Privacy Policy of Umla
Welcome to the Umla Privacy Policy (“Policy”). This Policy explains how we gather, secure, and share your information, along with the individuals with whom we share it. We recommend reading this Policy alongside our Terms and Conditions.
As you engage with the Umla mobile application ("App"), our websites, microsites (such as Umla.com), and digital services (including surveys and competitions) (collectively referred to as "Sites"), certain information about you is collected.
Moreover, if you choose to use the App or Sites to share information with other users, including friends and contacts ("Users"), we may need to share your information at times.
The App and Sites have a global reach, and your data will be transferred to and utilized in India, regardless of your residing country. This Policy details how we protect your personal data during international transfers, so please read it thoroughly!
Who We Are
The App and Sites are operated by the "Umla Technologies Private Limited" (also referred to as "we" or "us"), encompassing Umla Technologies Pvt. Ltd. The Umla Group comprises entities controlling personal information processed through the Umla App and Sites.
The Umla Group has designated a Data Protection Officer, can reach via email at:[[email protected]].
Collection of Information
Registration Information:
Upon downloading the App and creating an account ("Account"), we may gather specific data ("Registration Information") about you, including:
- Name
- Username
- Email address
- Contact number
- Personal preferences
- Photographs
- Location
- Govt ID
Login data for linked social media accounts (e.g., Facebook, Instagram). For more information, refer to "Linking other Accounts to Umla" in section 7 below.
You can modify this information by logging into Umla at any time (except for date of birth and location, which may be updated based on device settings). Ensure your account details are current. Profile data like your name, username, and personal preferences might be visible to other users.
For Users in India, data we collect aligns with categories of "Personal 'Information" as defined by applicable laws:
- A.Identifiers, like name and location
- B.Personal information, including contact and financial details
- C.Characteristics protected under relevant laws, like gender identity, sexual orientation, and medical conditions
- D. Commercial information, such as transactions
- E. Biometric information
- F.Internet activity, including browsing history and interactions with our Sites and App
- G.Geolocation data
- H.Audio, visual content, like photos and videos
- I.Employment-related details, such as work history
- J.Non-public education information
- K.Derived inferences from above data for profile creation.
We value your privacy and will use this reference to shape Umla's Privacy Policy according to your specific requirements.
Profile Information
We advise and encourage all our members, including you, to be cautious about the information you reveal on your profile. We discourage sharing email addresses, URLs, instant messaging details, phone numbers, full names or addresses, credit card details, national identity numbers, driver's license details, and sensitive information that might be misused.
When you share information about yourself or communicate with other Users through messaging, the responsibility for the personal information you disclose lies with you. Refer to Section 4 for details on who can access your posts on Umla.
Profile Verification Information (Including Biometric Information)
To ensure safety, security, and a positive user experience, we require Users to verify their accounts. This may entail providing your phone number and carrying out photo verification, helping prevent robot activity and fake profiles that could be used for malicious purposes.
If you opt to verify your profile photo, each submitted photo will be scanned, including potential facial recognition comparisons to your profile photo for identity verification. Verification photos are not displayed on your profile. We retain these scans for verification and record-keeping purposes for three years after your last interaction with us, or as needed. After the retention period, we securely delete the scans from our systems.
We've tailored Umla's Privacy Policy to incorporate these considerations from your reference.
Purchases Information
If you choose to purchase any of our premium offerings, we will securely process your payment information for fraud prevention and audit/tax compliance purposes.
Umla employs automated decisions to prevent processing fraudulent payment transactions as part of our anti-fraud protocols. Our systems assess payment transactions to identify potential breaches of our Terms and Conditions of Use. Transactions meeting specific criteria indicating likely breaches and fraud are automatically blocked. Users affected by blocked transactions will be notified and can contest the decision with Umla.
Please note that if your account is blocked for any reason, your accounts on other Umla platforms/applications may also be blocked as part of our anti-spam and anti-fraud measures.
Geolocation Information
With your device location access, we collect WiFi access point and location data including longitude and latitude to offer personalized features. This information helps us tailor the App, making it easier for you to engage with other Users by showing locality information on profiles and suggesting nearby profiles.
If you granted Umla location access and wish to disable it:
iPhone app — settings, privacy, location services, Umla Android — settings, location, Umla, permissions, location Device Information
When using the App, we may gather device details like unique identifiers, device model, and operating system for various purposes outlined in this policy. With your permission, the App might access your device's address book solely to add a contact.
Links
We track your interactions with links on Umla, including third-party services, for aggregated click statistics and analytics.
Messages
We review message content to identify trends, topics, and sentiments among Users. Personally identifying information is stripped from messages before review. User message content and derived information are not shared with third parties.
We've incorporated relevant elements from your reference into Umla's Privacy Policy.
Umla Success Stories, Surveys, and Other Contributions
Occasionally, we conduct surveys for research purposes and may reach out to inquire if you're interested in participating. Additionally, we might contact you to gather feedback, testimonials, or for participation in marketing campaigns (e.g., if you've found a connection on Umla, we may ask if you'd like to be featured in our advertising). These surveys and campaigns are voluntary, and detailed information will be provided during contact. If you prefer not to be approached for surveys or marketing efforts, kindly contact our Customer Support Team via our Feedback Page
When You Contact Customer Support
When you reach out to our Customer Support team via our Feedback Page, we will receive your email address and may track your IP address, along with the information you provide to assist in resolving your query. Records of our communications, including complaints from you about other Users (or from other Users about you), will be retained for 6 years after your account is deleted.
Cookies and Similar Technologies
When you use our Sites or App, we may automatically collect personal data through cookies or similar technologies. Cookies are small files that can be placed on your device or browser to help us recognize and remember you.
For comprehensive information on cookies, including their usage and the choices available to you, please refer to our Cookie Policy.
We've adapted relevant aspects from your reference into Umla's Privacy Policy.
Use of Your Information
Our utmost priority is to ensure your experience with Umla is delightful, without any hitches. To create this experience, we may utilize your Registration and other data to:
- 1.Provide you with our services and features.
- 2.Keep you updated with information about the App, including updates and new features.
- 3.Customize the App/Sites and the content to cater to your preferences. Conduct research and analysis on your interaction and usage patterns. Test new technologies and processes for App/Sites enhancement.
- 4.Resolve disputes, troubleshoot issues, and enforce our Terms & Conditions. Investigate fraudulent activities, safeguard our legal rights, and enforce our Terms & Conditions.
- 5.Send you information about promotions and offers available (e.g., specify types of goods/services/offers) through direct marketing or other communication methods, provided you've opted in for our communications. Email direct marketing will only be used with your consent during Account creation or via App Settings (you can withdraw from marketing anytime through App Settings or opt-out mechanisms provided in each message).
- 6.Safeguard our Users and third parties from potential harm. Our Matching Algorithms
- 7.We've designed matching algorithms to predict your compatibility with other users, showing you potential matches. Our matching algorithms employ the following data to predict compatibility and generate profile recommendations.
Information in your profile
Activity in our App.
Photo verification status.
Device coordinates for proximity assessment.
The legal basis for processing profile and proximity data is the necessity for contractual services under Article 6(1)(b) GDPR. Processing app activity data is based on our legitimate interests under Article 6(1)(f) GDPR, particularly our interest in offering personalized recommendations for your matches. If you've provided sensitive data in your profile (e.g., beliefs), processing is based on your explicit consent.
Matching Algorithms and Moderation Practices
At Umla, our matching algorithms are developed to assess compatibility between users, helping us connect you with like-minded individuals. We use the following data to generate profile recommendations and predict compatibility:
Information from your profile. Activity within our app.
Photo verification status.
Device coordinates for proximity assessment.
Processing profile and proximity data is necessary for providing our contractual services under Article 6(1)(b) GDPR. App activity data processing is based on our legitimate interests as per Article 6(1)(f) GDPR, specifically our aim to offer personalized recommendations for matching within the app. If sensitive data (e.g., beliefs) is provided in your profile, its processing relies on your explicit consent.
Moderation Practices
We employ automated systems and a moderation team to review accounts, photos, and profile content for possible breaches of our Terms and Conditions. If an account or message indicates potential violations, it may receive a warning, access restrictions, or be blocked. Users can contest such decisions by reaching out to us.
Any content not in accordance with our Terms and Conditions may result in termination or restricted access to your Account.
Lawful Basis for Data Processing
Umla operates in compliance with Indian data protection laws. We ensure transparency regarding our lawful basis for using your data, as outlined in the table below. Consent-based processing allows withdrawal at any time, while legitimate interests-based processing offers the right to object. Relevant sections of this Policy explain consent withdrawal or opt-out procedures (where applicable).
| Purpose for Data Use | Data | Source | Legal Basis |
|---|---|---|---|
| Providing Umla networking service | Name, email address, date of birth, location | Provided by you during registration; location data from your device | Contractual necessity |
| Facilitating networking opportunities | Optional profile info, including special categories (e.g., sexual preferences, religion), photos, etc. | Provided by you | Contractual necessity & legitimate interests |
| Identity verification and fraud prevention | Phone number, photo for profile verification, ID photo, geolocation, device info | Provided by you or obtained from your device | Legitimate interests |
| Processing premium service payments | Payment card details | Provided by you | Contractual necessity |
| Sending marketing information | Name, email address, postal address, Instagram handle, phone number | Provided by you | Consent or legitimate interests |
| Research, analysis, and testing | Log and usage data, IP address, browser, pages accessed, images, etc. | Provided by you | Legitimate interests |
| Responding to queries | Email address, IP address, social media name, phone number | Provided by you; IP address from device | Legitimate interests |
| Investigating and blocking users | Registration info, profile data, message content, IP, device data | Provided by you or device | Legitimate interests |
| Enabling third-party account login | Data from Facebook and others | Obtained from third-party accounts | Legitimate interests |
| Blocking payment transactions | Name, IP address, email, mobile number, cardholder info, payment details, user ID | Provided by you or device; payment info from interactions | Legitimate interests |
| Serving ads on Umla | Location, gender, age, profile data | Provided by you or device | Legitimate interests |
| Serving ads on third-party networks | Site or app visit data, IP, age, gender, device ID | Provided by you or device | Consent |
| Running surveys and marketing campaigns | Email address, cell phone number | Provided by you | Legitimate interests |
| Enabling video/audio calls and media sharing | Usage data, images, video | Obtained from device | Legitimate interests |
| Defending legal claims and protecting rights | Relevant info | Provided by you, device, or third parties | Legitimate interests |
Disclosure of Information
Umla is committed to safeguarding your Registration Information and personal data. However, there are limited circumstances where disclosure may occur, as described below:
| Circumstances for Disclosure | Disclosed Data |
|---|---|
| Providing Umla networking service | Registration Information, personal data, and other Categories |
| Moderators | Name, user registration details, profile data, message content, photographs |
| Payment Processing and Telecommunications Companies | Cardholder name, cardholder address, card number, payment amount, transaction date/time |
| Law and Harm | All personal data, including CCPA Categories, when legally required to comply with court orders, protect safety, address fraud, or safeguard rights and property |
| Business Transfers | All personal data, including CCPA Categories, in case of business transitions, acquisitions, re-organizations, sales, insolvency, or administration |
| Marketing Services Providers | Advertising identifier (Device ID), estimated location (based on IP address), age, gender, data about site/app visit, hashed email address for 'custom audiences' |
| Anti-Spam and Anti-Fraud | Email address, phone number, IP address, social network ID, username, user agent string, transaction and payment data |
| Aggregated Information | Aggregated data including personal data (anonymized) for industry analysis and demographic profiling |
More Information About Disclosures
Service Providers
Umla collaborates with trusted third-party service providers to deliver specific functions and services ("Service Providers"). The selection of suppliers may vary based on user engagement with Umla's platforms and services, including the App and Sites. Here are some examples of the types of suppliers we engage:
Billing Services:
To facilitate the purchase of premium features, such as Google Play for payment processing.
Authentication Services:
For user account verification, like Instagram or other social media platforms for authentication.
Social Media Providers:
To enable users to link their Umla account with their social media accounts, such as Facebook, Instagram, or Spotify.
Product Improvement and Market Research:
We conduct customer surveys and market research using third-party platforms like Typeform and agencies like Kantar to enhance our products and services.
IT Services:
Some third-party software providers assist in our business operations, such as community management software (e.g., Khoros) for processing user inquiries received via social media.
Rigorous due diligence is carried out before engaging Service Providers to ensure compliance with data protection and information security requirements. Only necessary personal data is shared, and measures are taken to ensure data is as non-attributable as possible. Contractual agreements enforce strict data retention limits and compliance with our data protection standards.
IT Services:
Some third-party software providers assist in our business operations, such as community management software (e.g., Khoros) for processing user inquiries received via social media.
Marketing Services Providers
Umla collaborates with Marketing Services Providers (e.g., Facebook) to market and advertise the App and services on third-party platforms and measure ad campaign effectiveness. For instance, these providers help us:
Exclude Umla users from new user ad campaigns.
Display Umla ads to those who visited the App/Sites but haven't created an account. Create a Lookalike Audience with characteristics similar to yours.d campaign effectiveness. For instance, these providers help us:
Include users in custom audiences for targeted content. Limited personal data is shared with these providers, including
Advertising identifier associated with your device. Estimated location based on your IP address
Age and gender.
Data about your App/Sites visit and actions taken (e.g., downloads, account creation).
Hashed version of your email address for 'custom audiences'. Hashing encrypts data for privacy, preventing it from being traced back to the original email address
Please refer to our Cookie Policy for information about tracking technologies and managing your preferences.
These third parties may use collected data for their own purposes, including aggregating it with other data for advertising-related services offered to other clients.
4.What Others May See About You
We believe our Users are amazing and want to provide features that let you showcase your awesomeness to the world. Our App is designed to facilitate connections and interactions among Users.
When using Umla, it's important to understand that anything you post or submit on the App might be publicly visible and accessible by both App Users and non-users. We urge Users to exercise caution when sharing information that could potentially become public.
Please be mindful of sharing sensitive details on your profile, such as religious affiliation or health information. You can also choose to include sensitive information in your profile using Umla badges, such as your political or religious preferences.
While providing this information is voluntary, including your sexual preferences, there's no obligation to do so. Keep in mind that photos you upload on Umla can also reveal information about you. By uploading sensitive information, including through badges, you're giving explicit consent for us to process and share this information publicly with other Users.
Your Umla profile and other information you make available on the App, including data from third-party accounts like Facebook or Instagram (see section 7 of this Privacy Policy for more), can be viewed and shared by Users, whether they're on the App or not. For instance, a User might recommend you as a match to their Facebook friends by sharing a screenshot of your profile picture, regardless of whether their friend is an App User.
If you access the App through a shared device using your Facebook or another third-party account, remember to log out of both the App and the associated account when you're done to prevent others from accessing your Umla account.
5. Our Policy Towards Age
While we aim for widespread enjoyment of our platform, Umla requires users to be at least 18 years old to use the service.
Umla does not knowingly gather information from or market to children, minors, or anyone below the age of 18. Should we discover that a child, minor, or someone under 18 has registered with us and provided personal information, we'll take steps to terminate their registration.
6. Security
At Umla, we consider the security of your information a top priority and have implemented robust measures to safeguard it against unauthorised access, loss, misuse, and disclosure. Our approach involves employing reasonable security measures to ensure the confidentiality of your personal data, including utilising secure servers and firewalls.
It's important to acknowledge that, while we strive for the highest level of security, no website or online transmission can guarantee absolute protection against potential risks such as unauthorised access, hacking, data loss, or breaches. Nonetheless, we offer practical recommendations to enhance your data's security:
Always log out of your Umla account once you've finished your session, minimising the chance of unauthorised access.
Refrain from sharing your account password with others, as it's a crucial element in securing your account.
Regularly update your password to strengthen its effectiveness against potential threats.
If you suspect unauthorized access to your account or password, please follow the outlined steps provided here.
Be aware that any data transmission to our platform carries inherent risks, and it's important to exercise caution.
Your security is of utmost importance to us, and while we implement stringent security measures, it's essential to remain vigilant in safeguarding your personal information.
7. Linking Other Accounts to Umla
Integrating Your Social Media Accounts with Umla
By signing in to our platform using your social media accounts, such as Facebook or Apple ID, you grant permission for certain information to be shared with us. If you choose to sign in using your Facebook account, Facebook provides us with your name and profile picture. Unless you choose otherwise, Facebook may also share your email address (if linked to your Facebook account), date of birth, profile photos, gender, Page likes, and current location.
When you register or sign in through your Apple ID, you give Apple consent to share your Apple login, a customizable name, and an email (which can be hidden). This email will be associated with your Umla account and utilized for account retrieval purposes.
This shared information is utilized to establish your Umla account. If you remove the Umla app's access from your Facebook or Apple ID settings, our access to this data is revoked. Nevertheless, the personal data gathered during the initial setup of your Umla account using Facebook or Apple ID remains in our possession (full removal of your Umla account is required to completely revoke this access).
Linking Social Media to Your Umla Account
You have the option to link your Umla account to Instagram, Facebook, or Spotify. This integration enables selected information from those platforms to be shared directly with your Umla profile, such as Instagram photos or top Spotify artists.
Only the data that Instagram or Spotify permits to be transferred is received by us (subject to Instagram/Facebook/Spotify's terms and your consent when linking these accounts to Umla).
Should you decide to unlink your Instagram, Facebook, or Spotify account from your Umla profile, visit the settings in your respective social media account and follow the instructions to revoke the app access permission for Umla. Please note that any information previously imported to your Umla account from these platforms will persist unless you manually remove it within your Umla profile settings.
Your Rights
Privacy laws applicable in your country may give you the following rights:
Right to be informed: what personal data an organization 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
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.
If you want to exercise any of your rights listed above please visit our Feedback Page or email our Data Protection Officer at [email protected].
For your protection and the protection of all of our Users, we may need to request specific information from you to help us confirm your identity before we can answer the above requests.
If you have a concern about how we have processed your request or your personal data, you should contact us in the first instance via the contact details listed above.
Data Locations with Umla
We aim to make Umla accessible to you no matter where you are in the world. To achieve this, we maintain a global network of servers, which includes locations in India, and some other countries. While these servers are situated in third-party data centres, they are owned by the Umla Group.
It's worth noting that data collected by Advertising Partners and other Service Providers might also be stored outside of India. To ensure the protection of this data, we have put in place appropriate safeguards. These safeguards include India approved model clauses, which can be accessed here, as well as robust contractual standards.
If you require further information about the specifics of the safeguards we've implemented, please don't hesitate to contact us at [email protected].
Data Retention and Deletion with Umla
We retain your personal information only for as long as it is necessary based on the legal basis described in Section 2 above and as allowed by applicable laws. Please refer to "Profile Verification Information (Including Biometric Information)" in Section 1 above for details on our retention policy regarding biometric data.
Upon deletion of your Umla account, we ensure that your account becomes no longer visible within the app. However, for a period of up to 28 days following deletion, there's a possibility to restore your account in case of accidental deletion. After this 28-day period, we initiate the process of removing your personal data from our systems, unless:
We are legally obligated to retain it, such as for tax and accounting purposes if you made purchases within the app.
We need to retain it to demonstrate our compliance with applicable laws, such as retaining account information and records of behavior that led to an account block for evidential purposes in case of queries or legal claims.
There are unresolved issues, claims, or disputes that necessitate the retention of relevant information.
The information must be retained for our legitimate business interests, such as fraud prevention and enhancing user safety and security.
A note of caution: Even after you delete information from your profile or close your Umla account, copies of that information might still be accessible or viewable if it was previously shared with others or copied/stored by others. We don't have control over this and don't accept liability for it. If you've granted third-party applications or websites access to your personal data, they might retain such data in accordance with their terms of service or privacy policies.
Thanks for taking the time to read this, and we hope we didn't bore you!
Changes to this Policy with Umla
As Umla continues to develop, there might be updates to this Privacy Policy from time to time. The most current version of the policy will govern how we utilise your information and can always be accessed at umla.com/privacy. If there's a change to this policy that we deem, at our sole discretion, to be significant, we will inform you. This could be through an email to the address linked with your account or by posting a notice within Umla.
Effective Date
This Privacy Policy was last updated on July 30th, 2023.
