Privacy Policy

1.0 Who we are

Roka App Private Limited is the legal entity behind the Roka Dating and Matchmaking application. We are the sole proprietors of all intellectual property rights associated with the app. Our team is committed to providing a secure and reliable platform for connecting individuals, ensuring that your privacy and data are safeguarded under the highest standards of legal and ethical compliance. As the creators and maintainers of Roka, we are dedicated to continuously enhancing user experience while respecting the trust you place in us and our product.

2.0 Our commitment to you

1. We design all of our products and services with your privacy in mind. We involve experts from various fields, including legal, security, engineering, product design and others to make sure that our decisions are taken with the utmost respect for your privacy.
2. As the user of many same online services, we understand that insufficient information coupled with complicated language creates issues for the user to understand Privacy Policies. Thus, for the same reason, we are attempting to write our Privacy Policies and other related documents in a simple and plain language.
3. We have teams dedicated to keeping your data safe and secure. We constantly update our security practices and invest in our security efforts to enhance the safety of your information.

3.0 Information we collect

1. Registration information
   1. When you download the Site and create an account (“Account”), we may collect certain information (“Registration Information”) about you, such as:
      • Name;
      • Username;
      • Email address;
      • Mobile number;
      • Job title;
      • Billing address;
      • Debit/credit care number, UPI ID;
      • Gender identity;
      • Date of birth;
      • Sexual preference;
      • Photographs;
      • Location and;
      • Login information for social media accounts that you connect your Roka account (this could include, for example, your Facebook and Instagram accounts).
   2. We also collect information about your use of our services such as access logs, as well as information from third parties, like when you access our services through your third-party account or when you upload information from your third-party account to complete your profile. If you want additional information, we go into more detail below.
2. Information you give us
   1. You choose to give us certain information when using our services. This includes:
      • When you create an account, you provide us with at least your phone number and email address, as well as some basic details necessary for the service to work, such as your gender, date of birth, and who you’d like to connect with.
      • When you complete your profile, you have the option to share your sexual orientation with us. Where you provide such elements to us, you consent to us using it for the purposes identified and as laid out in this Privacy Policy. You can also share additional information with us, such as details on your bio and your interests, as well as content such as photos and videos. To add certain content, like pictures or videos, you may allow us to access your camera or photo album.
      • When you subscribe to a paid service or make a purchase directly from us (rather than through a platform such as iOS or Android), you provide us with information related to the purchases you make and our payment processors with information such as your debit or credit card number or other financial information.
      • When you participate in surveys, focus groups or market studies, you give us your insights into our products and services, responses to our questions and testimonials.
      • When you choose to participate in our promotions, events or contests, we collect the information that you use to register or enter.
      • If you contact our customer care team, we collect the information you give us during the interaction.
      • If you share with us information about other people (for example, if you use contact details of a friend for a given feature), we process this information on your behalf in order to complete your request. The contacts imported into the app are stored on our server, and we utilize them for profile sharing and setting up group chats.
      • Of course, we also process your chats with other members as well as the content you publish to operate and secure the services, and to keep our community safe.
3. Information we receive from others
   1. In addition to the information, you may provide us directly, we receive information about you from others, including:
      • Members: Members may provide information about you as they use our services, for instance as they interact with you or if they submit a report involving you.
      • Social Media: You may decide to share information with us through your social media account, for instance if you decide to create and log into your account via your social media or other account or to upload onto our services information such as photos from one of your social media accounts.
      • Other Partners: We may receive information about you from our partners where our ads are published on a partner’s service (in which case they may pass along details on a campaign’s success). Where legally allowed, we can also receive information about suspected or convicted bad actors from third parties as part of our efforts to ensure our members’ safety and security.
4. Information generated or automatically collected when you use our services
   1. When you use our services, this generates technical data about which features you’ve used, how you’ve used them and the devices you use to access our services. See below for more details.
      • Usage Information: Using the services generates data about your activity on our services, for instance how you use them (e.g., when you logged in, features you’ve been using, actions taken, information shown to you, referring webpages address and ads that you interacted with) and your interactions with other members (e.g., members you connect and interact with, and when you matched and exchanged messages with them).
      • Device information: We collect information from and about the device(s) you use to access our services, including hardware and software information such as IP address, device ID and type, apps settings and characteristics, app crashes, advertising IDs (which are randomly generated numbers that you can reset by going into your device’ settings and, in some cases, disable entirely), and identifiers associated with cookies or other technologies that may uniquely identify a device or browser.
      • Information collected by cookies and similar technologies: We use and may allow others to use cookies and similar technologies (e.g., web beacons, pixels, SDKs) to recognize you and/or your device(s). You may read our *Cookie Policy* for more information on why we use them and how you can better control their use.
        Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) have a “Do Not Track” (“DNT”) feature that tells a website that a user does not want to have his or her online activity tracked. If a website that responds to a DNT signal receives a DNT signal, the browser can block that website from collecting certain information about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many businesses, including ours, do not currently respond to DNT signals.
5. Other information with your consent
   1. Precise Geo-location data: If you give us your consent, we can collect your precise Geo-location (latitude and longitude) from your device. The collection of your Geo-location may occur in the background even when you aren’t using the services if the permission you gave us expressly permits such collection. If you decline permission for us to collect your precise Geo-location, we will not collect it, and our services that rely on precise Geo-location may not be available to you.
   2. Photo/Video Verification data: If you choose to participate in our Photo/Video Verification feature, we collect your face geometry data, which may be considered biometric data in some jurisdictions, to verify that you’re the real you. We request users to upload their photos and videos for the purpose of video verification.

4.0 How we use your information

1. The main reason we use your information is to deliver and improve our services. Additionally, we use your information to help keep you and our community 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 for which we use your information, together with practical examples.
2. 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
   • Communicate with you about our services
   • Manage your orders, payments, returns and exchanges.
3. To help you connect with other users
   • Recommend you to other members and recommend other members to you
   • Show members’ profiles to one another
   • Enable members to search for and connect with members
4. To provide new Roka services to you
   • Register you and display your profile on new Roka features and apps
   • Administer your account on these new features and apps
5. To provide offers and operate advertising and marketing campaigns
   • Perform and measure the effectiveness of advertising campaigns on our services and marketing our services off our platform.
   • Communicate with you about products or services that we believe may interest you.
6. To improve our services and develop new ones
   • Administer focus groups, market studies and surveys.
   • Review interactions with customer care teams to improve our quality of service.
   • Understand how members typically use the services to improve them (for instance, we may decide to change the look and feel or even substantially modify a given feature based on how members react to it).
   • Develop new features and services (for example, we may decide to build a new interests-based feature further to requests received from members).
7. To prevent, detect and fight fraud and other illegal or unauthorized activities
   • Find and address on-going, suspected or alleged violations of our Terms of Use, notably through the review of reports and interactions between members
   • Better understand and design countermeasures against violations of our Terms of Use
   • Retain data related to violations of our Terms of Use to address the violation and prevent against recurrences
   • Enforce or exercise our rights, for example our rights set out in our Terms of Use
   • Communicate to individuals who submit a report, including what we’ve done as a result of their submission
8. To ensure legal compliance
   • Comply with legal requirements
   • Assist law enforcement

5.0 Sharing your information

1. Since our goal is to help you make meaningful connections, the main sharing of members’ information is, of course, with other members. We also share some types of members’ information with service providers and partners who assist us in operating the services and in some cases, legal authorities. Read on for more details about how your information is shared with others.
2. With other members
   1. You share information with other members when you voluntarily disclose information on the service (including your public profile). Please be careful with your information and make sure that the content you share is stuff that you’re comfortable with being visible.
   2. If you choose to limit the audience for all or part of your profile or for certain content or information about you, then it will be visible according to your settings.
   3. If someone submits a report involving you (such as a claim you violated our Terms of Use), we may communicate to the reporter regarding the actions, if any, we took as a result of their report.
3. Sharing functionality
   1. You may choose to share other members’ profiles and they may share yours with people outside of our services, using the sharing functionality.
4. For corporate transactions
   1. We may transfer your information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control.
5. With law enforcement / when required by law
   1. We may disclose your information if reasonably necessary:
      1. to comply with a legal process, such as a court order, summon/subpoena or search warrant, government / law enforcement investigation or other legal requirements;
      2. to assist in the prevention or detection of crime (subject in each case to applicable law); or
      3. to protect the safety of any person.
6. To enforce legal rights
   1. We may also share information:
      1. If disclosure would mitigate our liability in an actual or threatened lawsuit;
      2. As necessary to protect our legal rights and legal rights of our members, business partners or other interested parties;
      3. To enforce our agreements with you; and
      4. To investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.
7. With your consent or at your request
   1. We may ask for your consent to share your information with third parties. In any such case, we will make it clear why we want to share the information.
8. We may use and share non-personal information (meaning information that, by itself, does not identify who you are such as device information, general demographics, general behavioral data, location in de-identified form), as well as personal information in hashed, non-human readable form, under any of the above circumstances.

6.0 IF YOU ARE LOCATED IN THE UNITED KINGDOM, THIS SECTION APPLIES TO YOU:

1. The UK General Data Protection Regulation requires us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:
   1. Consent: We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.
   2. Performance of a Contract: We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
   3. Legitimate Interests: We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
      • Send users information about special offers and discounts on our products and services.
      • Develop and display personalised and relevant advertising content for our users
      • Analyse how our Services are used so we can improve them to engage and retain users
      • Support our marketing activities
      • Diagnose problems and/or prevent fraudulent activities
      • Understand how our users use our products and services so we can improve user experience
   4. Legal Obligations: We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
   5. Vital Interests: We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

7.0 Inviting friends

1. If you refer a friend to Roka, you will send an email message, Whatsapp message, SMS, Messenger message to the contact details you submitted to us. We won’t share these details with anyone else. By choosing to invite your friend to join Roka you confirm that your friend is happy to receive the invitation. You also hereby agree to indemnify and hold Roka harmless from all claims arising out of your messages to any person through Roka. You must and will not use our invite friends feature to send spam.

8.0 Protection of your data

1. We try our best to ensure that your Personal Data is protected and secure from unauthorized or unlawful access, alteration, disclosure, use or destruction. We encrypt our services using SSL, the data is accessible only through a secret password and digital signatures, and our employees only have access to your data on a need-to-know basis. Unfortunately, the transmission of information via the internet is not always completely secure. Although we take all reasonable measures, we cannot guarantee the security of the data you transmit to our Site; any transmission is at your own risk.

9.0 How long do we retain your personal data?

1. Your Personal Data is retained no longer than strictly necessary or as long as allowed by law, whichever is shorter. In the event that you have not logged in to your profile for one year, your Personal Data may be erased from our records. Of course, you can always contact our support team through your registered email address with a request to delete your data from our records.

10.0 Storage and transfer of your personal data

1. Your personal data may be hosted by our storage partners in servers located in countries other than your country of residence.
2. You can also view, edit or delete your Personal Data by logging in to your Roka account. To protect loss of data due to natural disasters and other such unforeseeable circumstances, we store your limited details as backup for a safety retention window of up to 10 years following account deletion. During this period, account information will be retained although the account will of course not be visible on Roka anymore.
3. When you delete your account, your personal data is deleted after this retention window. We only retain your email address and phone number in order to be able to contact you with regard to payment matters. For internal use, we may store generic, non-personal data regarding your activity as a user (number of people invited, number of logins, term of your subscription, payment method, etc).
4. Roka shall not knowingly collect data from minors. Should a Member lie about his/her date of birth, and particularly if he/she fraudulently claims to be over 18 years of age, the parents of the minor in question should inform Roka of this by sending an e-mail to help@rokadating.com, requesting the data to be deleted. Roka commits to deleting all data on the minor in question as soon as possible.
5. When registering, the Member expressly consents to his/her data being transmitted to Roka service providers and subcontractors outside of the Member’s country of residence, to let Roka run statistical studies, support users, and if need be, host data processed by the Application.
6. Roka guarantees that the transfers are made under conditions ensuring the confidentiality and security of the data and providing an adequate level of protection in compliance with regulations.

11.0 Rights and choices

1. We want you to be in control of your information, so we want to remind you of the following options and tools available to you:
   1. Access / Update tools in the service
      1. Tools and account settings can help you access, rectify or remove information that you provided to us and that’s associated with your account directly within the service. If you have any questions on those tools and settings, please contact our customer care team for help.
   2. Device permissions
      1. Mobile platforms can have permission systems for specific types of device data and notifications, such as phone contacts, pictures, location services, push notifications and advertising identifiers. You can change your settings on your device to either consent or oppose the collection or processing of the corresponding information or the display of the corresponding notifications. Of course, if you do that, certain services may lose functionality.
   3. Uninstall
      1. You can stop all information collection by an app by uninstalling it using the standard uninstall process for your device. Remember that uninstalling an app does NOT close your account. To close your account, please use the corresponding functionality on the service.
   4. Account closure
      1. You can close your account by using the corresponding functionality directly on the service.
2. We also want you to be aware of your privacy rights. Depending on where you live, you may have the right to:
   1. Access/know
      1. You may have the right to request a copy of the information we keep about you, and in certain circumstances to receive this in a portable format. You can exercise your right to access directly within the service by putting in a request.
   2. Delete/erase
      1. You may request that we delete the personal information we keep about you. You can exercise your right to delete by submitting a request.
   3. Correct/rectify/update
      1. You can correct most information you provided to us by editing your profile directly in the service. If you believe the information, we hold about you is inaccurate, you may contact us to rectify it.
   4. Object/restrict
      1. You may also have the right to object to or request that we restrict certain processing. To do so, please contact us.
      2. For your protection and the protection of all of our members, we may ask you to provide proof of identity before we can answer the above requests. Keep in mind, we may reject requests, including if we are unable to authenticate you, if the request is unlawful or invalid, or if it may infringe on trade secrets or intellectual property or the privacy or other rights of someone else. If you wish to receive information relating to another member, such as a copy of any messages you received from them through our service, the other member will have to contact us to provide their written consent before the information is released. We may also ask them to provide proof of identity before we can answer the request. Also, we may not be able to accommodate certain requests to object to or restrict the processing of personal information, notably where such requests would not allow us to provide our service to you anymore. For instance, we cannot provide our service if we do not have your date of birth and thus cannot ensure that you are 18 years of age or older.
      3. If you are a resident of India, if we deny your privacy request, you may be able to appeal by contacting us, and explicitly referencing “Privacy Request Appeal.” If you have concerns about the result of your appeal you may contact the adjudicating officer appointed by the Central/State government under the Information Technology Act, 2000.
      4. If you are a resident of USA, if we deny your privacy request, you may be able to appeal by contacting us, and explicitly referencing “Privacy Request Appeal.” If you have concerns about the result of your appeal you may contact the attorney general for your state.
      5. In certain countries, including in the United Kingdom, you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how we process your personal information. You can find information about your data protection regulator in the United Kingdom. The data protection authority you can lodge a complaint with may be that of your habitual residence, where you work or where an alleged infringement took place.

12.0 Privacy policy changes

1. We are constantly looking for new ways to improve Roka and we may unilaterally update this Privacy Policy from time to time. When there is a significant change in this Privacy Policy, you will see a pop up in the app which you will have to accept before you can continue to use Roka.

13.0 How to contact us

For any queries, feedback, or concerns regarding the Roka Dating and Matchmaking app, please do not hesitate to reach out to us. Our dedicated team is always available to assist you and values your input. Contact us directly at feedback@rokadating.com. We are committed to providing prompt and attentive support to ensure your experience with our app is as enjoyable and seamless as possible. Your communication is vital to us, and we look forward to hearing from you.