DATA WE COLLECT ABOUT YOU
We may collect and receive different kinds of personal data about you when you use the App or Services or from third parties. Personal data means information relating to an identified or identifiable natural person. Personal data does not include information that has been deidentified, pseudonymized or anonymized to the extent permitted by applicable law.
The types of personal data and other data we collect include the following:
Identity data, such as your name, date of birth, age, gender and employment.
Contact data, such as your name, email address, postal address and telephone number.
Content data, such as information stored on your device, name, photos, social media handles or other digital content including text.
Relationship and other potentially sensitive data, such as your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, and trade union membership; information about your health; and genetic and biometric data.
Financial and transaction data, such as details about payments to and from you and details of in-App purchases.
Device data, such as the type of mobile device you use, a unique device identifier (for example, your device's IDFA, IMEA and UDID number or the mobile phone number used by the device), mobile network information, your mobile operating system, and time zone setting.
Usage Data, such as your use of the App including, but not limited to, traffic data and other communication data and the resources that you access.
Location data, such as your current or recent location disclosed by GPS technology.
Profile data, such as your name, in-App purchase history, preferences, feedback, device, name, photos, social media handles or other digital content including text.
Marketing and communications data, such as updates from us and your marketing preferences.
We also collect, use and share aggregated data, such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data as aggregated data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific App feature.
We do not intentionally collect any information about criminal convictions and offences. However, if you voluntarily include such data as part of your public profile, we will process this data pursuant to the terms of this Policy.
SOURCES OF DATA COLLECTION
We collect personal data and other data about you from the following sources:
Information you give us. You give us information (such as identity, contact and profile information) by filling in forms on the App and the Services or by corresponding with us (for example, by email or chat). You give us information when you register to use the App, subscribe to any of our Services, search for an App or Service, make an in-App purchase, share data via the App's social media functions, enter a competition, promotion or survey and when you report a problem with the App or our Services. You are not obligated to provide us with your personal data in all of the cases described above. However, without your personal data, you may not be able to use the App or some Services. For example, you may not register or create an account on the App without providing certain personal data, such as your name and age.
Information we collect about you and your device. When you use the App or Services, we automatically collect data about your device and usage information using cookies and other technologies. Please see the Cookies and Similar Technologies section below for further details. When you install or uninstall a Service containing a unique application number or when a Service searches for automatic updates, that number and information about your installation, such as the type of operating system, may be sent to us.Location Data. We use GPS technology on your device to determine your current location. The App and Services require location data to function. You can turn off location visibility at any time in the settings button from the App’s main menu or disable location services on your device; however, doing so means you will be unable to use the App or the Services. Among other purposes, your location data is necessary in order to permit other users to search for users in their own region. In addition, if you have background location services enabled on your device, the App will use these services to determine if you have changed your location in order to allow you to search for users in your area or for other users to identify that you are in their area. You can disable background location services in your device’s settings, but this might restrict the effectiveness or functionality of the App or Services.
Information we receive from other sources including third parties and publicly available sources. We receive personal data and other data about you from various third parties, including:Identity and contact data from social media and other sites, such as Facebook, that you may use to create an account or log-in on the App.
Identity and contact data from companies that refer you to the App, such as Conversion Squared Corporation.
Device and usage data from analytics providers such as Google, Kochava and Segment. You can review how these providers use this information and rights you may have by reviewing their privacy policies here:
Contact, financial and transaction data from providers of technical, payment and delivery services such as Apple and Google.
Third parties who provide targeted advertising using cookies and other tracking technologies for retargeting on third party websites and services such as Facebook, Google, Snapchat, Reddit, and Pinterest.We may combine data we receive from third parties with personal data and other data that we have collected from you.
COOKIES AND SIMILAR TECHNOLOGY
We use biometrics tracking technologies by allowing third parties to use this data to accurately place a puzzle on your face in your chosen images on your profile in the App. This data is not stored by the App or Jigsaw and this data is transferred directly to third parties Google Cloud and Amazon Web Services. You can choose to consent to these terms in The App.
HOW WE USE YOUR DATA
We use your personal data and other data for the following purposes:
To install the App and register you as a new App user.
To manage our relationship with you, including notifying you of changes to the App or any Services.
To respond to your email, chat, text or telephone inquiries.
To process in-App purchases and deliver Services.To deliver content to you.
To enable you to participate in a prize draw or competition or complete a survey.
To administer and protect our business and the App and Services, including troubleshooting, data analysis and system testing.
To make recommendations to you about goods or services which may interest you.
To monitor trends so we can improve the App and develop new products and services.
To deliver product updates and activity to you.To measure and analyze the effectiveness of the updates we serve you.
To monitor trends and usage so we can improve the App.
To administer, fulfill and enforce contractual obligations.
To estimate your liveness based on your facial image. This is so that we can ensure any verification images provided are not spoofed and all users are real. To do this we collect a selfie from you as part of our app onboarding process. We only share your selfie with our partner Yoti (Yoti USA Inc for US users and Yoti Limited for non-US users).
For compliance purposes and legal obligations, such as validating identity, complying with legal and regulatory requirements, protecting and defending us and our affiliates against legal actions or claims, and preventing fraud.
DISCLOSURES OF YOUR PERSONAL DATA
We do not sell your personal data to third parties for their own marketing purposes without your express consent.
We may share your personal data with third parties as follows:
Service providers we have engaged to provide services to us, including information technology and system administration services such as Amazon Web Services and Google (for back-up, storage and hosting).
Google, Kochava and Segment provide analytic services, including providing us insight into user behavior and usage using cookies and other tracking technologies (see Sources of Data Collection above for links to these companies’ privacy policies).
Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
Tax authorities and similar regulators.
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them.
Credit reference agencies and fraud prevention organizations in order to protect the rights, property or safety of us, our users, or others.
Any information that you provide as part of your personal description will be made generally available to the users of the App and will become publicly available knowledge. You should consider very carefully what information you decide to disclose about yourself when using the App. In addition, certain App features and Services include social networking, chat room or forum features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users, and be aware that the third party who operates that plug-in or functionality may collect further personal data about you. Once you submit information about yourself or post information publicly or to other users, we cannot control that information or prevent it from being further published or used by others.
We share nothing else other than the selfie you take for verification with Yoti and Yoti will have no way of linking your selfie to any other data about you. Yoti processes this data in its UK based servers to check liveness, and then returns an estimated liveness result to us. Yoti deletes your selfie immediately once the liveness detection is completed and does not use your selfie for any other purpose at all. We keep your image for a maximum of 24 hours after it is uploaded and it is deleted immediately if you pass Yoti's liveness check. Yoti's privacy centre is available here: https://www.yoti.com/privacy/.
Although we employ technical and organizational controls that we believe are reasonably appropriate to protect your information, we do not guarantee that our security precautions will protect against the loss or misuse of your information. Similarly, we cannot guarantee the privacy of information you transmit over the Internet or devices or that may be collected in transit by others, including contractors that provide services to us.
Any payment transactions on the App or Services will be encrypted using Secured Sockets Layer technology. Where we have given you (or where you have chosen) a password or unique code that enables you to access certain parts of the App or Services, you are responsible for keeping this information confidential. Do not share this information with anyone.
We will retain your information for as long as necessary to provide any services you request; for as long as you accept marketing communications from us; as necessary for the performance of legal agreements; to comply with legal obligations, including document preservation practices; to resolve disputes; during applicable statutes of limitations; in accordance with our internal document retention policy; and for other legitimate purposes. If you need additional information regarding our data retention practices, please contact us at the email or postal address listed below.
We may anonymize your personal data, in which case we may use the data indefinitely.We may elect to delete your personal and other data at any time, such as following a period of inactivity on your account or for other reasons in our discretion.
YOUR RIGHTS AND CHOICES
Opt-Out of Marketing. If you wish to opt-out of receiving marketing solicitations from us, please contact us at the email or postal address listed below. Even if you opt-out, we may still use and share the information we collect for non-marketing purposes.
Unsubscribe from Emails. Our marketing emails will include an automated way for you to opt out (unsubscribe) from marketing emails sent by us. To unsubscribe, please follow the instructions in the email you receive.
Notice to California Residents. If you are a California resident and the California Consumer Privacy Act of 2018 ("CCPA") applies to our processing of your personal data as a business as defined in the CCPA, this section provides additional information to you. This section does not apply to any matters exempted from the CCPA during the period of exemption. If you have a disability and need information on how to access this Policy in an alternative format, please contact us at the email or postal address listed below.
CCPA Categories, Sources, Use and Disclosure of Personal Data: We collect the following categories of personal data listed in the CCPA, and may have collected any or all of this information in the preceding 12 months: (a) identifiers such as name, postal address, email address, and account name; (b) categories described in Cal. Civ. Code § 1798.80(e), such as employment information and telephone number; (c) certain characteristics of protected classifications under California or federal law, such as age over 40, marital status and sex; (d) commercial information, including records of products or services purchased, obtained, or considered; (e) biometric information; (f) Internet or other electronic network activity information, including browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site; (g) geolocation data; (h) professional or employment-related information; and (i) education information, defined as information that is not publicly available personally identifiable information (as defined in 20 U.S.C. § 1232g, 34 C.F.R. Part 99). Refer to the applicable Policy sections above for our practices regarding the sources from whom we collect personal data, the business and commercial purposes for which we use personal data, and to whom we disclose personal data.
CCPA Requests. California residents have the right to make the following requests to the extent permitted by law. These rights have important conditions and exemptions, and we reserve the right to deny or limit the response to these requests to the extent permitted by applicable law. We will not charge fees to handle requests; however, if your requests are manifestly unfounded or excessive, we may deny them or charge you a fee.
Right to Know: You may request that we disclose the following information, applicable to the 12-month period preceding the receipt of your request: (a) categories of your personal data we collected; (b) categories of sources of your personal data; (c) business or commercial purposes for collecting your personal data; (d) categories of third parties with whom we shared your personal data; and (e) specific pieces of your personal data we collected. We are not required to provide this information to the same person more than twice within a 12-month period.
Request to Delete: You have the right to request deletion of your personal data we collected.
Instructions for Submitting Requests. You may submit CCPA requests by emailing or writing to the contact addresses listed below. We will take reasonable steps to verify your identity before responding to any requests, with the level and type of verification depending on the nature of your request and/or the nature of the personal data involved in the request. You may use an authorized agent to submit your request if the agent has your legal power-of-attorney or you provide the agent signed permission, verify your identity with us, and confirm with us that you provided the authorized agent permission to submit the request. We may deny or limit the response to requests where we are unable to verify your identity or the authorized agent’s authority or we suspect fraudulent or malicious activity. You have the right not to receive discriminatory treatment for exercising your CCPA privacy rights.
THIRD-PARTY LINKS, PLUG-INS AND SITES
Our App or Services may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services. Please check these policies before you submit any personal data to these websites or use these services.
If you have any questions about this Policy, or wish to exercise any of your rights herein, please contact us by email or postal mail as follows.
Email address: firstname.lastname@example.org
Postal address: Jigsaw, 91 Great Titchfield Street, London, W1W 6RW
This Policy version was last updated on July 28, 2021. It may change and if it does, these changes will be posted on the App and, where appropriate, notified to you by email or when you next start the App. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or the Services.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.