Updated: 27 March 2020
1. Processing manager
The data collected is processed byLomadsTechnologies Private Limited, a company incorporated under the Companies Act, 2013 (“LOMADS”). The company’s headquarters are located at BKC, Mumbai.
2. Information we collect
LOMADS collects and processes personal data on you when you use the LOMADS application or when you communicate with LOMADS. It may be information you share with us directly, or data we collect automatically.
- Mandatory data
- Identification data
- Email address/telephone number/Facebook/LinkedIn (mandatory for registration)
- Data relating to your activity on the application
- Technical data of the cell phone
- Data required for certain purposes
- Personal interests
- Professional career and education
- Data relating to taking part in activities and events, your experience and your satisfaction
- Geographical position
- Search preferences – people/activities/events
- Text messages sent and received through LOMADS chat
- Data relating to reports made and requests sent to the LOMADS customer service
2.1 Data you share directly
When you use our Services, you share information with us, some of which may be used to identify you. When you communicate this information, you accept that some of the data will be visible to the other Members of the Application, and therefore made public on the Application. In an effort to help you identify this information easily, it is signaled as ‘public’ below. LOMADS cannot be held liable for data published on its platform and disclosed by a Member. However, information not marked as Public will not be visible or accessible by other Members; such information is signaled as ‘private’ below.
2.1.1. Registration data
This is the basic data required for you to register and access our Services.
This data is collected by LOMADS using different methods depending on the type of registration you choose.
Data can be collected from Facebook or LinkedIn, to minimize the formalities (using the procedure you choose at registration). When you click on “Facebook”, you agree to let Facebook share this data with us.
In addition, you can register using a cell phone number/email and, if this is the case, your data will be sent to LOMADS directly by you.
This data relates to your identity.
- Your identification data:
- The following data is collected whether the Member uses Facebook/Instagram or registers using a cell phone number/email:
- your first name (public);
- your date of birth (private);
- your age (public); Only your age, as deduced from your date of birth, will be visible to other LOMADS members. You can also hide your age
- your gender (private);
- your profile photograph (public)
Depending on your type of registration, this information is mandatory for the supply of the Services. If you do not share it, LOMADS will not be able to supply the Services offered in the Application and you will not be able to create an Account.
You may add additional information to improve your Profile. This information is optional, shared at your own discretion, and is your sole responsibility. This data is as follows:
- professional career and education: profession or studies
- personal interests: personal preferences, leisure activities, musical preferences etc.
- email address or telephone number when this data is not mandatory for registration
- profile description: if you would like to, you can share additional information about you in the space provided for this purpose.
LOMADS does not encourage Members to share data that can be perceived as sensitive with other Members, or with LOMADS through the Application. Sensitive data refers to data that is legally qualified as “sensitive” by the General Data Protection Regulation (“GDPR”). More specifically, it includes information on race or ethnicity, political opinions, religious or philosophical beliefs or affiliation with a union, along with information on health, sexual life or sexual preferences (“Sensitive Data”). If a Member decides to share such information on his/her profile regardless, it is deemed to have been “clearly made public” by the Member who shared it, according to the GDPR.
2.1.2. Data relating to interactions with LOMADS:
When you contact our customer or support services, report an issue with our services, ask for help, exercise your personal data rights, or participate in surveys, when you share your experience of our services, give testimonies, or answer one of our questionnaires, LOMADS will collect, depending on the case, the following personal data:
- Data relating to reports and requests sent to the LOMADS customer service (private): Date and time of the report, nature and reason for the report, data relating to the reported user.
This data will be collected by LOMADS when you ask for help from our customer service, exercise your rights over your personal data, report a problem or another user. Such information is required to handle reports or answer your requests. Without this information, the report or your request cannot be handled. This type of information must also be processed when a report has been made against you.
In fact, LOMADS has a legal obligation to collect reports from its Members brought to its knowledge regarding contents or behavior likely to infringe our Terms of Service.
- Data relating to people/events/activities, your experience and satisfaction (private): participation, responses, satisfaction level, suggestions, experience.
Such data is collected by LOMADS when you connect with other members, reserve activities and events answer our surveys and satisfaction questionnaires, share your experiences. This data is useful if you wish to get relevant recommendations from LOMADS. However, data on your experiences and satisfaction is optional.
2.2 Data we collect automatically
When you use our services and features, we collect information on your activities on the Application:
- Activity data (private) (registration date, last connection, interactions with Members and third-party accounts, number of transactions, etc.)
When you access our Services and use the Application and its features, information on the way you use them is collected and processed. LOMADS is obliged to collect such information when you use the Services. Without this data LOMADS cannot supply the Services linked to the LOMADS application.
More specifically, this includes your registration date, last connection, the type and number of interactions with other Members, participation in events or activities.
- Common points with other Members (public)
One of the Application’s main value and purpose is to allow Members to find other Members they have interests in common with to facilitate real-life meet ups. Your consentwill be asked to authorize the collection and processing of your location data and your interest data to allow LOMADS to match with other Members.
The common points let LOMADS show you profiles of Members you have similar interests as you and who meet your search criteria.
You are free to withdraw your consent at any time and disable the geolocation option on your smartphone.
- Geographical position (private)
LOMADS can, if you expressly agree, access your position, approximately or more precisely depending on the technology you use. After you have given consent, you are free to withdraw your consent at any time and disable your smartphone’s geolocation option.
- Text messages sent and received (private)
Messages are sent and stored on LOMADS’s servers, to provide the Service to allow Members to have a conversation. Messages are strictly private and only implicate the Members involved. LOMADS’s authorized managers do not exercise any rights to view these conversations. These Messages are not transmitted or communicated to third parties except in cases of judicial requests, and/or in compliance with the applicable legislative or regulatory provisions. Moreover, Messages are strictly private and are not accessible to other Members who are not involved in the conversation, nor to any third party.
- Search preferences
The Application lets you set search preferences. You can change these settings in the Application and specify your needs, after agreeing to LOMADS collecting and processing your data, so you can be matched exclusively with results that meet your search criteria.
3. How do we use your data?
3.1. Supply of services and features according to our terms of service
- Creation and management of your Account as a Member:
- Creation of your profile.
- Registration, deregistration, deactivation of your Member profile.
- Management of parameters and preferences.
- Management of subscriptions.
- Management of access to the Services proposed by LOMADS.
- Help and technical support to Members.
- Managing and storing messages exchanged between Members
- Sending information messages relating to the Services or your interactions with other Members (notifications).
Legal basis: Execution of the contract
The data collected by LOMADS is required to make sure the Application is running smoothly and to supply the Services, which it is contractually obliged to provide to Members under the service contract biding the two parties (Terms of Service).
3.2. Geolocation to provide local recommendations
- Geolocation to suggest other Members, events and activities.
Legal basis: Consent
When you have given your consent, you are free to withdraw it any time by disabling the geolocation option on your smartphone. Withdrawal of consent does not affect any processing carried out before the withdrawal.
3.3. Suggesting relevant offers and contents (marketing and advertisements)
- Sending marketing or advertisement messages or contents.
- Distribute marketing contents and advertisements related to LOMADS offers and services on the application and by emails.
Legal basis: Legitimate interest
This processing is based on the legitimate interest of LOMADS to share its offers and to provide information on its service to third-party websites. You can object to receiving emails from LOMADS at any time by clicking on the “Click here to unsubscribe” link provided for this purpose in the emails you receive. You may also object to sharing data with third-party websites, social networks and third-party applications, by contacting us (see section 8. Contact).
- Disseminating on the LOMADS application advertisements, on the products and services of partners and the products and services of LOMADS. These advertisements are targeted based on your age, gender and location (non-specific, only by the city concerned).
Legal basis: Execution of the contract
This processing is required for the performance of the contract between LOMADS and the Member since the dissemination of these advertisements constitutes the counterpart of using the application.
3.4. Improving and optimizing our services and our knowledge of how you use them
- Improvement and optimization of the services of LOMADS, of the knowledge of its Members and the manner of using the Services:
- Statistical studies.
- Satisfaction survey.
- Analyses of the use of the Application and Services by Members.
Compatible subsequent use
This processing for statistical purposes is compatible with the following purposes; the provision of services and features; the provision of relevant offers and content; data security and combating illegal activities.
3.5. Guaranteeing the security of your personal data
- Detecting or preventing breaches of the security of the Services by identifying and analyzing fraudulent behavior.
Legal basis: Legitimate interest
This processing is based on LOMADS’s legitimate interest in guaranteeing the security of its application and the data it processes. You can object to this use at any time by contacting us. However, LOMADS may continue to implement the processing if it justifies legitimate and compelling reasons.
3.6. Preventing and combating illegal or unauthorized activities (breaches of the terms of service) and complying with legal requirements
- Analysing and processing reports of fraudulent/undesirable behavior.
- Managing undesirable behavior and warning, suspending, blocking or deleting the Member’s Account.
- Managing requests to exercise Members’ rights over their data.
Legal basis: Legal obligation
These processes are based on LOMADS’s legal obligation, as a data host, to remove illegal content as soon as it becomes aware of it and on its obligation to respond to requests to exercise Members’ rights over their personal data.
- Detecting or preventing fraudulent activities:
- Automated analysis of profile data, application activity and photos added by Members to detect fake profiles, fraudulent behavior or behavior that breaches the Terms of Service.
Legal basis: Legitimate interest
This processing is based on LOMADS’s legitimate interest in preventing and stopping fraudulent activities that may be carried out on its Services. You can object to this use at any time by contacting us. However, LOMADS may continue to implement the processing if it justifies legitimate and compelling reasons.
4. How data is shared
Only certain LOMADS employees from customer services and authorized managers process Members’ personal data for the purposes described above. These employees and authorized managers only have access to the data necessary to perform their duties.
- data hosting;
- the detection and prevention of fraud and swindling;
- studies, analyses and statistics;
- the use of the Application and/or the proper functioning of the Application;
- the provision of necessary assistance to Members;
- management of reports;
- marketing and advertising to address relevant offers, messages and content to LOMADS Members and LOMADS non-Members.
In addition, at the request of state bodies, in particular the judicial authorities, and in order to comply with any judicial or legal request, LOMADS may transmit the personal data of its Members.
Lastly, we may be required to share your data for the purposes of corporate operations, which include, but are not limited to, a restructuring, a change in control of the company, a merger, an acquisition, a transfer, or a termination of the company.
5. Exercising your rights over your Data
Every Member has a right to access, rectify, and a right to data portability and removal of his/her personal data, along with a right to object to or limit processing of his/her personal data, and the right to decide on the way to handle the personal data after his/her death. In an effort to address its Members’ concerns, LOMADS commits to respecting the protection of personal data and to process requests as soon as possible.
Exercising your rights
Members may exercise their rights, subject to proving their identity, by sending an email firstname.lastname@example.org, by exercising their rights directly via the Application, or by sending a letter to the following postal address: Lomads Technology Private Limited, 1st Floor, Kagalwala House, Plot No. 175, CST Road, Kalina, BKC, Santacruz East, Mumbai, Maharashtra 400098, India.
For any other claim, the Member may lodge a request with the national authority responsible for data protection.
6. How long will we keep your data?
LOMADS will store the Member’s data for as long as required in order for the Member to use his/her Account, namely:
- When the Member deletes his/her Account or requests its deletion from Customer Service, it will be deleted from the Application. However, the Member’s data will be kept in a separate archive for six months before being permanently destroyed, in order to enable LOMADS to comply with its obligation to keep it as host.
- The email address of the Member will be kept for commercial canvassing purposes for six months after a period of one year of inactivity of the Account. If the Member deletes his Account, the email address will not be used for commercial canvassing purposes.
- Requests for the exercising of rights: for the time that allows LOMADS to prove that it has responded to requests in case of disputes or inspections: one year from the month following your request.
LOMADS undertakes to make every effort and to invest all means at its disposal to guarantee that the stored data is kept as secure as possible. However, it is the Member’s responsibility to take appropriate measures to protect his/her data.
7. Personal data of minors
LOMADS shall not collect data from minors. Should a Member lie about his/her date of birth, and particularly if he/she fraudulently claims to be an adult, the parents of the minor in question should inform LOMADS of this fact by sending an e-mail to one of the contacts mentioned, requesting the data to be deleted. LOMADS commits to deleting all data on the minor in question as soon as possible.