PRIVACY POLICY - MoMeet
1. GENERAL PROVISIONS
1.1. This privacy policy of personal data applies to all information posted in MoMeet (including the Telegram bot and the MoMeet App, collectively referred to as "Company", "Service Provider", "We"), that visitors to MoMeet (the "Users", "You") may provide/receive while using it.
1.2. The Service Provider, in accordance with applicable legal requirements, ensures the confidentiality of data and the implementation of appropriate technical and organizational measures to protect data from unauthorized access, disclosure, accidental loss, alteration, destruction, or other illegal processing.
1.3. This Privacy Policy sets out our current data protection and privacy policy and obligations. Accordingly, we strive to collect and process only data strictly necessary in the context of our relationships with customers, partners, users/visitors of our Service and online resources, to provide services and/or information for specific and legitimate purposes.
1.4. We post our Privacy Policy in MoMeet in its latest version. Please read it carefully. By accessing and using MoMeet, you confirm that you have read, understood, and agreed to this Privacy Policy.
1.5. This Privacy Policy is an integral part of the User Agreement published in MoMeet and is required to be read in order to use the Service.
1.6. The Service Provider reserves the right, at its sole discretion, to change this Privacy Policy at any time by publishing an updated version of the Privacy Policy in MoMeet and, if the changes are significant, notifying Users about them. A modified or updated version of this Privacy Policy comes into force from the moment it is published in MoMeet. By continuing to use the Service, the User agrees to the updated Privacy Policy.
1.7. The Service is based on the algorithms of the Telegram application, so please also refer to the Telegram Terms of Use and Privacy Policy.
2. THE INFORMATION WE COLLECT ABOUT YOU
2.1. The main purpose for which the Service Provider collects your data is to provide you with services for using MoMeet (hereinafter referred to as the "Services"). In the process of providing our services to you, in order to be able to use and improve our services, we need to collect personal information about you.
2.2. The Service Provider will collect and process the following data about you:
2.2.1. Information that you provide us with.
You provide us with the following information about yourself during the registration process for using our Services: nickname, gender, age, orientation, the city in which you want to make acquaintances, the language in which the service will be operated. The information may also include a link to a personal profile, a personal account ID in the Telegram messenger, and the language of the Telegram messenger. In addition, this is information that you provide by continuing to use our Services, participating in a promotion or survey, as well as reporting problems with our Services.
2.2.2. Information we collect about you.
The Service Provider may automatically collect the following information:
- Technical information, including your registration data, operating system, device data, geographical location, and IP address.
- Details of the transactions you make when using our services.
2.2.3. Information that we receive from other sources.
The Service Provider may receive information about you if you use any of the websites we manage or other services we provide.
2.3. You agree that we have the right, but are not obliged to store all collected personal information for the entire period of your use of our Services and for a period prescribed by law, but not more than 5 (five) years. The storage period may be extended for a period not exceeding 1 (one) year, if there is a reasoned request from the competent authority.
2.4. The Service Provider does not intentionally process the data of minors. MoMeet is intended for users who are at least 18 years of age. We strongly recommend that individuals under the age of 18 obtain permission from their legal representatives before providing any personal information. If the Service Provider becomes aware that information about a minor has been received without the consent of legal representatives, such information will be deleted as soon as possible.
3. HOW WE PROTECT YOUR INFORMATION
3.1. The Service Provider keeps your personal information secure using secure storage with encryption according to industry standards, and we have implemented a number of security measures to ensure that your information is not lost, misused, or altered, including, but not limited to the following:
3.1.1. Physical measures.
The physical media containing your data will be stored indoors, and special physical means of protection of information (surrounding exterior fences, video surveillance system, access control system using badges and biometric recognition system, including infrared protection of site boundaries), are used.
3.1.2. Electronic measures.
The data will be stored in computer systems and on physical data carriers, which are enforced by strict entry restrictions.
3.1.3. Management measures.
Access levels are separated so that only authorized employees are allowed to come into contact with your data, and such employees have committed to comply with our internal data privacy rules.
3.1.4. Technical measures.
Encryption technology can be used to transfer and store your data. We use various security technologies and controls currently available to minimize the risk that your data may be disclosed, corrupted, misused, obtained without permission, disclosed without permission, or altered. Our technical security teams actively monitor abnormal and malicious activity on our servers and services.
3.1.5. Other measures.
We strive to protect your information from unauthorized access, modification, disclosure, or destruction of the data we collect and store. We take various measures to ensure information security, including:
- Encrypting our messages with you;
- Periodic analysis of our data collection, storage, and processing methods;
- Limited access to your data based on the necessary knowledge for our employees and suppliers, who are subject to strict contractual confidentiality obligations.
3.2. Please note that it is impossible to guarantee 100% security of information. Therefore, we ask you to take measures to protect your personal information.
3.3. You agree that the Service Provider is not responsible for any information leakage and other losses not caused by our intent or gross negligence, including, but not limited to hacker attacks, power outages or unavoidable technical failure, to the maximum extent permitted by law, leakage of user data through his own fault.
3.4. If you suspect that your personal information has been compromised, please contact us immediately.
3.5. Content Moderation and Harassment Prevention
3.5.1. The Service Provider reserves the right to review user-generated content (UGC) to ensure that it does not contain harassment, threats, defamation, inappropriate, or illegal content.
3.5.2. If user behavior is found to violate platform terms (e.g., harassing other users or sharing malicious links), the Service Provider may take actions such as issuing warnings, imposing restrictions, or terminating services.
3.6. Malware and Data Protection
3.6.1. The Service Provider implements automated and manual review mechanisms to detect potentially malicious software or links intended to steal credentials shared by users.
3.6.2. The Service Provider strongly advises users to avoid clicking on links from unknown sources and to ensure the security of their devices.
4. WAYS OF USING YOUR DATA
4.1. We use the information we collect about you for the following purposes or in the following ways:
4.1.1. To provide our services.
The Service Provider uses the collected information to fulfill its obligations concerning you, to provide you with information, products, and services, to maintain and provide better services, to verify your identity.
4.1.2. To comply with the requirements of the law.
The Service Provider will use the information in accordance with our legal obligations, government requests and reasonable user requests.
4.1.3. For research and development.
The Service Provider actively measures and analyzes data for the administration of our Services and for internal operations, including troubleshooting, data analysis, testing, research, statistical, and review purposes, as well as to understand how you use and interact with our Services. This review is being conducted by our operations teams to continuously improve our services and fix user interface issues. In addition, the Service Provider uses such information to customize, measure, and improve our Services, the content and layout of our websites, as well as to develop new services.
4.1.4. To communicate with you.
Without collecting and processing your data to confirm each message, the Service Provider will not be able to respond to the requests you send. All communications are properly stored by the Service Provider or other service provider designated by the Service Provider to verify accuracy, stored as evidence or used to fulfill other legal or contractual obligations.
4.1.5. To ensure compliance with our terms and conditions.
The information collected is also used to continuously and actively comply with our terms and conditions, including, but not limited to, reviewing, investigating and preventing any potentially prohibited or illegal activities that may violate the above provisions, or disclosing relevant information to a third party in accordance with them. The Service Provider reserves the right to suspend or terminate the provision of any services to any user found to be in violation of our terms and conditions.
4.1.6. For marketing and advertising.
The Service Provider may share your personal information with our marketing partners for the purposes of targeting, modeling and/or analytics, as well as marketing and advertising.
4.1.7. For other purposes.
The Service Provider may disclose your personal information for any other purposes for which you give additional consent, expressed by signing a written document or filling out an electronic form provided by the Service Provider.
5. LEGAL BASIS FOR PROCESSING
5.1. When we process your data, we will rely on one of the following legal bases for processing. We may process your data for several legitimate reasons, depending on the specific purpose for which we use your data.
5.1.1. Execution of the contract.
We may process data if the processing of your data is necessary to fulfill our obligations under the User Agreement that we have entered into with you. We may process data if the processing of your data is necessary to fulfill our obligations under another agreement that we have entered into with you.
5.1.2. Legal obligation or in the public interest.
We are required to process your data in accordance with legal obligations. The purposes of processing include control over identity verification, prevention of money laundering and fraud, risk control measures, as well as providing information to a competent authority, government agency, or law enforcement agency.
5.1.3. Legitimate interests.
If necessary, we may process data if we or the third party have a legitimate interest in pursuing commercial and business interests, except in cases where such interests, fundamental rights, and freedoms are.
5.1.4. Your consent.
In certain circumstances, we may request specific permission from you to process additional personal information for certain purposes. Your data will be processed in this way if you agree to it. If the legal basis is the consent you have provided, you can withdraw your consent at any time. Revocation of your consent will not affect the legality of the data processed prior to revocation.
6. WHO RECEIVES YOUR DATA
6.1. The Service Provider receives your data to fulfill requests and provide services, as well as to fulfill our contractual and legal obligations.
6.2. We transfer your data to third parties if it is necessary for our legitimate business needs, to fulfill requests, provide services and/or in accordance with the requirements or permits of the law. Third parties in such circumstances:
6.2.1. Service Providers.
The Service Provider will disclose the data to third-party partners and service providers (processors) so that they process it on our behalf. Where necessary, these service providers are required to provide sufficient guarantees in accordance with the Data Protection Act (for example, being bound by contractual obligations regarding confidentiality and data protection). We will only transmit the data they need to provide their services. This way, once transferred and disclosed, your data can be used by:
- Banks (other credit and financial institutions) and similar institutions.
- Payment systems (SWIFT, SEPA, Visa, Mastercard, etc.), payment service providers, card processing companies.
- Providers of data management, storage, archiving, cloud storage services.
- Companies that help us in providing our services (for example, companies that provide technology services for technical support, IT application development, website management, telephony/SMS services).
- Customer support service providers and marketing service providers.
6.2.2. Auditors and consultants.
We may disclose data for the purposes and in the context of inspections (for example, external inspections, security checks) to legal and other consultants to investigate security issues, risks, complaints, etc. This way, once transferred and disclosed, your data can be used by:
- Administrative service providers.
- Audit and accounting services and consultants.
- External legal consultants.
6.2.3. Regulatory authorities, law enforcement agencies, courts.
The Service Provider may disclose data in accordance with applicable laws and regulatory obligations, to respond to requests from regulatory authorities, government and law enforcement agencies, courts and court orders.
6.2.4. Other persons.
Other recipients may be any natural/legal persons to whom you ask to transfer your data (for example, a link, etc.) or give your consent to the transfer of data.
6.3. The Service Provider may also disclose your data in such circumstances as:
- In order to protect our rights, safety or property, as well as the rights of our customers or third parties/the public. This includes sharing information with other companies and organizations for the purposes of money laundering, fraud prevention and similar risks.
- If we are required to disclose or transfer your data in accordance with any legal or regulatory obligations or requests.
- To enforce or enforce the terms and conditions or any other agreement in force in the context of our relationship, as well as to investigate potential violations.
- In order to protect our rights, safety or property, as well as the rights of our customers or third parties/the public. This includes sharing information with other companies and organizations for the purposes of money laundering, fraud prevention and similar risks.
7. USER RIGHTS
7.1. In accordance with applicable law, you have the right to access the information we store about you. Your right of access may be exercised in accordance with the relevant data protection legislation. If you have any questions regarding our use of your personal information, please contact us. Under certain conditions, you may require us to:
- Provide you with more detailed information about our use of your data;
- Provide you with a copy of the information you have given us;
- Update any inaccurate, incorrect or outdated personal information that we store;
- Delete any personal information that is no longer necessary or no longer subject to the legal obligations of the Service Provider;
- If the processing is based on consent, revoke your consent so that we stop this particular processing;
- Stop direct marketing with you by contacting us;
- In cases where we carry out fully automated decision-making, which leads to legal obligations or a similar significant impact, you can request information from us about the decision-making methodology and ask us to check whether the automated decision was made correctly. We may reject the request, as permitted by applicable law, including in cases where the provision of information will lead to the disclosure of trade secrets or hinder the prevention or detection of fraud or other crimes. However, in these circumstances, we will verify that the algorithm and the source data are functioning as expected, without errors or distortions or, if required by law, correct processing;
- Restrict the use of your information during the investigation of the complaint.
7.2. When you exercise these rights, certain exceptions are provided for the protection of public interests (for example, the prevention or detection of crimes) and our interests (for example, the preservation of legal privileges).
7.3. Account Deletion
7.3.1. You have the right to request the deletion of your account at any time. To delete your account, you can navigate to “My - Settings - Account - Delete Account” in the MoMeet App.
7.3.2. Upon account deletion, all your personal data will be permanently deleted and cannot be recovered. This includes, but is not limited to, your profile information, messages, and any other data associated with your account.
7.3.3. Please note that deleting your account is irreversible. We recommend that you back up any important information before proceeding with the deletion.
7.3.4. If you have any questions or need assistance with account deletion, please contact our support team through the MoMeet App.
8. RIGHT TO COMPLAIN
8.1. If you have any complaints about the use of your data, please let us know and/or file a complaint using the contact details specified in section 11 of this Privacy Policy. We will immediately investigate and inform you of the result.
8.2. If you have a complaint, please indicate the reason for your complaint, how you would like us to resolve the complaint, and any other information that you consider appropriate. We will investigate your complaint based on the information you provide and any information provided by MoMeet.
8.3. Your complaint will be considered within 14 (fourteen) calendar days from the date of receipt of the complaint by the support service.
8.4. The Agent may make the following decisions based on your complaint:
8.4.1. Resolve your complaint in accordance with your request.
8.4.2. Make a decision to reject your complaint and indicate the reasons for the rejection.
8.4.3. Offer to resolve your complaint in an alternative way.
8.5. You agree to use the complaint procedure described in this section before filing a claim in court. Failure to comply with this provision may be used as evidence of your unwillingness to settle the issue out of court and/or the unacceptable nature of the complaint.
9. LINKS TO THIRD PARTY SITES
9.1. Our services may, from time to time, contain links to the websites of our partners, advertisers, and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and we are not responsible for them. Please review their policies before submitting any personal information to these websites.
10. CHANGES TO OUR PRIVACY POLICY
10.1. In order to keep up with changing legislation, best practices, and changes in the processing of personal data, we may update this Privacy Policy from time to time, as appropriate to the circumstances. If we make material changes to this Privacy Policy, we will provide you with an updated version of the Privacy Policy on the interface of the Service. If required by applicable law, we will obtain your explicit consent to material changes.
11. CONTACT DETAILS
11.1. Please send any questions, comments or requests regarding this Privacy Policy to the support service in MoMeet.
11.2. If you believe that we have not answered all your questions, or you believe that your data protection or privacy rights have been violated, you can submit a complaint to any supervisory authority or other government body responsible for compliance with data protection laws.
