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Blinqer Privacy Policy

Introduction

Welcome to Blinqer, a communication platform that provides end-to-end encrypted instant messaging, media and content sharing, and allows you to manage profile pages to be displayed to other users (the “Service”). The Services operates through a user mobile app.

This Privacy Policy (“Policy”) explains how information about you is collected and used by the Service, which is developed and operated by Blinqer, Inc. (“Company” or “we”, “us”, “our”).

We are committed to complying with applicable data protection laws, including the California Privacy Rights Act (CPRA).

The Platform is intended only for users of age 13 and above. We do not knowingly collect information or data from children under the age of 13 or knowingly allow minors under the age of 13 to use the Service.

This Policy may be amended from time to time. We will proactively notify you of the updated Policy through the Platform.

Contact us

If you have any questions, comments or concerns regarding this Policy or our processing of your personal information, please contact us at info@blinqer.com.

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What we collect and why

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Scenario: When you register to our Service

Purposes: Providing you with the functionality of the Service, contacting you regarding administrative issues related to the Services, this Policy, our Terms of Service, support and maintenance.

Categories of information processed: Mobile phone number (including country code), nickname/full name, profile photo, authentication status and your devices' unique ID.
We do not collect or use facial biometric data or other face data.

Scenario: When you provide the Service's app with access to your device components

Purposes

Internet access / cellular data / Wi-Fi, because an internet connection is required to use the Service.

Camera, required to upload media directly from your smartphone's camera.

Smartphone storage, required for saving and sharing media/files through the Service

Your contact list, required to sync your current contact list, invite friends and contact registered users.

FaceID Authentication Status, required to allow users to access their chats via Face ID, and set FaceID intervals for blurring the chat.

Device unique ID, required to prevent multiple registrations from a single device.

Screen lock administration, required to send the applicable notification type per user status.

Microphone/Speaker, required to record/play sound recordings sent between users.

Categories of information processed: Images; contact persons; voice recordings.

Scenario: Uploading or sharing user content through the Service

Purposes: Providing you with the sharing functionality you requested

Categories of information processed: Photos, videos, text posts and external links.

Scenario: Contacting us with an inquiry through our Email or Online contact form;

Purposes: Responding to your inquiry; our business development.

Categories of information processed: Mobile phone number, email address, full name, the subject of your inquiry and the text of your message.

Scenario: When you provide us with your feedback and reviews

Purposes: Responding to your feedback and reviews; our business development.

Categories of information processed: Mobile phone number, email address, full name and the feedback or review.

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You do not have a legal obligation to register or to provide us with the above information. However, if you choose not to register or to provide this information to us, we may not be able to fully provide you with the Service, or respond to your inquiry and feedback.

Please use discretion when providing user content that includes the personal information of you or others.

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Methods and sources for collecting your personal information

We collect the personal information from several sources:

  • Directly from you when you register to our Service or when you provide us with information through our email or the online contact form.

  • From our service providers helping us to operate the Service, and through the device you use to access our Service, including through third party cookies and analytics tools, such as internal analytics services, Customer.io, Segment, Mixpanel and AppsFlyer.

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Sharing your personal information

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We will not share your information with third parties, except in the events listed below or when you provide us with your explicit and informed consent.

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Scenario: We will share your information with our service providers who assist us with the internal operations of the Service. These companies are authorized to use your personal information in this context only as necessary to provide these services to us and not for their own promotional purposes

Purposes: Operating the Service and our business

Examples of Third parties involvedProviders, such as Firebase, Customer.io, Segment, Mixpanel and AppsFlyer

Subject to the following additional Policies:

https://firebase.google.com/support/privacy

https://customer.io/legal/privacy-policy/

https://segment.com/docs/privacy/portal/

https://mixpanel.com/legal/privacy-policy/

https://www.appsflyer.com/legal/services-privacy-policy/

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Scenario: We will share your user content with other users of the Service 

Purposes: Providing you the sharing functionality of the Service, when you choose to share content.

Examples of Third parties involved: Other users of the Service

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Scenario: If you abused your rights to use the Service or violated any applicable law while doing business with us

Purposes: Responding to, handling, and mitigating suspected violations of law in connection with our business.

Examples of Third parties involved: Competent authorities, legal counsels, and advisors.

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Scenario: If a judicial, governmental, or regulatory authority requires us to disclose your information.

Purposes: Complying with a binding request from a competent authority.

Examples of Third parties involved: Competent authorities.

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Scenario: If the operation of the Service or our business is organized within a different framework, or through another legal structure or entity.

Purposes: Enabling a structural change in the operation of the Service and our business.

Examples of Third parties involved: The target entity of the merger or acquisition, legal counsels, and advisors.

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Data retention and security

We retain your information for as long as needed to operate the Service, and thereafter as needed for record-keeping matters.

We will retain your information for as long as needed to operate the Service. Thereafter, we will still retain your personal information as necessary to comply with our legal obligations, resolve disputes, establish, and defend legal claims and enforce our agreements. The overall period of retention is approximately 7 years.

We implement measures to secure your information

We implement measures to reduce the risks of damage, loss of information and unauthorized access or use of information, such as end-to-end encryption. However, these measures do not provide absolute information security. Therefore, although efforts are made to secure your personal information, there is no guarantee that it will be immune from information security risks.

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Additional information for individuals in California

If you are an individual residing in California, we provide you with the following information pursuant to the California Privacy Rights Act (CPRA). This is also the information we have collected in the past 12 months.

We do not sell your personal information and have not done so in the past 12 months. We do not share your personal information for cross-context behavioral advertising.

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Categories of personal information: Identifiers

Specific types of personal information collected: Real name, unique personal identifier, online identifier and other similar identifiers

Business Purposes under the CPRA for which the information is used: 

  • Helping to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for these purposes.

  • Debugging to identify and repair errors that impair existing intended functionality.

  • Performing services on behalf of the business, including verifying customer information, providing analytic services, providing storage, or providing similar services on behalf of the business.

  • Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.

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Categories of personal information: Other personal information that identifies, relates to, describes, or is capable of being associated with, a particular individual

Specific types of personal information collected: Mobile phone number used for registration

Business Purposes under the CPRA for which the information is used: 

  • Helping to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for these purposes.

  • Debugging to identify and repair errors that impair existing intended functionality.

  • Performing services on behalf of the business, including verifying customer information, providing analytic services, providing storage, or providing similar services on behalf of the business.

  • Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.

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Categories of personal information: Internet or other electronic network activity information

Specific types of personal information collected: IP address from which you access the Service, time and date of access, type of browser used, language used, links clicked, and actions taken while using the Service. The source of the information is the consumer’s device

Business Purposes under the CPRA for which the information is used: 

  • Helping to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for these purposes.

  • Debugging to identify and repair errors that impair existing intended functionality.

  • Performing services on behalf of the business, including verifying customer information, providing analytic services, providing storage, or providing similar services on behalf of the business.

  • Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.

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Categories of personal information: Audio, electronic, visual or similar information

Specific types of personal information collected: Audio for audio and video recordings, Visual data - from camera - to take profile photos, to make video recordings,

Business Purposes under the CPRA for which the information is used: 

  • Helping to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for these purposes.

  • Debugging to identify and repair errors that impair existing intended functionality.

  • Performing services on behalf of the business, including verifying customer information, providing analytic services, providing storage, or providing similar services on behalf of the business.

  • Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.

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Disclosures to third parties

The chart below explains what is the personal information we disclosed for a business purpose to third parties in the preceding 12 months.

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Categories of personal information (under the CPRA): Identifiers, Internet or other electronic network activity information, Audio, electronic, visual or similar information

Categories of third parties to whom we disclose your information and the specific business or commercial purpose for the disclosure:

  • Our service providers, who will use it only as necessary to assist us in the internal operations of our business and the Service, and not for their own promotional purposes.

  • Cookie providers, for the same purposes indicated in the chart above.

  • Competent authorities, legal counsels, and advisors if you abused your rights to use the Service or violated any applicable law in the course of doing business with us.

  • Judicial, governmental, or regulatory authority if they require us to disclose your information

  • Target entity of the merger or acquisition, legal counsels, and advisors If the operation of the Service or our business is organized within a different framework, or through another legal structure or entity.

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Your rights under the CPRA if you are a resident of California

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Knowing the personal information we collect about you

You have the right to know:

  • The categories of personal information we have collected about you.

  • The categories of sources from which the personal information is collected.

  • Our business or commercial purpose is for collecting personal information.

  • The categories of third parties with whom we share personal information, if any.

  • The specific pieces of personal information we have collected about you.

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Right to deletion

Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:

  • Delete your personal information from our records; and

  • Direct any service providers to delete your personal information from their records.

 

Please note that we may not delete your personal information if it is necessary to:

  • Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us.

  • Help to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for those purposes.

  • Debug to identify and repair errors that impair existing intended functionality.

  • Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.

  • Comply with the California Electronic Communications Privacy Act.

  • Engage in public or peer-reviewed scientific, historical, or statistical research that conforms or adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the ability to complete such research, provided we have obtained your informed consent.

  • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us and compatible with the context in which you provided the information.

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  • Comply with an existing legal obligation.

We also will deny your request to delete if it proves impossible or involves disproportionate effort, or if another exception to the CPRA applies. We will provide you a detailed explanation that includes enough facts to give you a meaningful understanding as to why we cannot comply with the request to delete your information.

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Right to correct inaccurate personal information

If we receive a verifiable request from you to correct your information and we determine the accuracy of the corrected information you provide, we will correct inaccurate personal information that we maintain about you.

In determining the accuracy of the personal information that is the subject of your request to correct, we will consider the totality of the circumstances relating to the contested personal information.

We also may require that you provide documentation if we believe it is necessary to rebut our own documentation that the personal information is accurate.

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We may deny your request to correct in the following cases:

  • We have a good-faith, reasonable, and documented belief that your request to correct is fraudulent or abusive.

  • We determine that the contested personal information is more likely than not accurate based on the totality of the circumstances.

  • Conflict with federal or state law.

  • Other exception to the CPRA.

  • Inadequacy in the required documentation

  • Compliance proves impossible or involves disproportionate effort.

We will provide you a detailed explanation that includes enough facts to give you a meaningful understanding as to why we cannot comply with the request to correct your information.

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Protection against discrimination

You have the right to not be discriminated against by us because you exercised any of your rights under the CPRA.

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 Exercising your CPRA rights by yourself or through an authorized agent

If you would like to exercise any of your CPRA rights as described in this Policy, please contact us by e-mail at: info@blinqer.com.

We will ask you for additional information to confirm your identity and for security purposes, before disclosing the personal data requested to you, by using a two or three points of data verification process, depending on the type of information you require and the nature of your request.

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We may ask you for additional information to confirm your identity and for security purposes, before disclosing the personal data requested to you, by using a two or three points of data verification process, depending on the type of information you require.

You may also designate an authorized agent to make a request under the CPRA on your behalf. To do so, you need to provide the authorized agent with written permission to do so and the agent will need to submit to us proof that they have been authorized by you. We will also require that you verify your own identity, as explained below.

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Do Not Track

Our Do Not Track Notice. We do not currently respond or take any action with respect to web browser “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of Personal Data about a user’s online activities over time and across third-party web sites or online services. We do allow third parties who provide us with analytics tools, to collect Personal Data about a user’s online activities when a user uses the Service.

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We use your Analytics Information to provide you with our Service and to customize your experience.

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