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Privacy Policy

Last Updated: Aug 18, 2023

Nozy (referred to as "Service", “we,” “us,” or “our”) is committed to safeguarding the personal information it collects when you use our website at nozy.live (the “Site”), mobile applications (the “Apps”), and together, the “Services”. This Privacy Policy covers our data collection practices and describes your rights to access, correct, or restrict our use of your personal data; in plain language, keeping legal and technical jargon to a minimum. If you have any questions about this Policy, please contact us at [email protected].

If there is any inconsistency or ambiguity between the English version and any other language version, the English version shall prevail.

By using the Services, you agree to the terms of this Privacy Policy. You shouldn’t use the Services if you don’t agree with this Privacy Policy or any other agreement that governs your use of the Services.

If you are under the age of 18, you may not download or use Nozy. We do not knowingly collect, maintain, or sell information from minors under 18. We do not knowingly collect, maintain, or sell personal information from children under the age of 13.

1. What This Privacy Policy Covers

This Privacy Policy describes how our mobile applications, websites, and products collect, store, use, and share your personal information. It also describes how you can control and protect your privacy on our Service.

This Privacy Policy does not apply to the practices of companies that we do not own or control, such as companies that advertise on our Service or with whom we partner for certain services. For example, companies that advertise on our Service may tag your device or computer with cookies. We do not control these third-party cookies and their privacy policies may differ from ours.

2. What Data We Collect

We collect certain data from you directly, like the information you enter yourself, data about your usage, and data from third-party platforms you connect with us. We also collect some data automatically, like information about your device and what parts of our Services you interact with or spend time using.

2.1. Data You Provide to Us

We may collect different data from or about you depending on how you use the Services. When you create an account and use the Services, including through a third-party platform, we collect any data you provide directly, including

a. Account Data: In order to use certain features (registering for an account), you need to create a user account. When you create or update your account, we collect and store the data you provide, like your email address, phone number, username, gender, and date of birth, and assign you a unique identifying number (“Account Data”). We process your email address and once the email is confirmed we send transactional emails depending on specific actions. These emails are to notify you of said actions and are separate from email marketing and promotional emails. If you want to opt-out of these emails you can do so easily from your account settings.

If you give us your consent for email marketing, then we may use your email to notify you about promotions and discounts happening within the app.

b. Profile Data: You can also choose to provide profile information like a photo, bio (status and info), name, location, interests, story, video streams, or other data. Your Profile Data will be publicly viewable by others. To add certain content, like pictures or videos, you may allow us to access your camera or photo album. Some of the information you choose to provide us may be considered “special” or “sensitive” in certain jurisdictions. By choosing to provide this information, you consent to our processing of that information.

c. Usage Data: When you use our Services and features, we collect certain data including; messages, content published, video streams, chats, audio files, likes, visits, hashtags, photos, videos, gifts, in-app purchase history, other user-generated content, crash and diagnostics data and other user data as part of the operation of the Services and moderation.

d. Shared Content Data: Parts of the Services let you interact with other users or share content publicly, including live streams, messages posted under live streams, gifts you receive, stories you post, and the data you provided in your profile. Such shared content may be publicly viewable by others depending on where it is posted.

e. Accounts on Other Services Data: We may obtain certain information through your social media or other online accounts if they are connected to your account in our Services. If you log in to our Services via Google or another third-party platform, we ask for your permission to access certain information about that other account. For example, depending on the platform or service we may collect your name, login email address, gender, and birthday.

Those platforms and services make information available to us through their APIs. The information we receive depends on what information you (via your privacy settings) or the platform or service decide to give us.

If you access or use our Services through a third-party platform or service, or click on any third-party links, the collection, use, and sharing of your data will also be subject to the privacy policies and other agreements of that third party.

f. Paid Services Data: All our paid services are through iOS or Android platforms. We only receive a receipt of your transaction provided by these platforms. For security reasons, we do not collect or store sensitive cardholder data, such as full credit card numbers or card authentication data.

g. Communications and Support Data: If you contact us for support or to report a problem or concern (regardless of whether you have created an account), we collect and store your contact information, messages, and other data about you like your name, email address, location, operating system, IP address, and any other data you provide or that we collect through automated means (which we cover below). We use this data to respond to you and research your question or concern, in accordance with this Privacy Policy.

h. Sensitive Data: Please be careful about posting sensitive details about yourself on your Profile such as your sexual orientation, religious denomination and health details. While you may voluntarily provide this information to us when you create your Profile there is no requirement to do so. Please remember that photographs or any video clips that you post on our Services may reveal these kinds of sensitive personal data. Where you do upload and choose to tell us sensitive data about yourself, you are explicitly consenting to our processing of your information and making this public to other users.

2.2. Data From Others

In addition to the information you provide us directly, we receive information about you from others or by automated means, including;

a. System Data: Technical data about your computer or device, like your IP address, device type, operating system, and version, unique device identifiers, device language, device-specific and apps settings and characteristics, app crashes, advertising IDs (such as Google’s AAID and Apple’s IDFA), browser type, version and language, operating system, time zones, identifiers associated with cookies or other technologies that may uniquely identify your device or browser, and other systems data, and platform types (“System Data”).

b. Usage Data: We collect information about your activity on our Services, for instance how you use them (e.g., date and time you logged in, features you’ve been using, search preferences, clicks, and pages that have been shown to you, referring web page address, advertising that you click on) and how you interact with other users (e.g., users, you connect and interact with, time and date of your exchanges, number of messages you send and receive, number of content you post).

c. Other Data with your consent: If you give us permission, depending on the service and device you’re using. With your consent, we may collect your photos and videos (for instance, if you want to publish a photo, video, or streaming on the Services). To upload photos or record live streams or stories we will ask for necessary permissions to enable access.

d. Approximate Geographic Data: An approximate geographic location, including information like country, city, and geographic coordinates, calculated based on your IP address.

e. Other Partners: We may receive info about you from our partners, for instance where our ads are published on a partner’s websites and platforms (in which case they may pass along details on a campaign’s success).

3. How We Get Data About You

We use tools like cookies, web beacons, analytics services, and advertising providers to gather the data listed below. Some of these tools offer you the ability to opt-out of data collection.

3.1 Analytics

We use third-party SDKs to analyze data to give better service to our users. The information we give and receive are non-user-specific. We use these tools to analyze your use of the Services, including information like third-party websites you arrive from, how often you visit, events within the Service, usage and performance data, and more. We use this data to improve the Services, better understand how the Services perform on different devices and provide information that may be of interest to you. All the information we send is anonymized and cannot be tracked back to specific users. In other words, it is not possible to draw conclusions about a specific person. All the third-party SDKs we use are GDPR compliant.

a. 3rd Party Usage Analytics Tools: Facebook for ad tracking and analytics, Firebase for analytics; Appsflyer for ad tracking and analytics.

b. 3rd Party Conversion Tracking Tools: Appsflyer (https://www.appsflyer.com/trust/privacy/) is used for user conversion tracking.

c. Crash Detection Tools: We use Firebase (https://www.firebase.com/terms/privacy-policy.html) for crash detection. It facilitates the maintenance and improvement of the Services. All your crash data is collected anonymously.

4. What We Use Your Data For

The main reason we use your information is to deliver and improve our Services. Additionally, we use your info to help keep you safe and to provide you with advertising that may be of interest to you. Read on for a more detailed explanation of the various reasons we use your information, together with practical examples.

  • To administer your account and provide our Services to you
  • Create and manage your account
  • Provide you with customer support and respond to your requests
  • Complete your transactions
  • Communicate with you about our Services, including order management and billing
  • To help you connect with other users
  • Analyze your profile and that of other users to recommend meaningful connections
  • Show users’ profiles to one another
  • To ensure a consistent experience across your devices
  • Link the various devices you use so that you can enjoy a consistent experience of our Services on all of them. We do this by linking devices and browser data, such as when you log into your account on different devices or by using partial or full IP address, browser version, and similar data about your devices to help identify and link them.
  • To provide new services to you
  • Register you and display your profile on new features and apps
  • Administer your account on these new features and apps
  • To serve you relevant offers and ads
  • Administer sweepstakes, contests, discounts, or other offers
  • Develop, display and track content and advertising personalized to your interests on our Services and other sites
  • Communicate with you by email, phone, social media or mobile device about products or services that we think may interest you
  • To improve our Services and develop new ones
  • Administer focus groups and surveys
  • Conduct research and analysis of users’ behavior to improve our Services and content (for instance, we may decide to change the look and feel or even substantially modify a given feature based on users’ behavior)
  • Develop new features and services (for example, we may decide to build a new interests-based feature further to requests received from users).
  • To prevent, detect and fight fraud or other illegal or unauthorized activities
  • Address ongoing or alleged misbehavior on and off-platform
  • Perform data analysis to better understand and design countermeasures against these activities
  • Retain data related to fraudulent activities to prevent recurrences
  • To ensure legal compliance
  • Comply with legal requirements
  • Assist law enforcement
  • Enforce or exercise our rights, for example, our Terms
  • To process your information as described above, we rely on the following legal bases:

Provide our service to you: Most of the time, the reason we process your information is to perform the contract that you have with us. For instance, as you go about using our service to build meaningful connections, we use your information to maintain your account and your profile, to make it viewable to other users, and to recommend other users to you.

Legitimate interests: We may use your information where we have legitimate interests to do so. For instance, we analyze users’ behavior on our Services to continuously improve our offerings, we suggest offers we think might interest you, and we process information for administrative, fraud detection, and other legal purposes.

Consent: From time to time, we may ask for your consent to use your information for certain specific reasons. You may withdraw your consent at any time by contacting us at the address provided at the end of this Privacy Policy.

5. Moderation Practices

We use a combination of automated systems and a team of moderators to monitor and review accounts (including photos and any other information uploaded onto user profiles) and messages for content that indicates breaches of our Terms of Service. If an account or message meets certain criteria that demonstrate that the Terms of Service are likely to have been breached, the relevant account will be subject to a warning and the user’s access restricted and/or blocked. Affected Users can contact Nozy to contest the decision.

If you post anything that is inconsistent with our Terms and Conditions of Use, we reserve the right to terminate or restrict access to your Account.

6. Data Disclosure

Our policy is to not disclose your personal data, except in the limited circumstances described below:

Circumstances where data may be disclosed Disclosed data
Other Users - You share information with other users when you voluntarily disclose information on the service (including your public profile). Please be careful with your information and make sure that the content you share what you’re comfortable being publicly viewable since neither you nor we can control what others do with your information once you share it. Profile information, live streams, stories, and what you want to share publicly.
Moderators - to monitor activity on the site/apps and approve content. Fraud prevention and anti-spam providers to protect the service from criminal activity. Name and user registration details, profile information, location, purchase history, the content of messages, and photographs. (CCPA Categories A, B, C, and H)
Service Providers and Partners - We use third parties to help us operate and improve our Services. These third parties assist us with various tasks, including data hosting and maintenance, analytics, customer care, marketing, advertising, payment processing, and security operations. These service providers may access your personal data and are required to use it solely as we direct, to provide our requested service.We may also share information with partners who distribute and assist us in advertising our Services. For instance, we may share limited information on you in hashed, non-human readable form to advertising partners. We follow a strict vetting process prior to engaging any service provider or working with any partner. All of our service providers and partners must agree to strict confidentiality obligations Which could include all data for analytics, diagnostics, ad tracking, and crash logs.
Advertising Partners - our Advertising Partners serve targeted advertisements on our App and Sites (this includes rewarded video ads) – More information on this is available below Advertising identifier associated with your device (Device ID), age, gender, and IP address (and your estimated locations based on your IP address) (CCPA Categories A, C, and G)
Law and Harm - As we mentioned in the Terms of Service, we think it is very important that all Nozy users behave whilst using the App. We will cooperate with all third parties to enforce their intellectual property or other rights. We will also cooperate with law enforcement inquiries from within or outside your country of residence where we are required by law, where there is an investigation into alleged criminal behavior or to protect the vital interests of a person. This may include preserving or disclosing any of your information, including your Registration Information if we believe in good faith that it is necessary to comply with a law or regulation, or when we believe that disclosure is necessary to comply with a judicial proceeding, court order, or legal request; to protect the safety of any person; to address fraud, security or technical issues e.g. through anti-spam providers to protect the service from criminal activity or to protect our rights or property or those of third parties. In such cases, we may raise or waive any legal objection or right available to us. This could include any personal data that Nozy holds about you, depending on the nature of the request or the issue that we are dealing with, including all CCPA Categories listed above
Marketing Services Providers - To help us serve marketing and advertising on third-party websites and applications and measure the effectiveness of our advertising campaigns. More information on this is available below. Advertising identifier associated with your device (Device ID), estimated location (based on your IP address), purchase history, age, gender and data about your visit to our Sites or App and action taken on those (for example if you downloaded our App or created an account with our App), hashed email address (for ‘custom audiences’ only) (CCPA Categories B, C, G, F and K)
Business Transfers - In the event that a Nozy or any of its affiliates undergoes a business transition or change of ownership, such as a merger, acquisition by another company, re-organisation, or sale of all or a portion of its assets, or in the event of insolvency or administration, we may be required to disclose your personal data to a purchaser of all or part of the business or to an insolvency practitioner This could include all personal data that Nozy holds about you, including all CCPA Categories listed above
Anti-Spam and Anti-Fraud - Your data may be shared with other Fepar A.S apps or it’s parent company, for example, to block accounts and suspected fraudulent payment transactions as part of our anti-spam and anti-fraud procedures. This could include email address, phone number, IP address, and IP session information, social network ID, username, user agent string, and transaction and payment data (CCPA Categories B, F, and D)
  • Aggregated Information - We may share aggregated information with third parties that includes your personal data (but which doesn’t identify you directly) together with other information including log data for industry analysis and demographic profiling.

  • Sharing Data with Advertising and Marketing Partners
    We collaborate with trusted marketing service providers, like Facebook, and advertising partners, such as AdMob, for dual purposes:

  • Advertising:

    • Serve tailored ads on our platforms based on user preferences.
  • Marketing:

    • Display our ads on third-party platforms.
    • Identify and target potential Nozy users.
    • Evaluate the effectiveness of our advertising and marketing campaigns.
    • Understand and enhance user engagement with our services.

    Certain personal data, such as your app ID, and ad unit id may be accessed by our partners. However:

    • The data shared is often in a hashed, non-human readable format to prioritize privacy.
    • These partners are bound to use this information exclusively as directed by us.
    • All partnerships undergo a stringent selection process to ensure the utmost safety and respect for personal data.
    • These partners are GDPR compliant.
  • For clarity, some reasons we utilize marketing tools include:

    • Excluding existing Nozy users from campaigns targeting new users.
    • Showcasing Nozy ads to those who’ve visited but haven’t registered.
    • Forming a ‘Lookalike Audience’ – identifying potential users with similar profiles.
    • Including users in a ‘custom audience’ designed for ads matching their interests.

7. Our Policy Towards Age

Although we want as many people as possible to enjoy our creation, you have to be at least 18 years old to use the App.

Nozy does not knowingly collect any information about or market to children, minors, or anyone under the age of majority. If we become aware that a child, minor, or anyone under the age of 18 has registered with us and provided us with personal data, we will take steps to terminate that person’s registration and delete their Profile information from Nozy. If we do delete a Profile because you violated our no children rules, we may retain your email and IP address to ensure that you do not try to get around our rules by creating a new Profile.

Service Providers: We use third-party service providers to carry out moderation services to improve app quality and enforce our age policy.

We carry out due diligence on all Service Providers we engage to ensure they have adequate data protection and information security measures in place and only provide them with the personal data necessary for the service they are providing. Our suppliers are also subject to extensive obligations under our contractual arrangements, including strict data retention limits.

8. Data Retention

We keep your personal information only as long as we need it for legitimate business purposes and as permitted by applicable law. To protect the safety and security of our users on and off our services, we implement a safety retention window of 6 months following account deletion unless there is a technical difficulty. During this period, account information will be retained although the account will of course not be visible on the services anymore.

When you delete your account or it is deactivated by us, we make sure it is no longer viewable on the App. For up to 28 days it is still possible to restore your Account if it was accidentally deleted or wrongfully deactivated. After 28 days, we begin the process of deleting your personal information from our systems.

In practice, we delete or anonymize your information upon the deletion of your account (following the safety retention window) or after 10 years of continuous inactivity. An account is considered inactive when the Application of the Member has not established contact with servers, and the Member has not used the Application. In any event, the Account of a Premium Member is not considered inactive.

Unless:

  • We must keep it to comply with applicable law (for instance, if you make purchases within the App, some personal data may need to be kept for tax and accounting purposes);
  • we must keep it to evidence our compliance with applicable law (for instance, records of consents to our Terms, Privacy Policy, and other similar consents are kept for five years);
  • there is an outstanding issue, claim, or dispute requiring us to keep the relevant information until it is resolved; or
  • the information must be kept for our legitimate business interests, such as fraud prevention and enhancing users' safety and security. For example, information may need to be kept to prevent a user who was banned for unsafe behavior or security incidents from opening a new account.
  • Correspondence with our Customer Support team will be retained for longer to allow us to deal with any subsequent queries you may have but will usually be deleted within 6 years if there are no queries.
  • Anonymized information about activity on our Services is retained for longer periods of time for statistical and product research purposes but this is not attributable to an individual once the profile has been deleted.

Keep in mind that even though our systems are designed to carry out data deletion processes according to the above guidelines, we cannot promise that all data will be deleted within a specific time frame due to technical constraints. The deleted data may also be available for up to 72 hours due to caching systems and the interconnection of proxy servers. Some of your data like photos may be in cache for 30 days since the CDN service is renewed every 30 days.

9. Data Protection and Security

We work hard to protect you from unauthorized access to or alteration, disclosure, or destruction of your personal information. As with all technology companies, although we take steps to secure your information, we do not promise, and you should not expect, that your personal information will always remain secure. Your password is an important part of our security system, and it is your responsibility to protect it. You should not share your password with any third party, and if you believe your password or account has been compromised, you should change it immediately and contact [email protected] with any concerns.

We regularly monitor our systems for possible vulnerabilities and attacks and regularly review our information collection, storage, and processing practices to update our physical, technical, and organizational security measures.

We may suspend your use of all or part of the Services without notice if we suspect or detect any breach of security. If you believe that your account or information is no longer secure, please notify us immediately.

We are not responsible for virus protection outside our service network. We are also not responsible for the damage or destruction of user data. We will pursue every detected attack by hackers, etc. under civil law and, if necessary, by the prosecution.

In case of a breach, we will notify; the EU representatives, our DPO, and our users who were or potentially were affected by the breach within 72 hours of the attack. We will get in contact via email thus, it is important that you sign up with a valid email address that you often check so you are notified of any harmful attacks that may occur.

10. Your Rights

You have certain rights around the use of your data, including the ability to opt out of promotional emails, cookies, and the collection of your data by certain analytics providers. You can update or terminate your account from within our Services, and can also contact us for individual rights requests about your personal data.Privacy laws applicable in your country may give you the following rights:

  • Right to be informed: what personal data an organization is processing and why (this notice).
  • Right of access: you can request a copy of your data.
  • Right of rectification: if the data held is inaccurate, you have the right to have it corrected.
  • Right to erasure: you have the right to have your data deleted in certain circumstances.
  • Right to restrict processing: in limited circumstances, you have the right to request that processing is stopped but the data retained.
  • Right to data portability: you can request a copy of your data in a machine-readable form that can be transferred to another provider.
  • Right to object: in certain circumstances (including where data is processed on the basis of legitimate interests or for the purposes of marketing) you may object to that processing.
  • Rights related to automated decision-making including profiling: there are several rights in this area where processing carried out on a solely automated basis results in a decision that has legal or significant effects for the individual. In these circumstances, your rights include the right to ensure that there is human intervention in the decision-making process.
  • The particular rights which are applicable to you (which might include other rights not listed above) may vary depending on your country. You should make yourself aware of the rights you have under applicable privacy laws in your country.

We want you to be in control of your information, so we have provided you with the following tools:

Access / Update tools in the service: Tools and account settings that help you to access, rectify, or delete information that you provided to us, and that’s associated with your account directly within the service.

Device permissions: Mobile platforms have permission systems for specific types of device data and notifications, such as gallery, camera and microphone permissions as well as push notifications. You can change your settings on your device to either consent or oppose the collection of the corresponding information or the display of the corresponding notifications. Of course, if you do that, certain services may lose full functionality.

Deletion: You can delete your account by using the corresponding functionality directly on the service.

We want you to be aware of your privacy rights. Here are a few key points to remember:

Reviewing your information: Applicable privacy laws may give you the right to review the personal information we keep about you (depending on the jurisdiction, this may be called right of access, right of portability, or variations of those terms). You can request a copy of your personal information by sending us an email at [email protected].

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 contact us via [email protected].

For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer the above requests.

Keep in mind, we may reject requests for certain reasons, including if the request is unlawful or if it may infringe on trade secrets or intellectual property or the privacy of another user. If you wish to receive information relating to another user, such as a copy of any messages you received from him or her through our service, the other user will have to contact our Privacy Officer to provide their written consent before the information is released.

Also, we may not be able to accommodate certain requests to object to the processing of personal information, notably where such requests would not allow us to provide our service to you anymore. For instance, we cannot provide our service if we do not have your date of birth.

Uninstall: You can stop all information collected by an app by uninstalling it using the standard uninstall process for your device. If you uninstall the app from your mobile device, the unique identifier associated with your device will continue to be stored. If you reinstall the application on the same mobile device, we will be able to re-associate this identifier from your previous transactions and activities.

Accountability: In certain countries, including in the European Union, you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how we process your personal information. The data protection authority you can lodge a complaint with notably may be that of your habitual residence, where you work, or where we are established.

If you want to exercise any of your rights listed above please visit our Feedback Page or email us at [email protected].

11. Children’s Privacy

Our Services are restricted to users who are 18 years of age or older. We do not permit users under the age of 18 on our platform and we do not knowingly collect personal information from anyone under the age of 18. If you suspect that a user is under the age of 18, please use the reporting mechanism available through the service. If we become aware that a child, minor, or anyone under the age of 18 has registered with us and provided us with personal data, we will take steps to terminate that person’s registration and delete their profile information from our Services. If we do delete a Profile because you violated our no children rule, we may retain basic account and profile information to ensure that you do not try to get around our rules by creating a new profile.

12. International Transfer Policy

In order to provide the Services to you, we must transfer your data to our servers and process it there. By visiting or using our Services, you consent to the storage of your data on servers. If you are using the Services, you consent to the transfer, storage, and processing of your data. Specifically, personal data collected in Switzerland and the European Economic Area (“EEA”) is transferred and stored outside those areas.

That data is also processed outside of Switzerland and the EEA by our group companies, or our service providers, including to process transactions, facilitate payments and provide support services. We have entered into data processing agreements with our service providers that restrict and regulate their processing of your data on our behalf. By submitting your data or using our Services, you consent to this transfer, storage, and processing by us and its processors. We operate a global network of servers including in Germany, the Netherlands, Turkey, and Canada. Data collected by advertising partners may also be held outside the European Economic Area. We ensure that the data is adequately protected by ensuring that valid, legal mechanisms are in place. For European users, if your data is transferred internationally (outside of the EEA), we rely on standard contractual clauses and additional security measures in line with the relevant clauses in the GDPR and the relevant caselaw. If you want more information relating to the nature of the safeguards we have in place please email [email protected].

13. California Privacy Rights

Consumers residing in California have some additional rights with respect to their personal information under the California Consumer Privacy Act (“CCPA”).

Your California Consumer Rights:

California consumers have the right to request access to the specific pieces of personal information we have collected about them in the last 12 months. You may make this request up to two times in a 12-month period. You may also request additional details about our information practices, including the categories of personal information we have collected about you, the categories of sources of such collection, the business or commercial purpose for collecting or selling personal information, the categories of third parties with whom we share and sell your personal information, the categories of personal information we have disclosed and sold about you in the preceding 12 months, and the categories of third parties to whom we sold personal information in the preceding 12 months. If you are a California consumer, you also have the right to request the deletion of your personal information (subject to certain exceptions), to opt-out of sales of personal information (we never sell user information, regardless of the country they are located in) and to receive equal service and price and not be discriminated against even if you exercise any of your CCPA rights.

California consumers may make a rights request by emailing us at [email protected]. Your request must include sufficient information that allows us to reasonably verify you are the person about whom we collected personal information, which may include your email address, name, and username. If you have an account with us, you can find your account id on your main account page after you log in. We will not discriminate against you if you choose to exercise your rights under the CCPA.

14. Privacy Policy Changes

Because we’re always looking for new and innovative ways to help you build meaningful connections, this policy may change over time. We will notify you before any material changes take effect so that you have time to review the changes.

15. Contact Us

If you have any questions regarding this privacy statement, the processing of your personal data, you can contact us directly. We are also available to you in the case of requests for information, requests, or complaints:

Address:

Yesilkoy SB Mah. ISBI Plaza Sokak ISBI Plaza

Bakırkoy/ISTANBUL

E-mail: [email protected]

16. Legal Notice

For European citizens or residents:

You can exercise your rights as a data subject (right to be informed; right of access; right to rectification; right to erasure; right to restriction; right of data portability; and the right to object) by contacting our European representative:

EU Representative

Pursuant to Article 27 of the General Data Protection Regulation (GDPR), Nozy has appointed Naq Cyber B.V. as its GDPR representative in the EU. If you usually reside in an EU Member State you can contact Borlux Ltd regarding matters pertaining to the GDPR by:

Contact: Nadia Kadhim

Address: Vlamingstraat 4, 2712BZ Zoetermeer, Netherlands

Email: [email protected]

When contacting our European representative, always mention our name and the nature of your request or inquiry in the subject of your email.

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