OUR COMMITMENT TO OUR USERS
In Lucky Jojo, your privacy is a top priority. Your privacy is at the heart of how we design and create the services and products you know and prefer so you can fully trust them and focus on creating effective contacts.
We appreciate your trust when you provide us with your information and we take it very seriously.
We are not compromising on issues of your privacy. We design all our products and services in accordance with your privacy. We engage with experts in various fields, such as the legal, security, engineering, product design and others, to ensure that no decision is taken without respect for your privacy.
We work hard to keep your information safe. We have teams that are dedicated exclusively to the security and protection of your data. We constantly update our security practices and invest in our security efforts to improve the security of your information.
We appreciate your trust in your information and we always intend to maintain this trust. This starts by ensuring that you understand the information we collect, why we collect it, how you use it and how you choose your information. This Policy describes our privacy practices in plain language, keeping the legal and technical phraseology to a minimum.
1. Who we are
European Trades Ltd
3. Information we collect
It goes without saying that we can not help you develop meaningful contacts without some information about you, such as basic profile details and the types of people you would like to meet. We also collect information generated when using our services, for example access logs, as well as information from third parties, such as when you access our services through social media accounts. If you want more information, we’ll go into more detail below.
Information you give us
- You choose to give us some information when you use our services. These include
- When you create an account, you provide at least your login information, as well as some basic information required for the service, such as your gender and date of birth.
- When you finish your profile, you can share with us additional information, such as details about your personality, lifestyle, interests, and other details about you, as well as content such as photos and videos. To add content, such as photos or videos, you can allow us to access your camera or photo album. Some of the information you choose to provide us may be considered as “special” or “sensitive” in certain jurisdictions, such as your racial or ethnic origin, sexual orientation, and religious beliefs. By choosing to provide this information, you agree to process this information.
- When you sign up for a paid service or you make a purchase directly from us (and not through a platform such as iOS or Android), you provide us or our payment service provider with various information such as your debit or credit card number or other financial data.
- When you participate in surveys or focus groups, provide us with your views on our products and services, answers to our questions and testimonials.
- When you choose to participate in our promotions, events or contests, we collect the information you use to sign up or log in.
- If you contact our Help Desk, we collect the information you provide during the interaction. Sometimes, we monitor or record these interactions for educational purposes and to ensure a high quality of service.
- If you ask us to contact or otherwise process someone else’s information (for example, if you ask us to send an email on your behalf to one of your friends), we collect information about other people you gave us to complete your request.
- Of course, we also process your conversations with other users, as well as the content you post, as part of the service operation.
Information we receive from others
In addition to the information you provide us directly, we receive information about you from others, such as:
- Other Users Other users may provide information about you as they use our services. For example, we may collect information about you from other users if they contact us about you. Also, if someone asks us to access their contacts and happens to be one of those contacts, we may contact you on behalf of the user.
- Social Media Media You may be able to use your social media login (such as your Facebook login) to create and sign in to your Lucky Jojo account. This relieves you of the need to remember one more username and password and lets you share some information with us from your social media account.
- Other Affiliates We may, for example, receive information about you from our affiliates when your Lucky Jojo accounts can be created through a partner’s websites (in which case they are forwarded with the registration information to us) or when Lucky Jojo ads are published on sites and platforms of a partner (in which case they can be shared with details about the success of a campaign).
Information collected when you use our services
When you use our services, we collect information about the features you have used, how you used them and the devices you use to access our services. See below for more details:
- Usage information We collect information about your activity in our services, for example how you use them (e.g., the date and time you logged in, the features you use, searches, clicks, and pages presented to you, address the referrer site, clicked ads), and how you interact with other users (e.g., users with whom you connect and interact, the time and date of your exchanges, the number of messages you send, and you take it).
- Device information We collect information from and for the devices you use to access our services, such as:
- information about hardware and software, such as the IP address, device ID and type, device and application settings and features, application errors, ad IDs (e.g. Google’s AAID, and Apple IDFA, both of which are randomly generated numbers that you can restore by going to your device’s settings), browser type, version and language, operating system, time zones, related tags century with cookies or other technologies that may uniquely identify your device or browser (eg IMEI / UDID and MAC address);
- information about your connection to a wireless network or mobile network such as a service provider and signal strength;
information on device sensors, such as accelerometers, gyroscopes and compasses.
- Other information, with your consentIf you give us permission, we can collect your exact location (latitude and longitude) by various means, depending on the service and device you are using, including GPS, Bluetooth or Wi-Fi connections . Your geographic location may appear in the background even when you are not using the services if the permission you have given us explicitly allows this collection. If you deny our permission to collect your location, we will not collect it. Similarly, if you provide your consent, we can collect your photos and videos (for example, if you want to post a photo, video or stream streaming services). We can also collect your contacts (for example, if you want to address your friends on your behalf).
4. Cookies and other data collection technologies
Some browsers (such as Safari, Internet Explorer, Firefox, and Chrome) have a ‘Do not Track’ (‘DNT’) feature telling a site that a user does not want to monitor their online activity. If a site that responds to a DNT signal receives a DNT signal, the browser may prevent this site from receiving certain information about the browser user. Not all browsers offer DNT option and DNT signals are not yet uniform. For this reason, many businesses, like Lucky Jojo, are currently not responding to DNT signals.
5. How we use the information
The main reason we use your information is to offer and improve our services. In addition, we use your information to keep you safe and to provide you with ads that may be of interest to you. Read below for more detailed explanations of the various reasons we use your information, along with practical examples.
To manage your account and provide our services to you
- Creating and managing your account
- Providing customer support and responding to your requests
- The completion of your transactions
- Communicate with you about our services, including order and billing management
To help you connect with other users
- Analyze your profile and other users’ profiles to suggest important contacts
- The appearance of user profiles among them
To ensure a consistent experience across all of your devices
- To connect the different devices you use so you can enjoy a consistent experience across all of our services. We do this by connecting devices and browser data, such as when you sign in to your account with different devices or use partial or full IP address, browser version, and similar data about your devices to identify and connect them.
To offer you relevant offers and advertisements
- For organizing draws, competitions, discounts or other promotions
- To develop, display and track content and ads tailored to your interests on the services and other websites
- To communicate with you via email, phone, social media or mobile devices about products or services that we believe may be of interest to you
- To improve our services and develop new services
To manage focus groups and surveys
- To conduct research and analysis of user behavior to improve our services and content (for example, we may decide to change the look and feel or even fundamentally modify a particular feature based on user behavior)
- To develop new features and services (for example, we may decide to create a new function based on interests in addition to requests we receive from users).
- To prevent, detect and combat fraud or other illegal or unauthorized activities
To address persistent or alleged inappropriate behavior inside and outside the platform
- To perform data analyzes to better understand and design countermeasures against these activities
- To keep data on fraudulent activities to prevent duplication of these
To ensure compliance with the laws
- To comply with legal requirements
- To help law enforcement
- To enforce or exercise our rights, for example our Terms
To process your information as described above, we rely on the following legal bases:
We provide our service to you: Most of the time, the reason we process your information is to execute the contract you have with us. For example, as you use our service to create essential contacts, we use your information to maintain your account and profile, make it visible to other users, and suggest other users.
Shady interests: We can use your information where we have legitimate interests to do so. For example, we analyze user behavior in our services to continually improve our offers, suggest offers that we believe may be of interest to you, and process information about administrative management, fraud detection, and other legal purposes.
6. How we share information
Since our goal is to help you make essential contacts, the main case of sharing user information is of course with other users. We also share some user information with service providers and partners to help us run our services with other European Trades Ltd companies and, in some cases, with legal authorities. Read below for more details on how your information is shared with others.
- With other users You share information with other users when you voluntarily disclose information about the service (including your public profile). Please be careful with your information and make sure that the content you share is what you like to be publicly visible, since neither you nor we can control what others do with your information after you share them. If you choose to restrict the audience for all or part of your profile or for specific content or information about you, then it will be visible under your Settings.
- With our service providers and partners We use third parties to help us operate and improve our services. These third parties help us with various tasks such as hosting and data maintenance, analysis, customer service, marketing, advertising, payment processing and security work. We can also share information with partners who distribute and help us advertise our services. For example, we may share limited information about you in fragmented, non-human-readable forms in advertisers. We follow a rigorous checking process before any service provider engages or collaborates with any partner. All service providers and partners must comply with strict confidentiality obligations.
- for other companies of European Trades Ltd., to help us process your information as service providers, as per our instructions and on our behalf. The assistance provided by members of European Trades Ltd. may include technical processing tasks such as hosting and data maintenance, customer service, marketing and targeted advertising, financial and accounting assistance, better understanding of how our service is used, and user behavior for improving our service, protecting our data and systems and combating spam, abuse, fraud, violations and other offenses.
- To improve your chances of creating important contacts with others, we can give you opportunities to be visible to other European Trades Ltd. services or take advantage of platform-to-site functionality. Of course we will comply with applicable laws and where relevant, we will inform you of any such opportunity and will allow you to agree or refuse. Examples of such opportunities may include the creation of a new service by European Trades Ltd., which will target a particular demographic group that we believe will be of interest to you based on your search criteria.
We may also exchange information with other companies of European Trades Ltd for legitimate business purposes, such as corporate audits, analyzes and consolidated reports, as well as compliance with applicable laws. We may also share user information with other companies of European Trades Ltd to remove users who violate our service terms or have been reported for criminal activity and / or misconduct. In some cases, we may remove that user from all platforms.
- For Corporate Transactions We may forward your information if we are involved, in whole or in part, in a merger, sale, redemption, divestment, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control.
- When required by law We may disclose your information if it is reasonably necessary: (i) to comply with a legal process such as a court order, a summons or a search warrant, a search of government / law enforcement or other legal requirements , (ii) to assist in the prevention or detection of criminal offenses (without prejudice to applicable law), or (iii) to protect the security of any person.
- For the imposition of legitimate rights We may also share information: (i) if the disclosure would reduce our legal liability to an actual or threatened lawsuit; (ii) if necessary to protect the legitimate rights and legitimate rights of users, (iii) to enforce our agreements with you, and (iv) to investigate, prevent or take other actions in connection with an illegal activity, suspicion of fraud or other tort / delict.
7. Cross-border data transfers
The exchange of information referred to in Section 6 sometimes involves cross-border data transfers, for example in the United States of America and other jurisdictions. For example, when the service allows users to be in the European Economic Area (EEA), their personal information is transferred to countries outside the EEA. We use standard contractual terms approved by the European Commission or other appropriate safeguards to allow transfers of data from the EEA to other countries. Standard contractual clauses are commitments between companies that transfer personal data and which are binding on them to protect your privacy and data security.
8. Your rights
We want you to have control over your information, so we provide the following tools:
- Access / update tools in the service.A tools and account settings that help you access, correct or delete the information you provided to us and that relates to your account directly within the service. If you have any questions about these tools and settings, please contact the Help Desk.
- Device access rights. Mobile platforms have access rights systems for specific types of device and notification data such as directory and location services and advanced notifications. You can change the settings on your device either to provide consent or to oppose the collection of the corresponding information or to display the corresponding notifications. Of course, if you do this, some services may lose their full functionality.
- Delete. You can delete your account using the corresponding function directly in the service.
We want you to know your privacy rights. Here are some basic points to keep in mind:
- Review your information. The applicable privacy laws may give you the right to review the personal information we hold for you (depending on jurisdiction, this may be called access rights, portability rights or variations of these terms). You can request a copy of your personal information by submitting a request here.
- Update your information. If you believe that the information wehold about you is inaccurate or that we no longer have the right to use it and you wish to request correction, deletion or oppose processing, please contact us here.
For your own protection and the protection of all our users, we may ask you to provide proof of identity before we can respond to the above requests.
Please note that we may reject requests for a number of reasons, such as if the request is unlawful or if it violates any other user’s trade secrets or intellectual property or privacy rights. If you want to receive information about another user, such as a copy of any messages you received from him / her through our service, the other user should contact the Privacy Officer to provide his / her written consent before releasing the information .
We may also not be able to accept certain requests for objection to the processing of personal information, especially when such requests will not allow us to provide our service to you anymore. For example, we can not provide our service if you do not have your date of birth.
- Uninstall You can stop collecting all information from a program if you install it without installing using the standard installation procedure for your machine. If you drop the app from your mobile phone, the unique ID associated with your phone will still be stored. If you reinstall the app on the same mobile device, we will be able to recreate this ID with your previous transactions and activities.
- Accountability In some countries, including the European Union, you have the right to file a complaint with the relevant data protection authority if you have concerns about how your personal information is processed. The data protection authority to which you can file a complaint may be that of your usual residence where you work or where we are established.
9. Residents of California
If you are a California resident, you can request a notification that discloses the categories of personal information that apply to you and which we have shared with third parties for direct marketing purposes during the previous calendar year. To request this notification, submit your request here. Please wait up to 30 days for one answer. For your own protection and the protection of all our users, we may ask you to provide proof of identity before we can respond to such a request.
10. How do we protect your information
We work hard to protect you from unauthorized access or alteration, disclosure or destruction of your personal information. As with all technology companies, while we take steps to protect your information, we do not promise and should not expect your personal information to remain safe.
We regularly monitor our systems for potential vulnerabilities and attacks, and regularly review our collection, storage and processing practices to keep up with physical, technical and organizational security measures.
We may suspend the use of all or part of the services without notice if we suspect or detect any security breach. If you believe your account or information is no longer safe, please let us know here immediately.
To ensure that your systems and information are protected against unauthorized access, theft and loss, we have implemented a reward program to find defects. For more information on the reward program for finding defects, you can contact us.
11. How long do we keep your information?W
e retain your personal information only for as long as we need it for legitimate business purposes (as described in Section 5) and as permitted by applicable laws. To protect security and protect our users in our services, we apply a three-month security retention period after deleting the account. At this time, the account information will be retained, although the account will not be visible anymore on the services.
In practice, we delete or anonymize your information after you delete your account (after the security retention period) or after two years of continuous inactivity unless:
- we are obliged to keep them in compliance with applicable laws (for example, some “traffic data” are kept for one year in compliance with legal data retention requirements)
- there is a pending issue, claim or dispute that requires the information to be retained until it is resolved or
- information must be kept for our legitimate business interests, such as fraud prevention and improved user security and protection. For example, information may need to be retained to prevent a new account being opened by a user who has been prevented from opening a new account due to unsafe behavior or security incidents.
Please note that although our systems are designed to perform data deletion procedures in accordance with the above instructions, we can not promise that all data will be deleted within a specific timeframe due to technical limitations.
12. Private child privacy
Our services are restricted to users aged 18 and over. We do not allow users under the age of 18 on our platform and do not knowingly collect personal information from anyone under the age of 18. If you suspect a user is under 18, use the reporting mechanism available through the service.
Because we are always looking for new and innovative ways to help you create essential contacts, this policy can change over time. We’ll let you know before any major changes take effect so you have time to check for changes.
14. How can you contact us?