Updated 08.10.2021.

Indie Privacy Policy

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Welcome to the Indie Privacy Policy (“Policy”). This explains how we collect, store, protect, and share your information, and with whom we share it. We suggest you read this in conjunction with our Terms and Conditions of Use. While you’re using the Indie mobile application, we collect some information about you. In addition, you may choose to use the App or Sites to share information with other users, including your friends and contacts (“Users”). We may also need to share your information sometimes. The App and Sites are global, and your information will be sent internationally. This Policy explains how we use your personal data.

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1. Who we are

a. The App and Sites are operated by Scagos & Company LLC (also referred to in this policy as “we” or “us”) which includes Indie, both of which are controllers of personal information collected and processed through the Indie App and Sites. Full legal address below:

b. Full legal address of Scagos & Company LLC: Georgia, Tbilisi, Isani-Samgori district, Rustavi high. Bl. 19, storeroom, floor

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2. Collection of information

a. When you download the App and create an account (“Account”), we may collect certain information (“Registration Information”) about you, such as:

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Registration Information

1.1. When you download the App and create an account (“Account”), we may collect certain information (“Registration Information”) about you, such as:

Name;
Username;
Mobile number;

Email address;
Gender identity;
Date of birth;
Nationality;
Work preferences;
Photographs;
Location; and
Login information for social media accounts that you connect to your Indie Account (this could include, for example, your Facebook and Instagram accounts as well as IMDB accounts).

1.2. Once you register, you will be able to review and change this information at any time just by logging in to Indie (other than your date of birth and location (which, if you have given Indie access to your location in your device settings, is automatically updated based on the location of your device). It is your responsibility to ensure that your account details are kept up to date. If your phone number changes, please ensure that you update this in your account. The information we collect helps to enhance the App and verify our Users. Registration Information may be visible to other Users who view your profile page.

1.3. For Users who are California residents, the data we may collect falls within the following categories of “personal information”, as defined by the California Consumer Privacy Act (CCPA):

Identifiers, such as name and location;
Personal information, as defined in the California customer records law, such as contact (including email and telephone number) and financial information;
Characteristics of protected classifications under California or federal law (if you choose to provide them), such as age, gender identity, race, ancestry, national origin, and medical conditions;
Commercial information, such as transaction information and purchase history;
Biometric information (not relevant here);
Internet or network activity information, such as browsing history and interactions with our Sites and App;
Geolocation data, such as mobile device location;
Audio, electronic, visual and similar information, such as photos and videos;
Professional or employment-related information, such as work history and prior employer;
Non-public education information; and
Inferences drawn from any of the personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.

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Profile Information

2.1. We recommend and encourage you (and all our members) to think carefully about the information you disclose about yourself. We also do not recommend that you put email addresses, URLs, instant messaging details, phone numbers, full names or addresses, credit card details, national identity numbers, drivers’ licence details and other sensitive information which is open to abuse and misuse on your profile.

2.2. When you post information about yourself or use the messaging function to communicate with other Users, the amount of personal information you share is at your own risk.

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‍Profile Verification Information

3.1. For safety and security and to ensure you have the best possible user experience, we require Users to verify their accounts and might ask for your phone number and, in some instances, we might also ask that you carry out photo verification. And we also want to avoid fake Indie accounts being created which can be used for malicious activities and cybercrime – they threaten the Indie network and spoil things for everyone. This verification might be required by us for the prevention of fraud. You can also verify your photo on a voluntary basis (to add the blue ‘verified’ badge to your profile).

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Purchases Information

4.1. If you decide to purchase any of our premium services, we will process your payment information and retain this securely for the prevention of fraud and for audit/tax purposes. Indie uses automated decisions to prevent fraudulent payment transactions being processed as part of its anti-fraud procedures. In order to do this, our systems check payment transactions for behaviour that indicates breaches of our Terms and Conditions of Use. If a transaction meets certain criteria that demonstrate that the Terms and Conditions of Use are likely to have been breached and the transaction is likely to be fraudulent, the relevant transaction may automatically be blocked. Where a transaction is blocked, the user will be notified that their transaction cannot be processed and affected Users can contact Indie to contest the decision. Please note that if your account is blocked for any reason, any account(s) that you have on other Indie platforms/applications may also be blocked as part of our anti-spam and anti-fraud procedures.

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Geolocation information

5.1. If you have given Indie access to your location in your device settings, when you use your mobile, we will collect information about WiFi access points as well as other location information about your longitude and latitude and may save your device’s coordinates to offer certain features to you. This information helps us identify your physical location and we use it to personalise the App and make it easier for you to interact with other Users, by enabling the general locality information to be displayed to Users seeing your profile and showing you the profiles of other Users who are near you. If you have given Indie access to your location, but wish to turn this off, you can do so by the following methods: iPhone app — settings, privacy, location services, Indie. Android — settings, location, Indie , permissions, location

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Device information

6.1. We may collect information about your device when you use the App including the unique device identifier, device model, default language, operating system, and MAC address, for a number of purposes, as set out in this policy. In addition, if you permit us to do so, the App may access your device’s address book solely in order to add someone to your contacts.

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Links

7.1. We may keep track of how you interact with links available on Indie including third party services by redirecting clicks or through other means. We may share aggregate click statistics such as how many times a particular link was clicked on.

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Indie Success Stories, Surveys and other Contributions

8.1. From time to time, we run surveys for research purposes and we may contact you to find out if you would like to take part. We may also contact you to find out if you would like to provide feedback, a testimonial or take part in marketing campaigns (for example, if you let us know that you have found a match on the App, we may contact you to ask if you would be happy to feature in advertising for Indie). Such surveys and marketing campaigns are optional and more information will be provided at the point of contact. If you do not wish to be contacted to take part in a survey or marketing campaign, please contact our Customer Support Team via our Feedback Page.

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When you Contact Customer Support

9.1. If you contact our Customer Support team via our Feedback Page, we will receive your email address, and may track your IP address, as well as the information you send to us to help resolve your query. We will keep records of our communications with you, including any complaints that we receive from you about other Users (and from other Users about you) for 6 years after deletion of your account.

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‍Cookies and similar technologies

10.1. When you visit our Sites or when you use our App, we may collect personal data from you automatically by using cookies or similar technologies. A cookie is a small file that can be placed on your device or browser that allows us to recognise and remember you.

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3. Use of Your Information

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How We Use Information

The main reason we use your information is to deliver and improve our services. Additionally, we use your info to help keep you safe and to provide you with advertising that may be of interest to you. Read on for a more detailed explanation of the various reasons we use your information, together with practical examples.

To administer your account and provide our services to you
Create and manage your account
Provide you with customer support and respond to your requests
Complete your transactions
Communicate with you about our services, including order management and billing
To help you connect with other users
Analyze your profile, activity on the service, and preferences to recommend meaningful connections to you and recommend you to others; For more information on our profiling and automated decision-making, please see our FAQ
Show users’ profiles to one another
To ensure a consistent experience across your devices
Link the various devices you use so that you can enjoy a consistent experience of our services on all of them. We do this by linking devices and browser data, such as when you log into your account on different devices or by using partial or full IP address, browser version and similar data about your devices to help identify and link them.
To provide new Indie services to you
Register you and display your profile on new Indie features and apps
Administer your account on these new features and apps
To serve you relevant offers and ads
Administer sweepstakes, contests, discounts or other offers
Develop, display and track content and advertising tailored to your interests on our services and other sites
Communicate with you by email, phone, social media or mobile device about products or services that we think may interest you
To improve our services and develop new ones
Administer focus groups and surveys
Conduct research and analysis of users’ behavior to improve our services and content (for instance, we may decide to change the look and feel or even substantially modify a given feature based on users’ behavior)
Develop new features and services (for example, we may decide to build a new interests-based feature further to requests received from users).
To prevent, detect and fight fraud or other illegal or unauthorized activities
Address ongoing or alleged misbehavior on and off-platform
Perform data analysis to better understand and design countermeasures against these activities
Retain data related to fraudulent activities to prevent against recurrences
To ensure legal compliance
Comply with legal requirements
Assist law enforcement
Enforce or exercise our rights, for example our Terms
To process your information as described above, we rely on the following legal bases:

Provide our service to you: Most of the time, the reason we process your information is to perform the contract that you have with us. For instance, as you go about using our service to build connections, we use your information to maintain your account and your profile, to make it viewable to other users and recommend other users to you.

Legitimate interests: We may use your information where we have legitimate interests to do so. For instance, we analyze users’ behavior on our services to continuously improve our offerings, we suggest offers we think might interest you, and we process information for administrative, fraud detection and other legal purposes.

Consent: From time to time, we may ask for your consent to use your information for certain specific reasons. You may withdraw your consent at any time by contacting us.

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Moderation Practices

We may use a combination of automated systems and a team of moderators to monitor and review accounts (including photos and any other information uploaded onto user profiles) and messages for content that indicates breaches of our Terms and Conditions of Use. If an account or message meets certain criteria that demonstrate that the Terms and Conditions of Use are likely to have been breached, the relevant account will be subject to a warning and the user’s access restricted and/or blocked. Affected Users can contact Indie to contest the decision.
If you post anything that is inconsistent with our Terms and Conditions of Use, we reserve the right to terminate or restrict access to your Account.

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Aggregated Information – We may share aggregated information with third parties that includes your personal data (but which doesn’t identify you directly) together with other information including log data for industry analysis and demographic profiling.

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Indie does not sell your data and has not sold your personal data in the previous 12 months.

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More information about disclosures

Sharing your personal data with Service Providers

We engage certain trusted third parties to perform functions and provide services to us (“Service Providers”). The suppliers with which Indie shares User personal data vary depending on a variety of factors, such as which of our App, Sites and services a User engages with. For example, to provide our services to Users, we typically use the following suppliers:
Billing services – to allow customers to purchase paid features of our App (for example, Google Play)
Authentication services – to allow customers to authenticate their account (for example, Twilio)
Social media providers – to allow customers to create/connect their Indie account with their account(s) on such platforms (for example Facebook, Instagram or IMDB)
Product improvement and market research – we use third party platforms (such as Typeform) and agencies (such as Kantar) to carry out customer surveys and market research to improve our products and services
IT services – some of the third-party software providers used in the operation of our business may process Users’ personal data (for example, if a User contacts us via social media with a support inquiry, their inquiry may be processed by a community management software provider)

We carry out due diligence on all Service Providers we engage to ensure they have adequate data protection and information security measures in place and only provide them with the personal data necessary to the service they are providing. Measures are taken to ensure that the data shared is non-attributable to the greatest extent possible and our suppliers are also subject to extensive obligations under our contractual arrangements, including strict data retention limits.

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Sharing your personal data with Marketing Services Providers

We partner with providers of marketing services (such as Facebook for example) (‘Marketing Services Providers’) to help us market and advertise our App and services on third party websites and applications and measure the effectiveness of our advertising campaigns. For example:

to exclude you from advertising campaigns aimed at finding new users, if you already have a Indie account;
to show Indie adverts to users who have visited the Indie App/Sites but haven’t yet created a Indie account;
to show Indie adverts to existing Users to encourage them to use the service (for example, when we release new features for the App, we may advertise these features to existing users);
to create an audience for our advertisements of other potential users who have similar characteristics to you based on the information the Marketing Service Providers holds about you (also known as a Lookalike Audience); or
to include you in a ‘custom audience’ that will receive Indie advertising content (a custom audience is essentially a list of people who we think are most likely to be interested in a particular advertisement).

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We share a limited amount of your personal data with these Marketing Services Providers, namely:

the advertising identifier associated with your device (this is a random number assigned by your mobile device manufacturer (for example Apple or Google) to your device to help advertisers (including the manufacturer) know when an ad has been viewed or clicked in an app, and when an ad causes a ‘conversion’ (for example, downloading the app advertised to you))
your estimated location (based on your IP address)
age and gender
data about your visit to our Sites or App and action taken on those (for example if you downloaded our App or created an account with our App)

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For more information about how we use cookies and other tracking technologies, including how you can set and manage your preferences with regards to such technologies, please see our Cookie Policy. Some platforms require user consent before Indie is permitted to use data gained through the platform for advertising purposes and where this is the case, Indie will only use this data where the necessary consent has been obtained. Through your device’s privacy settings, you also have the option to prevent or limit device identifiers being shared with third party advertisers and what use is made of the device identifiers. In some cases, these third parties will also use the data that they collect for their own purposes, for example they may aggregate your data with other data they hold and use this to inform advertising related services provided to other clients.

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Sharing with Facebook

Where we share data with Facebook as our Marketing Service Provider (including via the Facebook “Like” function), we are Joint Data Controllers with Facebook Ireland for this processing. This arrangement means that Indie has to provide you this notice, but you should contact Facebook if you wish to exercise your data protection rights. Further information, including how Facebook enables you to exercise your data protection rights, and subsequently processes your information as independent data controller can be found in Facebook Ireland’s Data Policy.
This data referred to above can include actions that you take on our website such as your interactions with our Sites or other information collected from cookies or similar technologies including the Facebook pixel. This allows us to measure the effectiveness of our advertising, improve our marketing practices, and helps us deliver more relevant advertising to you and people like you (including on social media such as Facebook).

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4. What Others May See About You

a. Our App is designed to make it easier for you to connect with other Users and to interact with them. When using the Indie App, you should assume that anything you post or submit on the App may be publicly-viewable and accessible, both by Users and non-users of the App. We want our Users to be careful about posting information that may eventually be made public.

b. Please be careful about posting sensitive details about yourself on your profile such as your religious denomination and health details. You may also choose to add sensitive information about yourself, such as your religion and political leanings. While you may voluntarily provide this information to us when you create your profile, there is no requirement to do so. Please remember that photographs that you post on Indie may reveal information about yourself as well. Where you do upload and choose to tell us sensitive information about yourself, including through the addition of badges to your profile, you are explicitly consenting to our processing of this information and making it public to other Users.

c. Your Indie profile and other information you make available via the App, including certain information added to your profile through third party accounts (such as Facebook, Instagram or Spotify) may be viewed and shared by Users with individuals who may or may not be users of the App. For example, a User may recommend you as a match to his or her Facebook friend(s) by taking a screenshot of your profile picture and sharing it, regardless of whether such friend(s) is also a User of the App.

d. Please also note that in certain countries Users may be provided with functionality enabling them to download a copy of their conversation history (as this is required by local laws) and that Indie has no control over how users may then publish or use that information.

e. If you log in to or access the App through your Facebook account or another third-party account on a device which you share with others, remember to log out of the App and the relevant third-party account when you leave the device in order to prevent other users from accessing your Indie account.

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5. Our Policy Towards Age

a. You have to be at least 18 years old to use the App.

b. Indie does not knowingly collect any information about or market to children, minors or anyone under the age of 18. If you are less than 18 years old, we request that you do not submit information to us. If we become aware that a child, minor or anyone under the age of 18 has registered with us and provided us with personal information, we will take steps to terminate that person’s registration.

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6. Security

a. We take appropriate security measures to help protect your information against loss, misuse and unauthorised access, or disclosure. We use reasonable security measures to safeguard the confidentiality of your personal information such as secured servers using firewalls.

b. Unfortunately, no website or Internet transmission is ever completely 100% secure and even we cannot guarantee that unauthorised access, hacking, data loss or other breaches will never occur, but here are some handy tips to help keep your data secure:

Please make sure you log out of your Account after use.
Please don’t share the password you use to access your Indie Account with anyone else.
Change your password periodically.

c. We cannot guarantee the security of your personal data while it is being transmitted to our site and any transmission is at your own risk.

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7. Linking Other Accounts to Indie

a. Using your social media details to sign in to Indie

When you sign in to our App using your Facebook account, you give permission to Facebook to share with us your name and profile picture. Unless you opt-out, you also give permission to Facebook to share with us your email address (if there is one associated with your Facebook account), date of birth, profile photos, gender, Page likes and current town/city.
If you register or sign in with your Apple ID, you give Apple permission to share your Apple login, a name (that can be edited by you) and an email (you can choose to hide your email and Apple will create a random email address so your personal email can stay private). This email address will be linked to your Indie account and will be used to retrieve your Indie account.
We will then use this personal data to form your Indie account. If you remove the Indie app from your Facebook settings, or from your Apple ID, we will no longer have access to this data. However, we will still have the personal data that we received when you first set up your Indie account using your Facebook or Apple ID (you must delete your Indie account entirely for us to no longer have access to this data).

b. Linking social media accounts to your Indie account

You may link your Indie account with your Instagram, Facebook or IMDB accounts. This allows you to share some information from those accounts directly to your Indie account (for example, Instagram photos).
We only receive the limited information that these entities permit to be transferred (as detailed by Instagram/Facebook/IMDB) and agreed by you when you first connect your account from such platforms with your Indie account).
If you no longer want to link your Indie account to your Instagram, Facebook or IMDB account, please visit the settings in your Instagram, Facebook or IMDB account and follow the instructions to remove the Indie app access permissions. Please note that any information already added to your Indie account from those platforms will not be deleted unless you delete it within your Indie account as well.

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8. Your California Privacy Rights

a. For Users who are California residents, you have the following rights under the California Consumer Privacy Act, and you have the right to be free from unlawful discrimination for exercising your rights under the Act:

You have the right to request that we disclose certain information to you and explain how we have collected, used and shared your personal information over the past 12 months.
You have the right to request that we delete your personal information that we collected from you, subject to certain exceptions.

b. California’s “Shine the Light” law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the businesses’ practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes.

c. From time to time, as part of a joint promotion with a third party, we may, if you participate in such promotion, disclose your contact information to the third party to allow them to market their products or services to you. Where this is a condition for participation in a promotion, we will always let you know before when you enter the promotion. Please follow the instructions provided to you by third parties to unsubscribe from their messages.

d In addition, under California law, operators of online services are required to disclose how they respond to “do not track” signals or other similar mechanisms that provide consumers the ability to exercise choice regarding the collection of personal information of a consumer over time and across third party online services, to the extent the operator engages in that collection. At this time, we do not track our Users’ personal information over time and across third-party online services. This law also requires operators of online services to disclose whether third parties may collect personal information about their users’ online activities over time and across different online services when the users use the operator’s service. We do not knowingly permit third parties to collect personal information about an individual User’s online activities over time and across different online services when using the App.

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9. Your Rights

a. Privacy laws applicable in your country may give you the following rights:

Right to be informed: what personal data an organisation is processing and why (we provide this information to you in this Privacy Policy).
Right of access: you can request a copy of your data.
Right of rectification: if the data held is inaccurate, you have the right to have it corrected.
Right to erasure: you have the right to have your data deleted in certain circumstances.
Right to restrict processing: in limited circumstances, you have the right to request that processing is stopped but the data retained.
Right to data portability: you can request a copy of certain data in a machine-readable form that can be transferred to another provider.
Right to object: in certain circumstances (including where data is processed on the basis of legitimate interests or for the purposes of marketing) you may object to that processing.
Rights related to automated decision-making including profiling: there are several rights in this area where processing carried out on a solely automated basis results in a decision which has legal or significant effects for the individual. In these circumstances your rights include the right to ensure that there is human intervention in the decision-making process.

b. The particular rights which are applicable to you (which might include other rights not listed above) may vary depending on your country. You should make yourself aware of the rights you have under applicable privacy laws in your country.

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10. Data Locations

a. We want you to be able to access Indie wherever you happen to be in the world. To enable us to provide that service, we operate a global network of servers including in the US, UK, EU, and (for Users located in Russia) Russia. The hardware is located in third-party data centres. Data collected by Advertising Partners and other Service Providers may also be held outside the UK and the European Economic Area. We ensure that the data is adequately protected by ensuring that valid, legal mechanisms are in place such as: EU approved model clauses, and implementing robust contractual standards.

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11. Data Retention and Deletion

a. We keep your personal information only as long as we need it for the legal basis relied upon and as permitted by applicable law.

b. You may permanently delete your Account at any time

c. When your Account is deactivated, we take reasonable efforts to make sure it is no longer viewable on the App. For up to 30 days, it is still possible to restore your Account if it was accidentally or wrongfully deactivated. After 30 days, we begin the process of deleting your personal information from our systems, unless:

we must keep it to comply with applicable law (for instance, if you make purchases within the App, some personal data may need to be kept for accounting purposes);
we must keep it to evidence our compliance with applicable law;
there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or
the information must be kept for our legitimate business interests, such as fraud prevention and enhancing Users’ safety and security. For example, information may need to be kept to prevent a user who was banned for unsafe behaviour or security incidents from opening a new account.

d. Where Indie uses machine learning, for example, to help us detect and prevent fraudulent card transactions, and to detect and prevent spam communications on the App (as explained above), we may need to keep personal information for a longer period than the retention periods explained above, to enable the machine learning to work properly. Where this is the case, we always seek to minimise the amount of personal information that is used and we ensure that it is ring-fenced and kept securely from other User personal information. We regularly review the period for which personal information is required for machine learning purposes and delete any identifiable information when it is no longer required.

e. To prevent abuse and/or misuse of Indie by a User following termination or deletion of a profile/Account we shall retain such information as we deem in our sole discretion may be necessary to ensure that User does not open a new Account and profile in breach of our Terms and Conditions of Use and to ensure compliance with all laws and regulations.

f. Warning: Even after you remove information from your profile or delete your Account, copies of that information may still be viewable and/or accessed to the extent such information has been previously shared with others, or copied or stored by others. We cannot control this, nor do we accept any liability for this. If you have given third party applications or websites access to your personal information, they may retain such information to the extent permitted under their terms of service or privacy policies.

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12. Changes to this Policy

a. As Indie evolves, we may revise this Privacy Policy from time to time. If we make a change to this policy that, in our sole discretion, is material, we will notify you, for example, via an email to the email associated with your Account or by posting a notice within Indie.

Indie