Privacy policy

Privacy Policy

Last Updated: April 25th, 2017

Pomvom Ltd. (“Pomvom”, “we”, “our” or “us”) respects the privacy of its users (“User(s)” or “you”). This Privacy Policy is to inform you what information we collect when you visit our website at www.pomvom.com (the “Site”)and to our downloadable mobile application (the “Service”).


Capitalized terms which are not defined herein, shall have the meaning ascribed to them in our Terms of Use available at Terms which this Privacy Policy is incorporated thereto by reference (together, the “Terms”).

BY ACCESSING AND/OR USING THE SITE AND/OR SERVICE, YOU AGREE TO THE TERMS AND CONDITIONS SET FORTH IN THIS PRIVACY POLICY (THE “PRIVACY POLICY”), INCLUDING TO THE COLLECTION AND PROCESSING OF YOUR PERSONAL INFORMATION (AS DEFINED BELOW). IF YOU DISAGREE TO ANY TERM PROVIDED HEREIN, YOU MAY NOT USE THE SERVICES.

INFORMATION WE MAY COLLECT

We may collect two types of data and information from our Users. The first type of information is non-identifiable and anonymous information (“Non-Personal Information”). We are not aware of the identity of the User from which we have collected the Non-Personal Information. Non-Personal Information is any unconcealed information which is available to us while Users are using the Service. Non-Personal Information which is being gathered consists of technical information and behavioral information, and may contain, among other things, the activity of the User on the Service, type of operation system and browser, type of mobile device, and operating system version, User’s screen resolution, duration of usage of the App, User's 'click-stream' on the Site and/or Service, keyboard language, etc.

The second type of information is individually identifiable information (“Personal Information”). This information may identify an individual or may be of a private and/or sensitive nature such as User’s name, email address, phone number, identifying profile picture (“Selfie”), photographs (i) automatically uploaded from User’s photo gallery on User’s mobile device and/or (ii) uploaded or capture by you or other Users using the Service, UDID, User IP address, mainly for enhancing the User's experience and for geo-location and security purposes as further detailed below and any independently User-provided personal details.

For avoidance of doubt, any Non-Personal Information connected or linked to any Personal Information shall be deemed as Personal Information as long as such connection or linkage exists.

We do not collect any Personal Information from you or related to you without your approval, which is obtained, inter alia, through your active acceptance to the Terms.

HOW WE COLLECT INFORMATION ON OUR USERS

There are two main methods we use:

Use of the Service. When you use the Service, we collect Non-Personal Information derived from information we receive from third party providers. We also collect Non-Personal Information when you access or use the Service. In other words, we are aware of your usage of the Service and may gather, collect and record the information relating to such usage, either independently or through the help of third-party services as detailed below.

We will collect Personal Information when you register for use of the Service by information you input directly. When you use the Service, we may also collect Personal Information such as photographs captured by User Contacts in which you are facially recognized You may actively grant us access to all the contacts in your mobile device such access may be revoked by the User at any item upon notice to Pomvom, some of which may qualify as Personal Information.

IT IS THE YOUR SOLE RESPONSIBILITY TO OBTAIN ANY AND ALL CONSENTS REQUIRED UNDER ANY APPLICABLE LAWS, REGARDING THE ACCESSING OF ANY PERSONAL INFORMATION OF OTHERS WHICH IS PART OF THE SERVICE, AND TO ADHERE TO ANY APPLICABLE STATE AND FEDERAL LAWS REGARDING SUCH INFORMATION.

Voluntarily Provided. We may collect Personal Information which you voluntarily provide when you use the Service. By registering for an Account you agree we may store the Personal Information and Non-Personal Information either independently or through our authorized third-party service providers as detailed below.

HOW WE USE YOUR INFORMATION

Your information is collected for purposes, which include without limitation the following: (i) to provide you with and operate the Service, including for sharing your photographs with others and for statistical and research purposes; (ii) to personalize the content provided to you; (iii) to develop, improve and custom the Service and offering available through the Services; (iv) to be able to contact Users for the purpose of providing them with technical assistance, support, and collect feedback; (v) to be able to reply to User online queries or governmental agencies’ requests; (vi) for customization and improvement of the Service’s accuracy and interface; and (vii) to comply with any applicable rule or regulation.

SHARING INFORMATION WITH THIRD PARTIES

Pomvom will not share any Personal Information it collects with any third party. Notwithstanding, Pomvom may disclose Personal Information in the following cases: (i) to satisfy any applicable law, regulation, legal process, subpoena or governmental request; (ii) to enforce this Privacy Policy and/or the Terms of Use, including investigation of potential violations thereof; (iii) to detect, prevent, or otherwise address fraud, security or technical issues; (iv) to respond to User's support requests; (v) respond to claims that any content available on Pomvom’s Service violates the rights of third-parties; (vi) to respond to claims that contact information (e.g. name, e-mail address, etc.) of a third-party has been posted or transmitted without their consent or as a form of harassment; (vii) to protect the rights, property, or personal safety of Pomvom, its Users, or the general public; (viii) when Pomvom is undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of its assets; or (ix) to collect, hold and/or manage your Personal Information through Pomvom’s authorized third party service providers, as reasonable for business purposes, which may be located in a country that does not have the same data protection laws as your jurisdiction; (x) pursuant to your explicit approval prior to the disclosure; (xi) cooperate with third parties for the purpose of enhancing the User's experience; or (xii) to authorized third party service providers solely for the purpose of providing you with the Service.

For avoidance of doubt, Pomvom may transfer and disclose or otherwise use Non-Personal Information or information which is linked to anonymous random identifiers or information that is aggregated in a non-identifiable way, at its own discretion.

DELETION OR MODIFICATION OF PERSONAL INFORMATION

If for any reason you wish to modify or delete your Personal Information please contact us at: support@pomvom.com and we will make reasonable efforts to modify or delete any such Personal Information pursuant to any applicable privacy laws. Pomvom may store photographs taken using the Service for a limited time pursuant to Pomvom’s retention and deletion policy. Pomvom is not obligated to maintain back-ups of such photographs. It is your sole responsibility to store any of your photographs taken using the Pomvom Service.

Note that unless you instruct us otherwise we may retain your Personal Information for a period of seven (7) years. Please note, upon request to delete your account, Pomvom may depersonalize your Account activity history for the purpose of enhancing and improving our Services. Pomvom reserves the right, at its sole discretion, to delete any User Account if it has been inactive for over ninety (90) days.

THIRD PARTY SOFTWARE/SERVICE

While using the Service we may be using third party software and/or service for various needs, inter alia, in order to collect and/or process the information detailed herein (the “Third Party Service Provider”). Furthermore, Pomvom is using Third Party Service Providers for facial recognition technology allowing for the Pomvom Service. Note that these are independent software and/or service providers and Pomvom does not take any liability about the information collection policies of these providers, or about any kind of issue, legal or otherwise, relating thereto. Third Party Service Provider’s includes without limitation, Modulus.io, which privacy policy is available at https://modulus.io/legal/privacy-policy; Cloudinary.com, which privacy policy is available at http://cloudinary.com/privacy; and Skybiometry, which privacy policy is available at https://skybiometry.com/Home/PrivacyPolicy.

DIRECT MARKETING

You hereby agree that we may use your contact details for the purpose of informing you regarding our products and Services, which may interest you, and to send to you other marketing material, transmitted to the email address or to the mobile device. You may withdraw your consent contacting us at: support@pomvom.com.

SECURITY

We take a great care in implementing and maintaining the security of Pomvom's Service and its User's Personal Information. Pomvom employs industry standard procedures and policies to ensure the safety of its Users’ Personal Information, and prevent unauthorized use of any such information. We do not, however, guarantee that unauthorized access will never occur.

PROTECTING CHILDREN

You must be at least thirteen (13) years of age to use the Service. By agreeing to these Terms, you represent and warrant to us: (i) that you are at least thirteen (13) years of age; (ii) that you have not previously been suspended or removed from the Service; and (iii) that your registration and your use of the Service is in compliance with any and all applicable laws and regulations. Please note that in certain jurisdiction a minor is considered any person under the age of eighteen (18) and in such jurisdictions the above representations shall apply.

If you are using the Service on behalf of an entity, organization, or company, you represent and warrant that you have the authority to bind such organization to these Terms and you agree to be bound by these Terms on behalf of such organization.

CHANGES TO THE PRIVACY POLICY

The terms of this Privacy Policy will govern the use of the Service and any information collected therein. Pomvom reserves the right to change this policy at any time, so please re-visit this page frequently. In the event of any substantial change of this policy, we will make reasonable efforts to post a clear notice on the Site. Such substantial changes will take effect seven (7) days after such notice was provided on our Services or sent by email. Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Updated” date and your continued use of the Services after the Last Updated date will constitute acceptance of, and agreement to be bound by, those changes.

ADDITIONAL INFORMATION AND CONTACT US

If you have any questions (or comments) concerning this Privacy Policy, you are welcome to send us an email at: support@pomvom.com and we will make an effort to reply within a reasonable timeframe.

By contacting Pomvom you warrant and agree that you are free to do so, and that you do not provide Pomvom with information, which violate any third party intellectual rights (the “Information”). Without degrading from the aforesaid, all rights, including intellectual property, arising from the communication will be owned by Pomvom and will be considered as Pomvom’s confidential material. It is clarified that any use of the Information, will be done in Pomvom’s sole discretion, and Pomvom is not obligated to use all or part of this Information.