South Korea), users can download their conversation history, but Rilly has no control over how users may use or publish that information.

 

-       If you access the app through a shared device, remember to log out to prevent others from accessing your account.

 

Our Policy Towards Age:

 

- Users must be at least 18 years old to use Rilly. We do not knowingly collect information from anyone under 18.

 

Security:

 

We take security seriously and have measures in place to protect your information. While we do our best to ensure security, no website or Internet transmission can be 100% secure. Here are some tips to help protect your data:

 

-       Always log out of your account after use.

 

-       Do not share your password with others.

 

-       Change your password regularly.

 

-       If you suspect unauthorized access to your account, follow the provided steps.

 

-       Be aware that data transmission over the Internet carries some risk, and any transmission is at your own risk.

 

7. Linking Other Accounts to Rilly

 

Using Your Social Media Details to Sign in to Rilly:

 

-       When signing in with your Facebook account, you give permission to share your name, profile picture, email (if associated with Facebook), date of birth, profile photos, gender, Page likes, and current town/city.

 

-       Registering with your Apple ID allows Apple to share your Apple login, a name (editable by you), and an email (which can be hidden). This email is linked to your Rilly account.

 

-       Removing the Rilly app from your Facebook or Apple settings revokes our access to this data, but we will retain data from your initial setup until you delete your Rilly account entirely.

 

How We Process Personal Data in BFF and Legal Bases for Processing:

 

-       Joining Hives is based on location, activity, "my life," and "my interests" information. Processing location data is necessary to provide the Hives service.

 

-       Recommendations for Hives based on profile and activity information are done in our legitimate interests to provide relevant Hive recommendations.

 

-       Sharing sensitive information, like sexuality and beliefs, is done with explicit user consent.

 

Profile Sharing on Our Rilly For Friends App:

 

-       BFF profiles are visible on both BFF mode in Rilly and the separate app, Rilly For Friends, to expand potential friend connections. This sharing applies to BFF members in jurisdictions where Rilly For Friends is available.

 

8. Your California Privacy Rights

 

-       California residents have the right to request disclosure of certain information about how personal information has been collected, used, and shared over the past 12 months.

 

-       The right to request deletion of personal information with exceptions.

 

-       The "Shine the Light" law allows California customers to inquire about business practices related to disclosing personal information to third parties for direct marketing purposes. Email us at support@rilly.app for inquiries related to this law.

 

-       We may disclose contact information as part of joint promotions with third parties for marketing purposes, but we will inform you when such promotions occur.

 

-       We do not currently track users' personal information over time and across third-party online services.

 

-       We do not knowingly permit third parties to collect personal information about users' online activities when using the App.

 

**10. Data Locations**

 

We operate a global network of servers, including locations in the US, UK, EU, and Russia (for Russian users). While our hardware is housed in third-party data centers, it is owned by the Rilly Group. Data collected by Advertising Partners and other Service Providers may be stored outside the UK and European Economic Area. We ensure data protection through mechanisms such as EU-approved model clauses and robust contractual standards. For further details on safeguards, contact us at DPO@Rilly.app.

 

**11. Data Retention and Deletion**

 

We retain your personal information only as long as necessary based on the legal basis (as outlined in Section 2). Refer to "Profile Verification Information (Including Biometric Information)" in Section 1 for our biometric information retention policy.

 

Once your Account is deleted, we ensure it's no longer viewable within the App. For up to 28 days, you can restore your Account if accidentally deleted. After 28 days, we commence the process of deleting your personal information from our systems, except in cases where:

 

-       We must retain it to comply with applicable law (e.g., tax and accounting purposes for App purchases).

-       We need to evidence our compliance with the law (e.g., retaining account information and behavior records for blocked accounts).

-       An outstanding issue, claim, or dispute requires retention until resolution.

-       Information is needed for our legitimate business interests, such as fraud prevention and enhancing safety and security (e.g., preventing banned users from opening new accounts).

 

Note: Even after removal from your profile or Account deletion, others may still have access to copies of shared information, as permitted under their terms of service or privacy policies. We disclaim liability for this.

 

**12. Changes to This Policy**

 

As Rilly evolves, we may periodically revise this Privacy Policy. The most current version will be available at Rilly.app/privacy-policy and will govern our use of your information. If we make material changes, we will notify you via email or within the Rilly platform.

 

*Effective Date*

 

This Privacy Policy was last updated on July 14th, 2023.