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PRIVACY POLICY

INCINQ Privacy Policy

Welcome to the INCINQ Privacy Policy ("Policy")! This explains how we collect, store, protect, and share your information, and with whom we share it. We suggest you read this in conjunction with our brilliant Terms and Conditions of Use. Whilst you're enjoying the INCINQ mobile application ("App"), we collect some information about you. In addition, you may choose to use the App to share information with other INCINQ users, including your friends and contacts ("Users"). We may also need to share your information sometimes. This Policy explains how we protect your personal data when and if we need to transfer it overseas, so please read very carefully!

If you have any questions or comments about this Policy, please feel free to contact us at info@Incinq.co.

1. COLLECTION OF INFORMATION.

Registration Information

When you download the App and create an account ("Account"), we may collect certain information ("Registration Information") about you, such as:

  • Name;

  • Username;

  • Email address;

  • Mobile number;

  • Gender identity;

  • Date of birth;

  • Sexual preference;

  • Photographs;

  • Location;

You will also be required to create a password in connection with the registration of your Account. Once you register, you will be able to review and change this information at any time by accessing your “Profile” page! You control your user profile and are able to correct or update (other than your email address, mobile number, date of birth, gender and location (which is automatically updated)) your information at any time by just logging in to INCINQ.

The information we collect helps to enhance the App and verify our Users (robots are not welcome!!). Registration Information such as your name and username may be visible to the public on your profile page.

Additional Information

We may ask you to provide your full name, address and email address. Such details may be shared with third parties for purposes relating to, for example, any of our loyalty programmes, sending gifts or delivery of merchandise.

We may also collect additional information in connection with your use of INCINQ, for example if you use our super cool electronic messaging function.

If you contact our Customer Support team, we will receive your email address, and may track your IP address as well as the information you send to us to help resolve your query. We will keep records of our communications with you, including any complaints that we receive from you about other Users (and from other Users about you).

We recommend and encourage you (and all our members) to think carefully about the information you disclose about yourself. We also do not recommend that you put email addresses, URLs, instant messaging details, phone numbers, full names or addresses, credit card details, national identity numbers, drivers' licence details and other sensitive information on your profile which is open to abuse and misuse.

Please be careful about posting sensitive details about yourself on your profile such as your religious denomination and health details. You may also choose to add sensitive information about yourself when you add certain INCINQ Badges to your profile, such as your religion and political leanings. While you may voluntarily provide this information to us when you create your profile, including your sexual preferences, there is no requirement to do so. Please remember that photographs that you post on INCINQ may reveal information about yourself as well. Where you do upload and choose to tell us sensitive information about yourself, including through adding certain Badges to your profile, you are explicitly consenting to our processing of your information and making this public to other users.

When you post information about yourself or use the messaging function, the amount of personal information you share is at your own risk. Please see Section 4 below for more information on who can access what you post on INCINQ. If you post anything that is inconsistent with our Terms and Conditions of Use, we reserve the right to terminate your Account - we really don't want to have to do this so please play by the rules!

For safety and security and to ensure you have the best possible user experience, we require users to verify their accounts and might ask for your phone number. We want to make sure you are not a robot! And we also want to avoid fake INCINQ accounts being created which can be used for malicious activities and cybercrime – they threaten the INCINQ network and spoil things for everyone. We use a third party provider for account verification who will keep your phone number for up to 90 days for fraud identification purposes. We collect and use your phone number on the basis of our legitimate interests identified in section 11 below and for the prevention of fraud.

It is your responsibility to ensure that your account details are kept up to date. If your phone number changes, please ensure that you update this in your account.

To prevent abuse of the app/site, INCINQ uses automated decisions and moderators to block accounts as part of its moderation procedures. In order to do this, we check accounts and messages for content that indicates breaches of our Terms and Conditions of Use. This is done through a combination of automated systems and our team of moderators. If an account or message meets certain criteria that demonstrate that the Terms and Conditions of Use are likely to have been breached, the relevant account will automatically be blocked. All users of accounts that have been blocked will be notified that their account has been blocked and affected users can contact INCINQ to contest the decision..

INCINQ also uses automated decisions to prevent fraudulent payment transactions being processed as part of its anti-fraud procedures. In order to do this, our systems check payment transactions for behaviour that indicates breaches of our Terms and Conditions of Use. If a transaction meets certain criteria that demonstrate that the Terms and Conditions of Use are likely to have been breached and the transaction is likely to be fraudulent, the relevant transaction may automatically be blocked. Where a transaction is blocked, the user will be notified that their transaction cannot be processed and affected users can contact INCINQ to contest the decision.

Please note that if your account is blocked, any account(s) that you have on our other group platforms/applications may also be blocked as part of our anti-spam and anti-fraud procedures.

 

We process some limited data (demographics and information that you have optionally provided us with via INCINQ Badges) to drive targeted advertising in our legitimate interest, via promo cards and ads on our App. We also process limited data (device identifiers) and share this with third party advertising networks which host our ads. You will be able to stop targeted advertising within the “Contact & FAQ” page accessible via your profile. If you opt-out of targeted advertising you will still see adverts though they will be less relevant to you. Through your device’s security settings you also have the option to prevent or limit device identifiers being shared with third party advertisers and what use is made of the device identifiers.

Finally, we want to keep in touch with you to make sure you know about the great promotions and offers we have available. If you’ve told us it’s OK, we will use your email address and phone number to send you information on these. You can withdraw this consent at any time via Settings in the App.

Data Storage

By using the App, you acknowledge that INCINQ is a global app operating through servers located in a number of countries around the world, including the United Kingdom. If you live in a country with data protection laws, the storage of your personal data may not provide you with the same protections as you enjoy in your country of residence.

Geolocation Information

If you turn these features on, when you use your mobile, we will collect information about WiFi access points as well as other location information about your longitude and latitude and may save your device's coordinates to offer certain features to you. This information helps us identify your physical location and we may use it to personalise the App and make it easier for you to interact with other Users, by enabling the information to be displayed and shared with other members choosing to view “nearby” posts.

If you have enabled location services, but wish to turn them off, you can do so by the following methods:

  1. iPhone app — settings, privacy, location services, INCINQ

  2. Android — settings, location, INCINQ, permissions, location

Log and Usage Data

We keep your personal information only as long as we need it for legitimate business purposes (as set out in Section 11 below) and as permitted by applicable law.

In practice, we delete or anonymise your information upon deletion of your account (following the safety retention window), unless:

  1. we must keep it to comply with applicable law (for instance, some “traffic data” is kept for one year to comply with statutory data retention obligations);

  2. 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);

  3. there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or

  4. 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 behaviour or security incidents from opening a new account.

Where INCINQ uses machine learning, for example, to help us detect and prevent fraudulent card transactions, and to detect and prevent spam communications on the App (as explained above), we may need to keep personal information for a longer period than the retention periods explained above, to enable the machine learning to work properly. Where this is the case, we always seek to minimise the amount of personal information that is used and we ensure that it is ring-fenced and kept securely from other user personal information. We regularly review the period for which personal information is required for machine learning purposes and delete any identifiable information when it is no longer required.

Device Information

We may collect information about your device when you use the App including the unique device identifier, device model, operating system, and MAC address. In addition, if you permit us to do so, the App may access your device's address book solely in order to add someone to your contacts.

Links

We may keep track of how you interact with links available on INCINQ including third party services and clients by redirecting clicks or through other means. We may share aggregate click statistics such as how many times a particular link was clicked on.

Cookies

Unlike the chocolate chip kind, these cookies have no calories! They are small data files that are transferred to your computer's hard disk and are basically a tool that stores information about website visits, recognises you and your preferences each time you visit INCINQ, and ensures site functionality and enables us to provide the services our members request.

The cookies we collect enable us to learn how people interact with INCINQ, which in turn helps us make a better product for you! Cookies store information about your website visits and can recognise you and your preferences each time you visit the INCINQ site. They help us to provide a better service to you!

INCINQ's use of cookies and local storage devices is basically related to the performance of INCINQ's site, such as analytics that help us determine how our site is performing and ensuring a smooth and trouble-free experience for our members and visitors.

Below is a table to explain INCINQ's cookie functions and why they’re used.

If for any reason you decide that you do not want all of your INCINQ activities to be stored you may set your browser and mobile settings to block cookies and local storage devices, but please remember that if you do so, you may not be able to access all of the features INCINQ offers!

We use the following types of cookies:

Cookie FunctionsCookie Purposes

Analytics and researchWe use Google Analytics to collect information about how visitors use the site. The cookies collect information in an anonymous form, including the number of visitors to the App, where visitors have come from and the pages they visited. For more information about Google's Privacy Policy, please visit http://www.google.com/intl/en/policies/.

PerformanceWe need to use certain cookies and save data to your local storage devices to ensure our members have the best possible experience. They assist with your navigation of our site, ensuring pages load quickly and respond promptly to your requests – no one likes snail pace technology!

Our use of cookies and local storage devices, including the specific cookie names, may change over time, but will generally fall into the above categories. We will notify you of any important changes to our use of cookies and local storage devices. Please visit this page regularly so that you are aware of any changes.

If you would like to know more about these clever and calorie free cookies, including flash cookies/local storage devices, the following websites provide useful information:

 

2. USE OF INFORMATION.

Our main goal is to ensure your experience on INCINQ is an enjoyable one and you don't end up getting stung! In order to deliver an enjoyable experience to you, we may use your Registration and other information to:

  • offer you our services and features;

  • contact you with information about the App (e.g., updates and new offerings);

  • personalise the App and the content we deliver to you;

  • conduct research and analytics about how you use and interact with the App;

  • resolve disputes between you and other Users; and

  • investigate fraud, protect our legal rights, and to enforce our Terms & Conditions.

3. DISCLOSURE OF INFORMATION.

Our policy is to not disclose your Registration Information, except in the limited circumstances described here:

Circumstances where data may be disclosedDisclosed data

Your Consent – If you consent, we may share or disclose your Registration Information, such as when you use a third party web client or application to access your Account. 

Service Providers - We engage certain trusted third parties to perform functions and provide services to us. We may share your Registration Information with these third parties, but only for the purposes of performing these functions and providing such services e.g. information technology companies (hardware and software) which provide services to support our products and help us with information security matters.This could include all data, including all CCPA Categories listed above

Moderators – To monitor activity on the apps and approve content.Name and user registration details, profile information, content of messages and photographs.

Payment Processing and Telecommunications Companies – To facilitate payments for our premium services.Cardholder name, cardholder address, card number, payment amount, transaction date/time.

Law and Harm - As we mentioned in the Terms & Conditions, we think it is very important that all INCINQ 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 enquiries from within or outside your country of residence where we are required to by law, where there is an investigation into alleged criminal behaviour 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 INCINQ holds about you, depending on the nature of the request or the issue that we are dealing with.

Business Transfers -In the event that INCINQ or any of our 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.This could include all personal data that INCINQ holds about you.

Advertising Partners – To serve targeted advertisements to users.Device ID, geolocation data, demographic data.

Anti-Spam and Anti-Fraud -Your data may be shared with other INCINQ group companies, for example, to block accounts and suspected fraudulent payment transactions as part of our anti-spam and anti-fraud procedures.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. You may opt-out of receiving marketing messages by using the opt-out mechanisms and links provided in each email.

We ensure these parties must adhere to strict data protection and confidentiality provisions that are consistent with this Policy. Measures are taken to ensure that the data shared is non-attributable to the greatest extent possible.

INCINQ does not sell your data and has not sold your personal data in the previous 12 months.

4. WHAT OTHERS MAY SEE ABOUT YOU.

We think INCINQ users are awesome, and we want you to share how awesome you are with the world, so we have built certain features to enable this. Our App is designed to make it easier for you to connect with other Users and to interact with them.  You might share information like the photos and messages you send or upload and any metadata provided with those messages, along with any comments or information you provide in connection with your photos.

When using INCINQ, you should assume that anything you post or submit on the App may be publicly-viewable and accessible, both by Users of the App and non-Users of the App. We want INCINQ users to be careful about posting information that will eventually be made public.

 

5. MODIFYING YOUR REGISTRATION INFORMATION.

You may access or modify the Registration Information you provided at any time or permanently delete your Account (although we really hope you don't!)

When your Account is deactivated, we take reasonable efforts to make sure it is no longer viewable on the App. For up to 30 days it is still possible to restore your Account if it was accidentally or wrongfully deactivated. After 30 days, we begin the process of deleting your Account from our systems. We are not responsible for any information, pictures, comments, or other content that is deleted from our systems resulting from the deactivation of your Account.

To prevent abuse and/or misuse of INCINQ by a User following termination or deletion of a profile/Account we shall retain such information as we deem in our sole discretion may be necessary to ensure that User does not open a new Account and profile in breach of our Terms and Conditions of Use and to ensure compliance with all laws and regulations.

Warning: Even after you remove information from your profile or delete your Account, copies of that information may still be viewable and/or accessed to the extent such information has been previously shared with others, or copied or stored by other Users or to the extent such information has been shared with search engines. We cannot control this, nor do we accept any liability for this. If you have given third party applications or websites access to your personal information they may retain such information to the extent permitted under their terms of service or privacy policies.

Removed and deleted information may persist in backup copies for up to 30 days to enable restoration, but will not be available to others in the meantime.

6. 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 - sorry kids, we know INCINQ is cool, but you'll have to come back when you're old enough!

INCINQ does not knowingly collect any information about or market to children, minors or anyone under the age of 18. If you are less than 18 years old, we request that you do not submit information to us. If we become aware that a child, minor or anyone under the age of 18 has registered with us and provided us with personal information, we will take steps to terminate that person's registration and delete their Registration Information from INCINQ. 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.

7. CHANGES TO THIS POLICY.

As INCINQ evolves, we may revise this Privacy Policy from time to time. The most current version of the policy will govern our use of your information and will always be here. If we make a change to this policy that, in our sole discretion, is material, we will notify you, for example, via an email to the email associated with your Account or by posting a notice within INCINQ. By continuing to access or use the App after those changes become effective, you agree to be bound by the revised Privacy Policy.

8. SECURITY.

Here at INCINQ we pride ourselves on taking commercially reasonable security measures to help protect your information against loss, misuse and unauthorised access, or disclosure. We use reasonable security measures to safeguard the confidentiality of your personal information such as secured servers using firewalls.

Unfortunately no website or Internet transmission is ever completely 100% secure and even we cannot guarantee that unauthorised access, hacking, data loss or other breaches will never occur, but here are some handy tips to help keep your data secure:

  1. Please make sure you log out of your Account after use as you never know who may stumble onto your Account!

  2. Please don't share your social media password with anyone else!

  3. Change your social media password periodically.

If you ever think someone has had access to your social media password, please report it to the relevant social media platform and change your password immediately. We cannot guarantee the security of your personal data while it is being transmitted to our site and any transmission is at your own risk.

WE EXPRESSLY DISCLAIM ANY REPRESENTATION OR WARRANTY, WHETHER EXPRESS OR IMPLIED, WITH RESPECT TO ANY BREACHES OF SECURITY, DAMAGE TO YOUR DEVICE, OR ANY LOSS OR UNAUTHORISED USE OF YOUR REGISTRATION INFORMATION OR OTHER DATA.

 

 

9. YOUR UK AND EU RIGHTS.

Under UK and EU law, you have the right to lodge a complaint with data protection regulators, and the Information Commissioners’ Office (ICO) is the UK’s lead regulator. You can find out how to raise a concern with the ICO by visiting their website at www.ico.org.uk. If you’re within the EU, you may also get in touch with your local Data Protection Regulator who may liaise with the ICO on your behalf.

You have a number of rights under European Data Protection law as detailed below. These rights apply to all of our users:

  1. Right to be informed: what personal data an organisation is processing and why (we provide this information to you in this Privacy Policy).

  2. Right of access: you can request a copy of your data.

  3. Right of rectification: if the data held is inaccurate, you have the right to have it corrected.

  4. Right to erasure: you have the right to have your data deleted in certain circumstances.

  5. Right to restrict processing: in limited circumstances, you have the right to request that processing is stopped but the data retained.

  6. Right to data portability: you can request a copy of your data in a machine-readable form that can be transferred to another provider.

  7. 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.

  8. 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 which 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.

 

How does INCINQ protect my personal data?

INCINQ has implemented appropriate security measures to protect and prevent the loss, misuse, and alteration of the information under our control, including your personal data. Our technical experts at INCINQ work hard to ensure your secure use of our site.

While we take reasonable precautions against possible security breaches of our website, member database and records, no website or Internet transmission is completely secure and we cannot guarantee that unauthorised access, hacking, data loss, or other breaches will never occur. We urge you to take steps to keep your personal data safe (including your password) and to log out of your account after use. If you lose your password or give it out, or another service provider that you use suffers a data breach and you have used the same credentials with that service provider as you have with INCINQ, your personal data may be compromised. 

Where is my personal data kept?

We want you to be able to access INCINQ wherever you happen to be in the world. To enable us to provide that service, we will operate a global network of servers potentially including in the US, Hong Kong, Czech Republic and Russia. The hardware is located in third-party data centres but is owned by INCINQ Labs. 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 such as: EU approved model clauses (which can be found here), and implementing robust contractual standards.

 

Does INCINQ use my personal data for any other purpose?

We may use material that you post on the open access areas of INCINQ in advertising and promotional materials on our partner sites and partner products. We believe these uses are in line with our legitimate interests in enabling us to improve our site and better tailor your online experience to meet your needs. If we intend to do this, we will contact you for your prior approval.

From time to time we may run surveys for research purposes and we may contact you to find out if you would like to take part. We may also contact you to find out if you would like to take part in marketing campaigns. Such surveys and marketing campaigns are optional and more information will be provided at the point of contact. We may also contact you for feedback purposes. If you do not wish to be contacted to take part in a survey or marketing campaign, please contact our Customer Support Team via Feedback Page.

We use your personal data to resolve disputes, troubleshoot problems and enforce our Terms and Conditions.

Under EU and UK data protection laws, we are only permitted to use your data when we have a lawful basis to do so. The table below provides an overview of the legal bases that we rely on to use your data. Where the legal basis is consent, you can withdraw consent at any time. Where the legal basis is legitimate interests, you have a right to object to our use of your data. We explain in the relevant sections in this Policy how you can withdraw consent or opt-out of certain data uses (where applicable).