Privacy Policy
1. Introduction
1.1. This Privacy Policy (hereinafter referred to as "Policy") applies to our videochat application
– Alma (hereinafter referred to as "Service"). The term "Service" also includes and refers to
web-sites https://www.Alma-app.co/
1.2. We are committed to safeguarding the privacy of our data-subjects ("you" or "User"); in this
Policy we explain how your personal data, meaning any information relating to you as an identified
or identifiable natural person, that we may hold about you, is collected, used, stored, disclosed,
and removed (each and all referred to as "processing"). Under this Policy, we may use your personal
data in order to: (a) Identify the User; (b) Provide the User with our Service; (c) Inform the User
about our new services and promotions; (d) Support, protect and improve our Service; (e) Protect our
legitimate interests as well the Users’. For more information please read the Section 2 of this
Policy.
1.3. This Policy only applies to the information we process. It does not apply to the practices of
companies that we don't own or control, or employees that we don't manage. Information available via
our Service may contain links to third party applications or websites, and any information you
provide to those sites will be covered by any privacy policies they may have. Please be sure to read
the privacy policies of any third-party applications and/or sites you visit. It is those sites'
responsibility to protect any information you give them, so we can't be held liable for their
wrongful use of your personally identifying information.
1.4. We may update this Policy from time to time and will notify you of changes to the Policy
affecting your rights by email and/or by posting on our website at
https://www.Alma-app.co/privacy.html.
2. Your Personal Data and How We Use It In this Section 2 we set out: (a) the general categories of
data and types of personal data that we may process; (b) the source of that personal data; (c) the
purposes for which we may process personal data; and (d) the legal bases of the processing.
2.1. We may process your registration data. Registration data may include: your full name, photo
(your "avatar"), ID, username and email address, gender, date of birth, country, region and city of
residence as well as your social network account data. The source of the data is you. Registration
data is required in order for you to be able to access and use the Service. The legal bases for this
processing are consent and the performance of a contract between you and us and/or taking steps, at
your request, to enter into such a contract.
2.2. We may process your PC or software data. All the personal data that is automatically sent by
User’s installed software, including: the User’s IP address, cookies files content, personal data
that is sent by browser or another software that allows you to access our Service, as well as
date/time and your requested page URL, E-wallet ID, CSP name and exact date/time of the SMS-message
sent and its content as well. If you buy products or services from us, we may collect your first and
last name, partial credit card number and/or other payment information. The legal bases for this
processing are consent and the performance of a contract between you and us and/or taking steps, at
your request, to enter into such a contract. We use our commercially reasonable efforts to make sure
your credit card number and other payment information is kept strictly confidential by using only
third-party billing services that are GDPR compliant and use industrystandard encryption technology
to protect your credit card number from unauthorized use.
2.3. We may process your usage data. Usage data is data about your use of the Service. Usage data is
primarily non-personally- identifying information of the sort that web browsers, servers, and
services like Google Analytics typically make available, such as the browser type, language
preference, referring site, and the time of each visit. Other information that we might have access
to includes how you use the Service (e.g. search queries), your approximate location, etc. Usage
data may include: 1) Data that we collect mainly for behaviour statistics, business intelligence and
email campaigns ("analytics data"). We gather the Service traffic data with the help of Google
Analytics. 2) Data that we collect mainly for technical, security and/or fraud prevention reasons or
for tracking errors ("technical data"). The legal basis for this processing is our legitimate
interests and/or by third-parties, namely to monitor the quality of the Service and improve the
Service as well as to prevent, detect and investigate fraud, criminal activity or other misuse of
the Service and to prevent security issues.
2.4. We may process your communication data. Communication data is information contained in or
relating to any communication that you send to us or generate through the use of our Service.
Communication data includes: 1) All your messages, requests and other communication with our
Customer Support which may happen during the dispute review process or via support tickets, emails,
or by means of any other communication tool; and 2) All your communications and file attachments or
other data that you generate mainly by communicating to other Users. Communication data may include
email address, username, avatar, IP address, full name, audio and video files and in the case of
manual ID verification: photo of the User’s personal ID, photo of the User and photo of the User’s
utility bill or related document. Our system may also randomly take screenshots of your
communications with other Users. The communication data may be processed for the purposes of
communicating with you, record-keeping, in order to review and resolve disputes, prevent illegal and
objectionable behavior, serve our customers better and improve our Service. The legal bases for this
processing is our legitimate interests, namely the proper administration of our Service and
business, prevention of illegal and/or immoral behaviour.
2.5. We may process your notification data. Notification data is information that you provide to us
for the purpose of subscribing to our email notifications, SMS notifications and/or newsletters. The
notification data may include your email address, phone number, username and full name. The
notification data may be processed for the purposes of sending you the relevant notifications and/or
newsletters. The legal bases for this processing is consent. You can unsubscribe at any point by
contacting us, unchecking a box in your Profile Settings or by clicking the unsubscribe link in the
email.
2.6. We may process any of your personal data when necessary for the establishment, exercise or
defence of legal claims, whether in court proceedings or outside the court procedure. This may
include using information for legal compliance, litigation or prelitigation, security monitoring and
investigation. You agree that your personal data may also be used as evidence that the Service was
actually used by you in case a dispute arises between us and the User. The legal basis for this
processing is our legitimate interests, namely the protection and assertion of our legal rights,
your legal rights and the legal rights of others. In addition to the specific purposes for which we
may process your personal data set out in this Section 2, we may also process any of your personal
data where such processing is necessary in order to protect your vital interests or the vital
interests of another natural person. The company does not determine the validity of the personal
data provided by you, we assume that you provide the accurate personal data and keep it updated.
Please try to avoid supplying any unnecessary personal data to us.
3. Information You Choose to Display Publicly via Our Service
3.1. Some Users may elect to publicly post personally identifying or sensitive information about
themselves in their normal use of our Service. This could occur through use of optional profile
fields, interactions in chats, or if a previously private interaction is made public. Information
like that, which is voluntarily posted in publicly visible parts of our Service, is considered to be
public, even if it would otherwise be considered to be personally identifying or sensitive.
Voluntarily publicizing such information means that you lose any privacy rights you might normally
have with regards to that information.
3.2. Please also remember that if you choose to provide personally identifiable information using
certain public features of our Service, individuals reading such information may use or disclose it
to other individuals or entities without our control and without your knowledge, and search engines
may index that information. We therefore urge you to think carefully about including any specific
information you may deem private in content that you create or information that you submit through
our Service.
4. Providing Your Personal Data to Others In this Section 4 we set out: (a) Third parties’ access
grounds to your personal data; (b) External services ("processors") that we use for processing
personal data on behalf of us; (c) Types of personal data that processors may process; (d) The
reason for using them.
4.1. Expect as provided by law, the Company undertakes not to sell, rent, exchange or otherwise
transfer personal data of Users to third parties without explicit consent of the Users.
4.2. We have the right to grant access to the User’s personal data to a third party under the
following circumstances:
4.2.1. A User has expressed one’s explicit consent to transfer personal data to third parties;
4.2.2. The transfer of the personal data is required for User’s use of the Service. In these cases,
we settle a claim with a third party to keep confidentiality of your personal data.
4.2.3. For processing payments, we use services provided by the following entity: (a) Comewell
Limited – located in the UK. The Registered Office of the Company is situated at: Office 3 Unit R1
Penfold Works, Imperial Way, Watford, WD24 4YY, United Kingdom.
4.3. For behaviour statistics, business intelligence and email campaigns we use the service by
Google LLC ("Google Analytics"), a company located in the United States. Data that we may provide to
Google Analytics may include your IP address and that data is used by Google Analytics to generate
information about your usage of our Service.
4.4. In addition to the specific disclosures of personal data set out in this Section 4, we may also
disclose your personal data: (a) to our auditors, lawyers, accountants, consultants and other
professional advisors insofar as it is reasonably necessary for the purposes of obtaining
professional advice or managing legal disputes and risks; (b) where such disclosure is necessary for
compliance with a legal obligation to which we are subject, or in order to protect your vital
interests and/or the vital interests of a third-party. (с) As necessary to comply with applicable
law or as part of a merger, acquisition, or sale of assets with notice to users.
5. Links from other Websites
5.1. Other websites may contain links to our Service. We use our commercially reasonable efforts to
make sure that they are not involved in any illegal activities and are GDPR compliant. Yet, these
websites are not under our control and are not subject to this Privacy Policy. They will likely have
their own privacy notices and terms of use. We have no responsibility for these websites. You
acknowledge that your use of and access to these websites are solely at your risk. It is your
responsibility to check the privacy notices of these websites to see how they treat your personal
data.
6. Protecting Children’s Privacy
6.1. Though our Service is not designed for use by anyone under the age of 18, we realize that a
child of such age can make an attempt to access it. We do not knowingly collect personal data from
the children under the age of 18, and we undertake all the possible measures in order to avoid the
access to our Service of people of the mentioned above age limit. If you are a parent or guardian
and believe that your child is using our Service, please contact us. Before removing any
information, we may ask for a proof of identification to prevent malicious removal of the account
details. If we discover that a child is using our Service, we will delete their information within a
reasonable period of time. You acknowledge that we accept the ID information of our Users "AS IS" to
verify their age – we do not bear any liability if such information is incorrect. To learn more
about our Retention Policy please read Section 9.
7. Unlawful Activity
7.1. We are entitled to investigate complaints or reported violations and to take any action we deem
appropriate, including, but not limited to, reporting any suspected unlawful activity to law
enforcement officials, regulators, or other third parties and disclosing any information necessary
or appropriate to such persons or entities relating to your profile, email addresses, usage history,
posted materials, IP addresses, and traffic information.
8. International Transfers of Your Personal Data
8.1. We store your information primarily within the European Economic Area. However, some features
and requirements of the service, involve transferring your information to third-party service
providers outside the European Economic Area. We have described all those service providers above in
the Section 4. Where such service providers are not established in a country ensuring an adequate
level of protection within the meaning of Regulation (EU) 2016/679, the transfers will be covered by
the standard data protection clauses adopted by the European Commission or by another appropriate
safeguard mechanism such as the Privacy Shield Framework.
9. Retaining and Deleting Personal Data This Section 9 sets out our data retention and deletion
policies, which are designed to help ensure that we comply with our legal obligations in relation to
the User’s right to be forgotten.
9.1. Personal data that we process for any purpose or purposes shall not be kept for longer than is
necessary for that purpose or those purposes.
9.2. Users may request the deletion of their account through our Service.
9.3. We will retain and delete your personal data as follows:
9.3.1. For all users who have deleted their account: (a) Personally-identifiable analytics data is
removed 30 days after account deletion. (b) Your public profile will be hidden 30 days after you
delete your account. (c) Your communication data will be deleted 5 years after you delete your
account. The screenshots that our system randomly takes in order for us to track and prevent illegal
and objectionable User behaviour are being constantly overwritten and are stored for 90 days. (d)
Your registration data, account data, ID data, trade data and technical data will be deleted 5 years
after you delete your account.
9.4. In some cases, it is not possible for us to specify in advance the periods for which your
personal data will be retained. In such cases, we will determine the period of retention based on
the period we need to access the data for the provision of services, receiving payment, resolving
your customer support issue or other issues or for any other auditing or legal reasons.
9.5. Notwithstanding the other provisions of this Section 9, we may retain your personal data for a
reasonable period of time where such retention is necessary for compliance with a legal obligation
to which we are subject, or in order to protect your vital interests or the vital interests of
another natural person.
10. Your Rights In this Section 10, we have summarised the principal rights that you have under data
protection law. Some of the rights are complex, might contain restrictions depending on the legal
basis for processing the data and not all of the details have been included in our summaries.
Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a
full explanation of these rights.
10.1. Your principal rights under data protection law are: (a) the right to access; You have the
right to confirmation as to whether or not we process your personal data and, where we do, access to
the personal data. Providing the rights and freedoms of others are not affected, we will supply to
you a copy of your personal data. The first copy will be provided free of charge, but additional
copies may be subject to a reasonable fee. You can ask for your personal data by contacting our
Customer Support. (b) the right to rectification; You have the right to have any inaccurate personal
data about you rectified and, taking into account the purposes of the processing, to have any
incomplete personal data about you completed. (c) the right to erasure; You have the right to the
erasure of your personal data. We have described our policy for retaining and deleting personal data
above in Section 9. (d) the right to object to processing; You have the right to object to our
processing of your personal data on grounds relating to your particular situation, but only to the
extent that the legal basis for the processing is that the processing is necessary for: the
performance of a task carried out in the public interest or in the exercise of any official
authority vested in us; or the purposes of the legitimate interests pursued by us or by a third
party. If you make such an objection, we will cease to process the personal information unless we
can demonstrate compelling legitimate grounds for the processing which override your interests,
rights and freedoms, or the processing is for the establishment, exercise or defence of legal
claims. (e) the right to restriction; You can request that your data no longer be processed in
certain cases, for instance, when you exercise your right to object as described above, or when you
contest the accuracy of your personal data processed by us. (f) the right to data portability; To
the extent that the legal basis for our processing of your personal data is consent, and such
processing is carried out by automated means, you have the right to receive your personal data from
us in a structured, commonly used and machine-readable format. However, this right does not apply
where it would adversely affect the rights and freedoms of others. (g) the right to complain to a
supervisory authority; If you consider that our processing of your personal information infringes
data protection laws, you have a legal right to lodge a complaint with a supervisory authority
responsible for data protection. You may do so in the EU member state of your habitual residence,
your place of work or the place of the alleged infringement. (h) the right to withdraw consent. To
the extent that the legal basis for our processing of your personal information is consent, you have
the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of
processing before the withdrawal. Without prejudice to the aforementioned, if we have reasonable
doubts concerning the identity of a user exercising their rights referred to in Section 10.1 or if
we otherwise due to security reasons deem it necessary, we may request the provision of additional
information and otherwise use all reasonable measures necessary to confirm the identity of the user.
You may exercise any of your rights in relation to your personal data by contacting our Customer
Support. Concerning "Right to erasure" users are also able to request the deletion of their account
through our Service.
11. Cookie Policy
11.1. What are cookies? As is common practice with almost all professional websites, this Service
uses cookies, which are tiny files that are saved to your web browser, to improve your experience
and to enable certain features, such as authentication. This page describes what information they
gather, how we use them and why we sometimes need to store these cookies. We will also share how you
can prevent these cookies from being stored, however this may downgrade or 'break' certain elements
of the Service’s functionality. Cookies may be either "persistent" cookies or "session" cookies: a
persistent cookie will be stored by a web browser and will remain valid until its set expiry date,
unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire
at the end of the user session, when the web browser is closed. Cookies do not typically contain any
information that personally identifies a user, but personal information that we store about you may
be linked to the information stored in and obtained from cookies.
11.2. Cookies that we use If you create an account with us then we will use cookies for the
management of the signup process, for general administration and for preventing abuse and misuse of
our Service. We use cookies when you are logged in so that we can remember this fact. This prevents
you from having to log in every single time you visit a new page. These cookies are typically
removed or cleared when you log out to ensure that you can only access restricted features and areas
when logged in. When you submit data through a form, cookies may be set to remember your user
details for future correspondence. In order to provide you with a great experience, we provide the
functionality to set your preferences for how the Service runs when you use it. In order to remember
your preferences we need to set cookies so that this information can be called whenever you interact
with a page that is affected by your preferences. We run an affiliate programme and as a part of it
affiliates advertise our Service. With the affiliate programme we use tracking cookies to track
users who visit our site through one of our affiliate partner sites in order to credit them
appropriately, and where applicable, allow our affiliate partners to provide you with a bonus for
making a purchase.
11.3. Cookies used by our service providers We use Google Analytics to analyse the use of our
Service. Google Analytics, among other methods, also gathers information about Service use by means
of cookies. The information gathered relating to our Service is used to create reports about the use
of our Service and how we might improve your experience. These cookies may track things such as how
long you spend on the site and the pages that you visit. Google's privacy policy is available at
www.google.com/policies/privacy/.
11.4. Managing cookies You can prevent the setting of cookies by adjusting the settings on your
browser (see your browser Help for how to do this). Disabling cookies will result in disabling most
features of this Service. Therefore, it is recommended that you do not disable cookies.
12. Collection of Users' Contact List
We understand the importance of privacy and are committed to protecting the personal information of
our users. As part of the functionality of our app, Alma, we may collect and access the contact list
on your device. This is done solely for the purpose of facilitating seamless communication and
enhancing your user experience within the app.
The contact list information collected may include names, phone numbers, email addresses, and other
relevant contact details stored on your device. Please note that we do not share this information
with any third parties without your explicit consent.
We assure you that we handle this data with the utmost care and adhere to applicable privacy laws
and regulations. We use industry-standard security measures to safeguard your contact list
information from unauthorized access, disclosure, alteration, or destruction.
By using Alma and granting access to your contact list, you acknowledge and agree to the collection,
storage, and processing of this information as described in this privacy policy.
If you wish to revoke our access to your contact list, you can do so by adjusting the app
permissions in your device settings or by contacting our support team.
We reserve the right to update and modify this privacy policy as needed. We encourage you to review
the policy periodically to stay informed about how we handle your personal information.
If you have any concerns or questions regarding the collection or use of your contact list
information, please don't hesitate to contact us through the provided channels.
Note: It is important to consult with a legal professional or privacy expert to ensure that your
privacy policy complies with relevant laws and regulations in your jurisdiction and covers all
necessary aspects of data collection and privacy protection.