1. What data do we collect about you?
1.1 Data provided through direct interactions
Registration and other account information
When you register to use our services, we may collect the following information about you:
If you register using your Google account: first name, last name, email address and profile photo
If you register using your mobile number we collect your mobile number.
Validation of your ADPLUS account
We validate the accounts of ADPLUS users by using SMS verification to ensure that each account is associated with a real and unique user. This validation process is initiated once you proceed with posting your first ad or service listing on our platform. In order to validate your ADPLUS account before posting your ad listing, we will send you an SMS on a valid mobile number provided by you.
If you do not agree to validate your account, then your account will remain active and you will be able to use our services with limited functionality. This limited functionality of an account implies that you cannot publish new ad or service listings until your account is verified by SMS.
In case you create several ADPLUS accounts using the same mobile number and validate all those accounts via SMS verification, all such accounts will have a limited functionality and you will be asked to choose one of them. The account chosen by you will return to full functionality, and the rest of the accounts will remain to have limited functionality.
Once you have validated your ADPLUS account, it will remain associated with the mobile number used for the SMS verification. If you wish to change the mobile number associated with your ADPLUS account, you will need to contact our Customer Support team.
Taking part in our user surveys
We will occasionally provide you with our user surveys in order to measure your overall satisfaction with the quality of our services. You may choose to provide us with your contact details such as your email and your mobile number upon our request to contact you and invite you to attend one of our user experiences (UX) tests or an interview with our team. Please be aware that the information you give us in relation to our survey questions may occasionally contain personal data as voluntarily provided by you in your answers.
1.2 Data we collect automatically when you use of our services
When you interact with our services, we automatically collect the following information about you:
Device Information
We collect device-specific information such as operating system version, unique identifiers. For example, the name of the mobile network that you are using. We associate the device identifiers with your ADPLUS account.
Location information
Depending on your device permissions, if you post an ad or service on our platform, we automatically collect and process information about your actual location. Your location data allows you to see ads or services near you and helps you in posting ads and services within your location. In case we need your location data, we will first show you a pop-up which will ask you to choose to allow or not to allow us to access your location data. If you do not allow us to have access to your location data, you will still be able to use our services but with limited functionality. If you do allow us to access your location data you can always change this later by going to the settings on our App and disable the permissions related to location sharing.
Client and Log data
Technical details, including the Internet Protocol (IP) address of your device, time zone and operating system, we will also store your login information such as registration date, date of last password change, date of the last successful login.
Call Recording
If our representative calls you on the telephone or if you call us on the telephone, we may record such call for training and internal quality purposes.
2. Why do we process your personal information?
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract, we are about to enter into or have entered into with you, or where you have expressly requested us to contact you.
Where it is necessary for our legitimate interests to improve our services and to provide you a safe and secure platform.
Where we need to comply with a legal or regulatory obligation.
We have set out below a description of the reasons for which we use your personal data, [and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate].
2.1 For providing access and delivering services through our platform
1. If you log in using your mobile number or email id, we use your first name and last name, mobile number and/or e-mail address to identify you as a user and provide access to our platform.
2. If you log in using your Google account or your Apple ID, we use your first name and last name and your email address of such account, as well as the URL to your profile picture (except for Apple ID) to identify you as a user on our platform and to provide you access to our platform.
3. We use third party payment service providers to process any payment you make to our services. Depending on the method of payment, you may be requested to provide us with your payment details which we will then provide to the payment service provider in order to process your payment. We do not store your credit card information.
2.2 For improving your experience on the platform and developing new functionalities of the platform
1. If you choose to provide us with your location data, we use your location to enhance the performance of our services and to personalize the content we direct towards you. For example - with the help of location data we display with service listings which are in your vicinity to improve your experience. For this purpose, Google Maps is integrated into our platform. This means that both Google and we are responsible for the processing of your location data in the context of Google Maps. In any case, we will not process your location data for any other purposes but those explained in this Privacy Statement. However, Google might process such location data for their own purposes as explained in the Google Privacy Policy which can be reviewed Your use of Google Maps through our platform is subject to Google Maps’ Terms of service.
2. In case you agree to opt for KYC verification as available on our services, depending on the device camera permission, we will request you to click in real time an image of your face and an image of your identity proof in quick succession in order to verify your identity. Upon completion of the KYC process, in case the image on the identity proof matches with the image of the face captured, your account will be considered as verified. Such verification will help you to build trust among other users and receive better responses to your listings.
We process the above information for adequate performance of our contract with you and on the basis of our legitimate interest to improve your experience of our services.
2.3 To take your feedback, promote and offer you services that may be of your interest
1. We use your mobile number, log data and unique device identifiers to administer and protect our platform (including troubleshooting, data analysis, testing, fraud prevention, system maintenance, support, reporting and hosting of data).
2. To prevent and detect fraud on our platform, we recognize suspicious or fraudulent user behaviour based on certain information such as user posted content, which may lead to us banning certain user accounts. We do this to detect and prevent fraud and to keep our services safe and secure for our users. If you think that your account was wrongfully banned, you can contact our Customer Support team, in which case our team will review the decision to ban your account.
2.4 To take your feedback, promote and offer you services that may be of your interest
1. We may contact you through your registered mobile number or email id in order to take feedback from you about our services.
2. We use your email address and mobile number to make suggestions and recommendations to you about our services that may be of interest to you.
We process the above information based on our legitimate interest in undertaking marketing activities to offer you services that may be of your interest. Specifically, you may receive certain marketing communications from us:
By any preferred means of communication if you have requested such information from us.
By email or phone, regarding similar products and services, if you already use our services or acquired some of our products.
By phone or email if you registered for a promotion.
By phone or email, if you have provided your feedback for our services through our platform, social media, or any other means.
Being a registered user on our platform, please note that if you have registered yourself on DND/DNC/NCPR services, you will still receive the above communications.
3. How will we inform you about changes in our privacy statement?
We may amend and update this privacy statement from time to time. We will notify you of material changes to this privacy statement as appropriate under the circumstances and as required by applicable laws, e.g. by placing a prominent notice within our services or by sending you a message via our services or by sending you an email. If you do not agree with the way we are processing your personal data and the choices we are providing to you, you may close your account at any time by writing to us from Help section.
4. Communication
We will communicate with you by email, SMS, WhatsApp or in the app notification in connection with our services/platform to confirm your registration, to inform you in case your ad listing has become live/expired and other transactional messages in relation to our services. As it is imperative for us to provide you such transactional messages you may not be able to opt-out of such messages.
5. Who do we share your data with?
We may have to share your personal data with the parties set out below.
Corporate Affiliates: We may share your data with our group companies which help us in providing business operation services such as product enhancements, customer support and fraud detection mechanism.
Select Partners: We may share your personal information which includes name, phone number and email address with select partners in the course of our business, who have agreed to respect and protect your privacy in the same manner we do. These partners may utilize your information to deliver services tailored to your preferences and interests. You may contact our Grievance Officer if you do not wish to receive such services.
Third Party Service Providers: We use third party service providers to help us deliver certain aspect of our services for example, cloud storage facilities. We conduct checks on our third-party service providers and require them to respect the security of your personal data and to treat it in accordance with the law. We do not allow them to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Advertising and Analytics Providers: In order to improve our services, we will sometimes share your non-identifiable information with analytics providers that help us analyze how people are using our platform/service. We, share your information with them in non-identifiable form for monitoring and reporting the effectiveness of the campaign delivery to our business partners and for internal business analysis.
Law Enforcement Authorities, Regulators and others: We may disclose your personal data to law enforcement authorities, regulators, governmental or public bodies and other relevant third parties comply with any legal or regulatory requirements. We may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy statement.
Publicly Available Information: When you post an item for sale using our services, you may choose to make certain personal information visible to other ADPLUS users. This may include your first name, last name, your email address, your location and your contact number. Please note, any information you provide to other users can always be shared by them with others so please exercise discretion in this respect.
6. Where do we store your data and for how long?
The data we collect about you will be stored and processed in secure servers in order to provide the best possible user experience. For example – for fast mobile app boot up.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
7. Your rights - data deletion requests
To exercise your privacy rights and choices, if you do not want us to process your data, then you can write an email to us as mentioned in the Help section of the App.
There may be situations where we cannot grant your request — for example, if you ask us to delete your transaction data and ADPLUS is legally obligated to keep a record of that transaction to comply with law.
8. Technical and organizational measures and processing security
All the information we receive about you are stored on secure servers and we have implemented technical and organizational measures that are suitable and necessary to protect your personal data. ADPLUS continually evaluates the security of its network and adequacy of its internal information security program, which is designed to (a) help secure your data against accidental or unlawful loss, access, or disclosure, (b) identify reasonably foreseeable risks to the security of the ADPLUS network, and (c) minimize security risks, including through risk assessment and regular testing. In addition, we ensure that all payment data are encrypted using SSL technology.
Please note, despite the measures we have implemented to protect your data, the transfer of data through the Internet or other open networks is never completely secure and there is a risk that your personal data may be accessed by unauthorized third parties.
9. Links to third-party websites
Our platform may contain links to third party websites or apps. If you click on one of these links, please note that each one will have its own privacy policy. We do not control these websites/apps and are not responsible for those policies. When you leave our platform, we encourage you to read the privacy notice of every website you visit.