This document is a disclosure in relation to privacy terms from Talent Unlimited Online Services Pvt Ltd. to help you understand what information we collect, how and why we collect this information, how we use the collected information, how the information so collected is secured and how we use our products and services. It also includes information that you may provide to us or the information we obtain automatically from our products and services and your control on aspects of collection of information.
That the Company has a legal/lawful basis of collecting, processing and storage of personal data due to the following -
- We collect information for purpose of providing you service and improved deliverance through our website/app.
- We will collect all requisite information for compliance with legal obligations;
- We share information with our Partner/Customer for the purpose of analytics, feature based services and better deliverance of service;
What information do we collect about you?
We may collect personally identifiable information about you, such as your- full name, phone number, gender, email address, Device ID, image, location, GPS coordinates, Advertising ID, Phone Brand, Phone Model, Memory, Storage, Year Class, Data network type (wifi/cellular), Network bandwidth, Device Language, Device Timezone, Root Status Device IP, event logs on the application, logs for API requests to/ response from the server, Device User Agent when you start using our mobile application. We also collect information regarding location data, user action logs, application API logs, user browsing history, installed apps, etc. The information collection differs as per the operating system of the User and is in consonance with the App Store (iOS) and Play Store (Android) rules and terms as laid down.
When you visit our website or mobile application, we may receive certain information about your behavior including user activity, page content, click/touch, movement, scroll, keystroke activity, gender, name, details provided as About Me, phone number(s), online identity, facebook Id, twitter Id, email, url, Company name and details, job title, addresses, country code, addresses.
If you choose to use our Services or App, we collect your the above-mentioned information with your absolute knowledge, consent and affirmation.
The SDK allows our Customers to collect usage data for its business purposes including, without limitation, improving the Customer's technology, generating revenue by analyzing internet trends, and sharing, transferring, disposing and/or selling anonymized and aggregated versions of such information to third parties.
For more information or to opt-out, please contact us at firstname.lastname@example.org
We collect information under the direction of and with absolute acceptance and knowledge of our customers, and have no direct relationship with the individuals whose data we may process. If you are a client of one of our current customers and would no longer like to be tracked by such customer, please contact the respective customer directly. We may transfer personal information to companies that help us provide our service and we do so with your consent and acceptance. Transfers to subsequent third parties are covered by the service agreements with our customers and is not our liability in any manner whatsoever.
Access And Retention Of Data Controlled By Our Customers: An individual who is a current or former Bobble customer who seeks access or wishes to correct, amend or delete inaccurate data should direct his query to email@example.com An individual who is a client of a current or former Bobble customer who seeks access or wishes to correct, amend or delete inaccurate data should direct his query to to the respective customer first and then, if no response is obtained or such response is not satisfactory, should contact Mr. Sanat Manhas (firstname.lastname@example.org) If we receive a request under this provision, we will acknowledge it within seventy-two (72) business hours and handle it promptly.
We will retain personal data we process on behalf of our customers for as long as needed to provide our services. Bobble will retain this personal information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.
Information We Collect on Behalf of Third Parties: Cookies And Tracking Technologies: Technologies such as: cookies and scripts are used by our partners, affiliates, analytics or service providers. These technologies may be used in analyzing trends, administering the Sites, tracking your movements around the Sites and to gather demographic information about our user-base as a whole. We may receive reports based on the use of these technologies by such companies on an individual as well as aggregated basis.
Who is collecting the data?
The data controller on behalf of the Company is collecting and managing the above-mentioned data.
Why is my information being collected?
This data is collected for the purpose of providing you our services, analytics, identifying you, providing you data-based features, etc. We collect your personal data only after receiving your consent and such consent is taken at multiple stages to avoid dissemination and collection of any unintended data. We collect data from you only after receiving your consent.
What types of information are you collecting?
We collect data directly from you upon your acceptance and confirmation from the data you provide to us while accessing the app/website or while updating your information on the same. We collect the following information to provide you an enhanced user experience and better services as well as to improve our products.
I. Personally identifiable information
We might ask for your personal information like your name, phone number, address, email accounts, photos etc. at different screens in the app, and collect this information automatically using Android’s Identity Permission.
Our Source for collecting information which is used, stored and processed by us are varied and dynamic. We use Keyboard App (Android package name com.touchtalent.bobbleapp and iOS bundle id 972432964), Background cookies and other tracking technologies, to collect your information for processing, usage, storage and servicing.
II. Language Modeling Data
We do NOT capture or store data inputted into secure text fields containing items such as password, credit card number, debit card number, OTP etc.
We capture all keystrokes and gestures input into our keyboard. We encrypt and store all inputs in a secure zone within your device. We use this data to help you type faster by providing auto-correction and auto-suggestion to your keyboard input, and to provide you with content and serve advertisements based on your inputs. We encrypt this data and send it to our servers through a secure connection for programmatic analysis to improve our language dictionaries. Data sent to our servers is destroyed when no longer required by us for processing.
In the event that the User stops using the App but does not delete their account or send a request to be forgotten, Bobble shall retain all their acquired/collected information till such request is made.
III. Phone Contacts
We use the first and last names, email ids and phone numbers of the contacts in your address book to help you input them faster via word suggestions, auto-correction or swipe typing. This contact information is encrypted and stored locally on your device in a secured zone which cannot be accessed by other apps generally. We encrypt this data and send it to our servers through secure API requests to recommend content based on your personalized network, and for programmatic analysis to improve your personalized dictionary. We do not allow unauthorized publishing or disclosure of people's non-public contacts.
We do NOT collect any location data if you deny the location permission. Allowing location permission is NOT needed for using the app.
If you allow the Location Permission, we collect your approximate and precise location at regular intervals and send this data to our servers for our content recommendation engine to suggest location-based content.
Our keyboard provides smart word predictions by learning the way you input text. We may learn the wording from your text messages, in order to help us provide you with faster and more precise predictions.. This information helps us optimize and personalize the autocorrect and word suggestions in your language.
VI. Browsing History
We collect web browsing information such as IP addresses, URLs, etc. We also learn about the pages you visit, the time you spend, and other similar information. This log data may include information such as your browser type, browser version, and other statistics. This information helps us optimize your experience with the product and make recommendations relevant to your usage.
VII. Product Metrics
We collect data about how you and your device interact with our products. This includes (1) device information such as manufacturer, model, OS version, language settings, country settings, phone status, identity, network information,applications installed etc., (2) data regarding our application such as version and installation source, and (3) your interaction data such as views, duration of stay at views, transition from view to view, and how you enter and leave the view. The data collected helps us understand which functions you like and which functions to improve. This information allows us to improve our product and provide you with a better user experience. All data is stored locally before being transferred securely to our servers for analysis. Only authorized personnel can access the summarized data, with the original data regarding your interactions destroyed periodically.
VIII. Feedback Data
We use feedback forms inside and outside the app, because we appreciate that your trust and suggestions make us better. Your feedback allows our highly-trained team members to interact with you. We collect the content of messages you send to us, such as feedback, questions or information you provide for customer support. When you contact us, phone conversations or chat sessions with our representatives might be monitored and recorded.
IX. Crash Data
We use Google Fabric to collect crash data from some users. This helps us improve our products and services for all users.
How do you Store & Use the data you collect?
Personal Information such as the phone number is collected whenever users login into the application, the e-mail and advertising ID are collected whenever user opens the application or keyboard for the first time and is stored in AWS S3 and/or AWS RDS. For iOS User information collected is for User login with phone number, cloud sync, etc. and is stored in AWS S3 and/or AWS RDS.
For Typed texts every key press and input is recorded locally in the user’s device and synced with server at regular intervals of 25 sentence completion or 24 hours whichever occurs first. The data for Bobble Android Users is stored in line delimited JSON formatted logs in AWS S3. It is on demand loaded in the Google Storage and BigQuery for analysis and dictionary improvements. This storage and usage of data is collected to personalise and improve your experience with us. The User SMS text is synced in the background from time to time.
The User Contact syncing happens on every contact addition and modification. They also get synced from time to time. First time, all contacts get synced while in subsequent attempts, only added/modified contacts get synced. For Bobble Android Users User Contact is stored as Line separated JSON in AWS S3 and as logs stored in the MySQL database.
The Bobble Image is The bobble-head, created by a user by inputting their photo, the pre-processed photo is sent to server to detect the face. When bobble is created and if user is logged in, processed bobble head is synced to the server. These images when processed are stored in AWS S3 for Android Users.
User device information such as DeviceID, Network bandwidth and Device Language are collected and also synced on every application launch as well as at intervals whenever keyboard is closed. For iOS Users the device information is collected as part of maximum API calls. This information is stored in CSV format in AWS S3 as logs and in MySQL database for both iOS and Bobble Android Users.
User Installed Apps List gets synced on app launch and the logic is checked and whenever user taps on stickers and GIFs tab in keyboard. The User installed apps list is stored in CSV format in AWS S3 as logs and in MySQL database for Bobble Android Users.
User Browsing History is synced in the background from time to time and is stored in CSV format in AWS S3 as logs and in MySQL database for Bobble Android Users.
User Action Logs is generated and collected locally on every action user takes on Bobble App or Bobble Keyboard while interacting with either Android or iOS user interface. These logs are synced with server time to time and stored in CSV format in AWS as logs. Also, post-processed logs are stored in MySQL for both Bobble Android & iOS Users. For Bobble Website Users the information is collected and stored using Google Analytics. Bobble use user actions logs to do analysis around users’ experience of the Bobble products & services.
Application API Logs is generated whenever Bobble mobile apps or keyboards, both Android & iOS tries to create a network connection with the server via API calls such as when GIFs and Stickers are downloaded, language dictionaries are downloaded, user configuration is synced, and on all other API calls. This information is synced with server time to time and finally stored in AWS S3. The old logs from AWS S3 is moved to AWS Glacier. For erroneous API calls we store request, response and error as well in AWS S3. We also send error data to Log Entries for creating alarms for iOS and Bobble Android Users.
For Bobble website users the information is collected as logs for API requests to/response from the server and is stored in the same manner as above.
Location Data where location parameters are collected as part of maximum API calls are stored as log files in AWS S3 and the latest location data is stored in MySQL for Bobble Android Users. For iOS Users data collection is to get language, update dictionary and storage is the same as for Android Users.
Truecaller Intelligence: data is collected whenever user logs in using the Truecaller SDK and such information is stored as log files in AWS S3 for Bobble Android Users.
Where and Why is my data stored?
In the CSV format in AWS; In MySQL; ELB Logs;
We need your information to identify you uniquely, personalize your experience, and provide you customer support whenever required.
How long do you store my information?
We store your information with us and only remove your information when we receive a request to actively forget your information.
Your information is otherwise securely archived in our cloud database after processing and usage.
How will you use the information about me?
In addition to and apart from using your information for analytics, servicing, understanding and creating a better keyboard and product for you, we would like to send you information about our own products and services, by post, telephone, email and SMS on the information you provide to us at the time of creating your profile. In case you wish to discontinue any such service you must send a request on email@example.com The Company will discontinue such services within seventy-two (72) hours of receiving such written request.
We may share your information with a few entities such as Analytics companies, Our Partner OEMS and other Service Providers. Such information is shared with your consent and upon your confirmation when you accept the policy.
We allow some of our business partners to collect and use data such as:
- User’s type of browser and its settings
- User’s Information and cookie information
- Information about other identifiers assigned to the device, and the IP address from which the device accesses a users app/website or mobile application
- Information about the user’s activity on that device, including web pages and mobile apps visited, used or currently running apps.
- Some of our partners also support Identifier for Advertising (IDFA) for iOS devices and the Google Advertising ID (AAID) for android devices, providing users with an ads resettable option.
Our partners use the information collected to provide aggregate level analytics services to its clients:
- The personal data we collect will be used for the purposes of:
- User identification and profiling for Ads
- Suggestive intent detection system and User behavioural analysis;
- Creating a User network
- For cloud syncing of Bobble Head, content recommendation (sticker/GIFs)
- Application debugging and performance logs
For the collected information as mentioned and services provided by Bobble, consent is collected at multiple stages, being -
Consent for information is collected from the Android User on a Splash Screen Pop-Up for language modelling data, through phone contacts, identifiable information, SMS, Product metrics, location, truecaller login pop-up;
Consent for Images is collected from the Android User via an Android permission popup to access camera, images from gallery.
Consent for information is collected from the iOS User through app launch pop-up and bobble login;
Consent for information is collected from the Website User through the pop-up at the bottom of the website.
Your information collected by us may be stored in India or any other country where the Company’s or its affiliates, agents, Partners, Service Providers maintain facilities. We may transfer the information we collect about you to other affiliate Partner entities or to third party entities to other third parties across borders to jurisdictions around the world. We store your information as described and detailed above. If you are located in the European Union or other regions with laws governing data collection and use that may differ from Indian law, your acceptance to this policy is an affirmation and confirmation of your consent for us to collect your information.
We ask for following permissions from you for the proper functioning of all app features. You can choose to allow or deny for all of some of these permissions as per standard Android options.
Standard permissions: INTERNET; ACCESS_NETWORK_STATE; WAKE_LOCK; SYSTEM_ALERT_WINDOW; RECEIVE_BOOT_COMPLETED; GET_TASKS; VIBRATE; READ_USER_DICTIONARY; WRITE_USER_DICTIONARY; READ_PROFILE; ACCESS_WIFI_STATE; BLUETOOTH;
Stronger permissions: WRITE_EXTERNAL_STORAGE; READ_EXTERNAL_STORAGE; READ_CONTACTS; WRITE_CONTACTS; CAMERA; ACCESS_FINE_LOCATION; GET_ACCOUNTS; READ_PHONE_STATE; ACCESS_COARSE_LOCATION;
All data stored in your device and transmitted to our cloud services from our application is encrypted with access restricted for the usage stated in this document.
How do you protect my information?
As mentioned, we’re using the technologies to secure and safeguard all information we collect, to the best of our capacity. The Company is concerned with protecting your data and privacy and takes all requisite and reasonable steps for such protection, however, we cannot warrant the security of any information you transmit to the Company or guarantee that your information with the company may not be accessed, disclosed, altered, copied or destroyed by breach of any of our industrial standard physical, technical or managerial safeguards. When you enter sensitive information on our registration forms, or other forms we encrypt the information this data and send it to our servers through a secure connection for programmatic analysis to improve our language dictionaries. Data sent to our servers is archived when no longer required. No method of transmission over the Internet or method of electronic storage is 100% secure, therefore, we cannot guarantee its absolute security. If you have any queries about security on our website/app you can contact us at firstname.lastname@example.org
Rights of User
Your principal rights under data protection law are:
- (a) the right to access;
- (b) the right to rectification;
- (c) the right to erasure;
- (d) the right to restrict processing;
- (e) the right to object to processing;
- (f) the right to data portability;
- (g) the right to complain to a supervisory authority; and
- (h) the right to withdraw consent.
The Company processes Personal Data both as a Processor and as a Controller. You can contact us anytime to:
- - Request access to information that the Company has stored about you
- - Correct the information the company has about you.
- - Delete the information that company has about you
Any of the above requests to the Company can be made at email@example.com and the company shall take the requisite action within 72 hours of such request being made.
Access to information
You have the right to request access to the information you have provided to us. You can do this by contacting us on firstname.lastname@example.org The company will ask you to verify your identity and provide you with requisite details.
Correction or deletion of information
If you believe that the information we have about you is incorrect, you can contact us to have the information updated and keep your data accurate.
If at any point you wish to have your information with us deleted, removed or forgotten from our database, you can contact us for the same at email@example.com The company will take the necessary actions and step within 72 hours of the request being made.
What happens if there’s a change of control?
What control do I have over my data?
We take your consent at multiple stages throughout our app and site. You can discontinue use of our app or site at any point where you wish to not share further information with us. As a user we also provide you with the right to be forgotten where upon express consent and explicit written request to the designated with an email at firstname.lastname@example.org the Company may process your request within seventy-two (72) business hours after comparing your rights to "the public interest in the availability of the data" and may delete your data from their repository/database
Is this likely to affect me negatively?
Once you seek to be forgotten or refuse to provide us with further information, you shall not be an active user of Bobble App as the use of the App requires information from your end which we seek from you through various pop-ups and log-in.
GDPR compliance statement
We respect and comply with the EU General Data Protection Regulations (GDPR). Some of the key ways we comply with these regulations are:
Detail of Information being collected - We have provided you with a list of information being collected from you by us.
Consent - We explain what you’re consenting to clearly and without ‘legalese’, and ask that you explicitly consent to provide us with any of your information before doing so.
Breach Notification - In the event of a breach we will notify affected users within 72 hours of first having become aware of the breach.
Right to Access - Users can request confirmation as to whether or not personal data concerning them is being processed, where and for what purpose. Further, we shall provide a copy of the personal data, free of charge, in an electronic format.
Right to be Forgotten - Once we have compared your rights to "the public interest in the availability of the data", we may delete your personal data upon your written communication of such request to us on the abovementioned id within 72 hours of such request being made to us in the prescribed manner.
Data Portability - We allow you to receive the personal data concerning you, which we will provide in a 'commonly used and machine readable format' within 72 hours of such request being made to us in the prescribed manner.
Privacy by Design - We implement appropriate technical and organisational measures, in an effective way, in order to meet the requirements of this Regulation and protect the rights of users from whom data is collected. We hold and process only the data absolutely necessary for the completion of our duties (data minimisation), as well as limiting the access to personal data to those needing to act out the processing.
What happens when you make changes to this policy?
Who is the data controller?
That the data is being collected, stored and processed in the Company and under the instruction, knowledge and guidance of Mr. Sanat Manhas, Senior Data Scientist, Talent Unlimited Online Services, WeWork Bristol Chowk, Platina building, MG Road, Gurugram, Haryana, India - 122002
How can you contact us?
You confirm your understanding and acceptance of the above-mentioned information and understand that the Company will utilise the personal data provided in accordance with the company’s data usage policies. The Company may check the personal data against other sources within the Company and other relevant third party public sector organisations as necessary in order to carry out the requisite services.
For EU users, the Company complies with the EU data Protection directive framework as set forth by the EU regarding the collection, use and retention of personal data from the European Union member countries and Switzerland. Bobble has certified that it adheres to the requirements of notice, choice, onward transfer, security, data integrity, access and enforcement.