For the purpose of processing personal data, we may engage data processors and/or, at its sole discretion, hire other persons to perform certain functions on behalf of Messej. In such cases, we shall take necessary measures to ensure that such data is processed by the personal data processors in accordance with instructions of and applicable European Union legislation. Shall also require the personal data processors to implement appropriate measures for the security of personal data. In such cases, we shall ensure that such persons will be subject to the non-disclosure obligation and will not be able to use this information for any other purpose, except to the extent necessary to perform the functions assigned to them.
ACCEPTANCE AND USE
DATA PROTECTION PRINCIPLES
“Personal data” means any information that enables us to identify you or the beneficiary of your transaction with us, directly or indirectly, such as name, email, address, telephone number, any form of identification number or one or more factors specific to your or your beneficiary’s identity.
We are committed to complying with applicable data protection laws and will ensure that personal data is:
DATA WE COLLECT ABOUT YOU
Messej may collect two (2) types of information about you: personal and non-personal.
PERSONAL INFORMATION WE COLLECT ABOUT YOU (PIPEDA)
According to the federal Personal Information Protection and Electronic Documents Act, 2000 (PIPEDA), “personal information” means information about an identifiable individual. The information you provide to Messej is considered personal information; it is possible to relate it back to you through your name, address, e-mail address, telephone number and any other information that can identify you. If information cannot be related to an identifiable individual it is considered anonymous information (such as laboratory results identified by alpha-numeric identifier instead of individual’s name). Whenever possible, Messej works with anonymous information. This privacy statement does not apply to anonymous information.
TYPES OF DATA WE COLLECT FROM YOU p>
Non-personal information refers to information that, by itself, does not identify you as a specific individual (e.g. demographic information or web site visitations). Messej may collect non-personal information through any of the methods discussed above as well as automatically through use of industry standard technologies described further below.
INFORMATION COLLECTED THROUGH TECHNOLOGY
While you are able to visit the Messej site and remain anonymous, Messej or its third party service providers may still collect non-personal information about your use of the Messej materials (e.g. Your internet browser, operating system, ip address, connection speed, and the domain name of your internet service provider). Such information may be gathered by the following methods:
OTHER INFORMATION YOU MAY SUBMIT
You may submit data to us for limited purposes such as requesting customer support; answering a questionnaire; participating in a study; entering contests or sweepstakes; or signing up to receive communications from us or another user.
INFORMATION WE COLLECT FROM YOU AUTOMATICALLY
We receive and store certain types of information automatically, such as whenever you interact with or use Messej app. This information helps us address customer support issues, improve the performance of Messej applications, providing you with a streamlined and personalized experience, and protect your account from fraud by detecting unauthorized access. Information collected automatically includes:
For example, we may automatically receive and record the following information on our server logs:
We may also use identifiers to recognize you when you access our service and or App via an external link, such as a link appearing on a third party site
HOW WE USE YOUR DATA
We may use your data for the following purposes:
We may use algorithms and other automated means to implement any of the above.
REMARKETING ON THE APP AND SERVICES
WITH WHOM WE SHARE YOUR DATA
We share data with third parties as follows:
Messej may occasionally send you push notifications through our mobile applications. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device. We may also collect location-based information if you use our mobile applications. You may opt-out of this collection by changing the settings on your mobile device.
DO NOT TRACK
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers and devices. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
INTEREST-BASED ADVERTISING TECHNOLOGIES
As noted above, you may limit advertising tracking using advertising identifiers through your mobile device’s privacy settings.
The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at http://www.networkadvertising.org/managing/opt_out.asp, or http://www.youronlinechoices.eu/ and http://www.aboutads.info/choices/.
We retain your data for as long as you have an account. When you close an account, we will delete your personal information. We may retain logs of automatically collected information (for internal analytics); your email address; your tax information; communications with you; and your transactional information (for auditing, tax, and financial purposes). When we no longer have a business reason for retaining data, we will delete or anonymize it.
If we receive a legal process pertaining to your account, we will retain your data for as long as we in good faith believe is necessary to comply with the legal process. Similarly, if we believe that your account has been involved in wrongdoing, we may preserve your data to defend or assert our rights.
EEA Data Subjects
Legal Bases for Processing your Information:
For individuals who are located in the European Economic Area, United Kingdom or Switzerland (collectively “EEA Residents”) at the time their personal data is collected, we rely on legal bases for processing your information under Article 6 of the EU General Data Protection Regulation (“GDPR”). We generally only process your data where we are legally required to, where the processing is necessary to perform any contracts we entered with you (or to take steps at your request prior to entering into a contract with you), for our legitimate interests to operate our business or to protect Messej App or your, property, rights, or safety, or where we have obtained your consent to do so. Below is a list of the purposes described in our policy with the corresponding legal bases for processing.
YOUR PRIVACY CHOICES
We enable you to make numerous choices about your data:
OUR COPPA POLICY TOWARDS CHILDREN
Messej complies with both the Children’s Online Privacy Protection Act of 1998 (COPPA) and, with regard to EU data subjects, with GDPR. We do not knowingly request to collect personal information required for Messej Premium Membership from any person under the age of 16. If a user submitting personal information is suspected of being younger than 16 years of age, Messej will prevent user from registering for Premium Plan or Package, cancel his/her membership without being liable to refund any paid subscription fees, also Messej retains the Right to close such account and/or not allow such users to continue using Messej Service. We will also take steps to delete the information as soon as possible.
Please notify us if you know of any individuals under the age of 16 using our Premium Services so we can take action to prevent access to our Services.
What is it?
How do we use it?
CROSS BORDER TRANSFERS
To facilitate our global operations, Messej may transfer, store, and process your information within our family of companies, partners, and service providers based throughout the world.
We contractually obligate recipients of your personal information to agree to at least the same level of privacy safeguards as required under applicable data protection laws. By communicating electronically with Messej, you acknowledge and agree to your personal information being processed in this way.
If you have a complaint about our privacy practices and our collection, use or disclosure of personal information please submit your request via any of Messej provided CONTACT US mediums.
DATA TRANSFERRED OUT OF THE EU
Our Singapore based company, Messej, is the publisher of Messej Mobile App, confirms its compliance with the EU-US Privacy Shield Framework. We are committed to subjecting all personal information received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework's applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce's Privacy Shield List at https://www.privacyshield.gov.
Messej does its best to process personal information it receives under the standards of Privacy Shield Framework and subsequently transfers to a third party acting as an agent on its behalf. Before we share your information with any third party that is not also certified under the EU-US Privacy Shield Framework, Messej will enter into a written agreement that the third party provides at least the same level of privacy safeguard as required under those Frameworks, and assures the same level of protection for the personal information as required under applicable data protection laws.
Worldwide data subjects with inquiries or complaints relating to Messej Privacy Shield internal policy should first contact Messej by filling the CONTACT US form provided in www.Messej.com. If we are unable to resolve your complaint or dispute, you may refer your complaint to our designated independent dispute resolution mechanism, i.e. the International Centre for Dispute Resolution ("ICDR").
LEGAL BASES FOR PROCESSING (FOR EEA USERS):
If you are an individual in the European economic area (EEA), we collect and process information about you only where we have legal bases for doing so under applicable EU laws. The legal bases depend on the services you use and how you use them. This means we collect and use your information only where:
If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party (e.g. your employer) have a legitimate interest to do so, you have the right to object to that use though, in some cases, and this may mean no longer using the services.
SECURITY MEASURES FOR SAFEGUARDING YOUR INFORMATION
Messej takes appropriate security measures to protect against unauthorized access, alteration, disclosure or destruction of personal information. These include, but are not limited to, internal reviews of: (a) Messej’s data collection; (b) storage and processing practices; (c) electronic security measures; and (d) physical security measures to guard against unauthorized access to systems where Messej stores personal information. All Messej employees, contractors and agents who access personal information are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution or unauthorized use or disclosure of personal information.
THIRD-PARTY APP SITE AND LINKS
The Messej contents may contain links to third parties who may collect personal information and non-personal information directly from you. Additionally, Messej may use third parties to provide components of the Messej contents. In either case, such third parties may have separate privacy policies and data collection practices, independent of Messej. Messej: (a) has no responsibility or liability for these independent policies or actions; (b) is not responsible for the privacy practices or the content of such App; and (c) does not make any warranties or representations about the contents, products or services offered on such App or the security of any information you provide to them
MOBILE ADVERTISING IDENTIFIERS
What are they?
How do we use them?
Other things you should know:
CALIFORNIA / DELAWARE DO NOT TRACK DISCLOSURES
Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party web sites or online services (e.g., browsers do not track signals). Currently, Messej do not monitor or take any action with respect to these signals or other mechanisms.
By creating an account, you consent to receive commercial emails from us. This includes newsletters and offers. Users from certain countries may have the ability to opt out or opt in at the time of account creation. All users may decline to receive commercial messages in their account settings. Please note that any opt-out request may take several days to process and you will continue to receive transactional emails from us (e.g., emails confirming transactions and/or providing information about your account).
We are committed to maintaining the security of your personal data and have measures in place to protect against the loss, misuse, and alteration of the data under our control. We employ modern and secure techniques to protect our systems from intrusion by unauthorized individuals, and we regularly upgrade our security as better methods become available.
Our data centers and those of our partners utilize modern physical security measures to prevent unauthorized access to the facility. In addition, all personal data is stored in a secure location behind firewalls and other sophisticated security systems with limited (need-to-know) administrative access.
All our employees who have access to, or are associated with, the processing of personal data are contractually obligated to respect the confidentiality of your data and abide by the privacy standards we have established. Please be aware that no security measures are perfect or impenetrable. Therefore, although we use industry standard practices to protect your privacy, we cannot (and do not) guarantee the absolute security of personal data.
The App may offer chat rooms, Chatbots, forums, message boards, or news groups to users. It is important to remember that any information disclosed in these areas becomes public information. Accordingly, as with any public forum, you should exercise extreme caution when deciding whether to disclose your personal information.
GDPR STATEMENT FOR (EEA USERS)
This applies only to natural persons residing in the European economic area (for the purpose of this section only, "you" or "your" shall be limited accordingly). It is Messej's policy to comply with the EU'S general data protection regulation (GDPR). In accordance with the GDPR, we may transfer your personal information from your home country to the United States (or other countries) based upon the following legal frameworks:
We enable exercise of these rights primarily through our services (which we reserve the right to modify). We also fulfil our obligations in response to direct requests. We will endeavor to process requests within one month. Please note that we may not be able to comply with requests to the extent that they would cause us to violate any law or infringe any other person's rights. We reserve the right to request appropriate identification. We will process requests free of charge unless they would impose an unreasonable cost on us.
If you have a request, complaint or inquiry, please contact our data protection officer at the address listed below. We are committed to working with you to obtain a fair resolution of any issue. You also have the right to file a complaint with the supervisory data protection authority of your jurisdiction.
GDPR Data Privacy User Rights
If you are an EU resident and Messej is processing, and/or transmitting your personal data, then you - as an “EU data subject” – benefit from the following rights and privileges under the General Data Protection Regulation (GDPR):
Right to Object: You have the Right to Object, on grounds relating to your particular situation, at any time to processing of your personal data based on a legitimate ground point (e) or (f) of Article 6(1), including profiling based on those provisions. In this case, we can no longer process your personal data unless we show that there is a compelling legitimate ground for the processing which override your interests, rights and freedoms or for our establishment, exercise or defense of legal claims.
YOUR RIGHT TO WITHDRAW CONSENT
Where the processing of your personal information by us is based on consent, you have the right to withdraw that consent without detriment at any time by contacting us firstname.lastname@example.org. You can also change your marketing preferences
You can also exercise the rights listed above at any time by contacting us at email@example.com.
If your request or concern is not satisfactorily resolved by us, you may contact our data protection officer, his email is firstname.lastname@example.org.
He can provide further information about your rights and our obligations in relation to your personal data, as well as deal with any complaints that you have about our processing of your personal data.
OPTING OUT OF MESSAGES FROM US
To opt-out of any future promotional messages from us, you should unsubscribe in the body of the promotional message that was sent to you (found at the bottom of the email) or send an unsubscribe request to us at email@example.com. We will process your request within a reasonable time after receipt.
OPTING OUT OF SHARING WITH THIRD PARTIES FOR MARKETING
If you do not want your Personal Information or Personal Data shared with any third party who may use such information for direct marketing purposes, then you may opt-out of such disclosures by sending an email to firstname.lastname@example.org. Please note that if you opt out in this manner, certain aspects of the App and platform may no longer be available to you. We will process your request within a reasonable time after receipt.
OPTING OUT OF INTEREST BASED ADVERTISING
CALIFORNIA RESIDENTS CONSUMER ACT CCPA
California residents are entitled to ask us for a notice identifying the categories of Personal
Information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to:email@example.com.
If you are a resident of the European Economic Area, please see the section below headed “Additional Information for users in the European Economic Area” for further information about your privacy rights.
CALIFORNIA RESIDENT RIGHTS (CCPA)
If you are a California resident who has provided us with your Personal Information during the creation of or during the course of establishing a relationship that is primarily for personal, family, or household purposes, you may, once per calendar year, request information regarding our disclosure of certain categories of your Personal Information. Specifically, pursuant to California Civil Code 1798.83 (the “Shine the Light” law), we will provide you a list of the categories of Personal Information disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. You must submit your request to us either by our e-mail address
PRIVACY COMPLAINTS PROCEDURE
Where you believe that we have not complied with our obligations under this Privacy Notice, or the applicable law, you may have the right to make a complaint to a relevant Data Protection Authority or through the courts. Although not required, we would encourage you to let us know about any complaint you might have and Messej will respond in line with our complaints procedure – our contact details are set out in the contact us section below.
We want to deal with your concerns fairly, effectively and promptly. However, some complaints are more complex than others and may take some time to investigate.
In order to assist in the speedy resolution of any complaint you may have, it’s important that we understand your complaint fully. Sometimes this means we may ask you to address your concerns to us in writing. This can be either by email or post to the addresses. We have established internal procedures for investigating any complaint, which may also involve experienced members of staff from Messej Companies considering or investigating the complaint. Where appropriate, the complaint will be dealt with by someone who was not directly involved in the matter which is the subject of your complaint. The member of staff will either have authority to settle your complaint or will have ready access to someone who has the authority. Our response will fully address the subject matter of your complaint and, if appropriate, will offer redress. If you phone us during our investigation and the member of staff handling your complaint is not available, then another member of our team will try to assist you.
Unless applicable data protection laws require responses within shorter timescales, we will try to resolve any privacy complaints you have within 15 business days of receiving your complaint and in exceptional circumstances, within 35 business days (and we will let you know if this is the case).
As noted above, if you are not satisfied with our reply/outcome, or otherwise with the handling of the complaint, you may have the right to lodge a claim before a relevant Data Protection Authority or the courts.
SECURITY AND PERSONAL INFORMATION
The Site uses its best endeavors to store all Personal Information on servers with restricted access, and all electronic storage and transmission of Personal Information are secured with appropriate security technologies. Not to withstand the foregoing, the app cannot guarantee that such precautions would render the Site and its servers immune to security breaches.