This Privacy Policy discloses the privacy practices of Sameri Limited (the “Company” or “Tunshey”) and the possible uses of the information that we gather via our mobile application, and via other submissions by you to the Company. By using the mobile application, you consent to the terms of this Privacy Policy.
If you do not agree to the terms and conditions of this Privacy Policy, including having your personally identifiable information ("Personal Information" as defined below) used in any of the ways described in this Privacy Policy, you may not be able to use the mobile application. Tunshey may update this Privacy Policy from time-to-time in our sole discretion. It is your responsibility to review the Privacy Policy for any changes each time that you use the mobile application and you are bound by such changes. Your use of the mobile application following us posting a new privacy policy on our mobile application signifies that you agree to and accept the Privacy Policy as modified. This Privacy Policy is part of our Terms of Use, and all other terms of using our mobile application.
Information Collected
The company collects information on our users in various ways, such as, by your voluntary submissions, participation in services provided via the mobile application and Services, from third parties with your consent, and through cookie and other tracking technology. Tunshey collects the following information:
Personal Information
"Personal Information" refers to information that tells us specifically who you are, such as your name, phone number, email, mailing address, and possibly information relating to certain support or customer service issues. In many cases, we need this information to provide to you many of the services that you may have requested.
Session Data/Visit Recording
By using the Tunshey mobile application, you are agreeing that all your actions taken while accessing the mobile application may be recorded by Tunshey and provided to third parties and partners. These actions may include but are not limited to filling out forms, accepting terms and conditions and providing consent to be contacted.
Phone Numbers
By providing a telephone number to us, you expressly consent, and authorize us or a third party on our behalf, to deliver autodialed or prerecorded telemarketing calls and/or text messages to the number you provide. You are not required to consent to these calls as a condition to assessing the mobile application, but withholding your consent may prevent
us from providing certain services to you. This consent encompasses all future autodialed or
prerecorded telemarketing calls and text messages from us or a third party placing these calls on our behalf. You may revoke consent to receive text messages at any time by contacting Tunshey, including by texting STOP.
Submission of Reviews, Ratings and Comments
We collect information that you voluntarily provide as part of our mobile application, including messages, posts, comments, responses, reviews, and ratings you submit through the mobile application, ("User Generated Content"). Tunshey may in our sole discretion share your User Generated Content with others such as your business reviews. If you do not want certain information shared with others, you should not submit User Generated Content, or should not submit User Generated Content that contains information or Personal Information you do not want shared in this manner. Once You have submitted User Generated Content, we reserve the right to publish it in any medium to others.
Aggregate Information
We may collect general, non-personal, statistical information about the use of the mobile application, such as how many visitors visit a specific page on the mobile application, how long they stay on that page, and which hyperlinks, if any, they click on. This information represents a generic overview of our users, including their collective viewing habits, and allows us and other third parties to modify information, promotions, offers and/or discounts on products and services based on user traffic and behavior. We collect this information through the use of technologies such as 'cookies' and web beacons, which are discussed in greater detail below. We collect this information in order to help enhance the mobile application to make for a better visitor experience.
Third Party Information
We may supplement information you provide to us with information from other sources, such as information to validate or update your address, payment card or other demographic and lifestyle information. We use this information to help us maintain the accuracy of the information we collect, to enable us to fulfill our products and services, to target our communications so that we can inform you of products, services and offers that may be of interest, and for internal business analysis or other business purposes consistent with our mission.
Cookies or Software Development Kits
Tunshey may automatically collect non-personally identifiable information and data through the use of cookies or software development kits. Cookies are small text files that recognizes repeat users, facilitate the user's ongoing access to the website and facilitate the use of the website. Software development kits also allow a mobile application to track usage behavior and compile usage information that will allow for the improvement of content and target advertising. You may also get cookies from our advertisers or other third parties with links on the mobile application as described below. We do not directly control these cookies or software development kits. The use of advertising cookies sent by third party ad servers is standard in the Internet industry. We may use the services of third parties to collect and use anonymous information about your usage and interactions with our mobile application through the use of technologies such as cookies to personalize advertisements for goods and services.
Other tracking technologies
Our mobile application use automatic data collection technologies including first- and third-party Cookies, log files, Web Beacons, Pixels, dynamic tags, and other technical means. We may use these technologies to collect information about your online activities over time and across third-party websites or other online services in order to deliver content and advertising tailored to your interests, both on our mobile application and on third-party applications (including but not limited to search engines and social media applications) as well as through other electronic communications. This practice is commonly known as Online Behavioral Advertising. The third-parties who provide us with third-party Cookies, Web Beacons, Pixels, dynamic tags, and other tracking technologies, may use these technologies to collect information about you when you use our mobile application in order to provide you with advertising based on your use of the app and to track performance of their advertising. Third-parties may have the ability to link the information they collect
about you when you use the mobile application with other information they collect about you elsewhere on the Internet, including but not limited to your PII or information about the mobile device you are using. Third-parties may also collect information about your online or application activities over time and across different websites, applications, and other online services and may use this information to provide you with Online Behavioral Advertising or other targeted content.
Do Not Track Disclosures
Tunshey does not have a mechanism in place for responding to “do not track” signals or other similar mechanisms used to limit collection of information for use in Online Behavioral Advertising to request correction or deletion of any PII that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect, or if we have a lawful basis for continuing to process such information. If you withdraw a registration or cancel a subscription or delete the mobile application, we may retain your PII in our records and we may continue to use and disclose that data in a manner consistent with this Policy, unless you request deletion of it.
Use of Information
The information the Company collects is used in a variety of ways, including:
· for internal review;
· to improve the mobile application;
· to optimize third-party offers of products and or services;
· to verify the legitimacy of reviews and ratings;
· to notify you about updates to the mobile application;
· to let you know about products, services, and promotions that you may be interested in;
· to get reviews and ratings;
· for our marketing purposes and the marketing of discounts offered through our mobile
application by service providers;
· to fulfill and provide products and services, including personalized or enhanced services,
requested by you; and internal business analysis or other business purposes consistent with our mission;
and to carry out other purposes that are disclosed to you and to which you consent.
Disclosures and Transfer of Information. We do not disclose Personal Information to third parties, except when one or more of the following conditions is true:
· We have your permission to make the disclosure;
· The disclosure is necessary for the purpose for which the personal information was obtained;
· The disclosure is to the service provider from whom you purchased services through Tunshey’s platform;
· The disclosure is to financial service providers in order to fulfill and carry out the purchase and provision of goods and services requested by you;
· The disclosure is permitted by relevant law;
· The Personal Information to be disclosed is otherwise publicly available in accordance with the applicable law;
· The disclosure is reasonably related to the sale or other disposition of all or part of our business or assets;
· The disclosure is for our own marketing purposes (including, without limitation, for the
Company to market services to you on third-party social media platforms, or with your authorization, for the marketing purposes of third parties;
· The disclosure is combined with information collected from other companies and used to
improve and personalize services, content, and advertising from us or third parties;
· The party to whom the disclosure is made controls, is controlled by, or is under common control with the Company;
· The disclosure is in our sole discretion necessary for the establishment or maintenance of legal claims or legal compliance, to satisfy any law, regulation, subpoena or government request, or in connection with litigation;
· The disclosure is in our sole discretion about users who we believe are engaged in illegal
activities or are otherwise in violation of our Terms of Use, even without a subpoena, warrant or court order; or
The disclosure is to outside businesses to perform certain services for us, such as maintaining our mobile application, mailing lists, processing orders and delivering products and services, sending postal mail, processing claims for lost or stolen certificates, providing marketing assistance, confirming your identity for review integrity, and data analysis ("Administrative Service Providers"), including Administrative Service Providers outside the country or jurisdiction in which you reside.
Prior to sharing of your Personal Information with others, agreements are made between Tunshey and such outside parties to whom we are transferring data to provide for the allowable use and security of the transferred information in accordance with this Privacy Policy and applicable law. If the Company becomes aware that any such outside party is improperly using or disclosing Personal Information, it will notify that outside party and request that it take reasonable steps to cease such use or disclosure.
We may provide certain Personal Information as a service to others for their marketing purposes.
We may also disclose your name and address to service providers when you submit User Generated Content relating to those service providers. If you properly notify us that you no longer want us to share your Personal Information, we will cease sharing your Personal Information. However, except as otherwise stated in this Privacy Policy, we do not directly control the third parties to which we share such Personal Information and you will need to further notify such third parties directly if you would like them to cease use of your Personal Information. We may also disclose aggregate visitor data in order to describe the use of the mobile application to our existing or potential business partners or other third parties, or in response to a government request. We may also share aggregated demographic and preference data with third parties to enable the provision of targeted information, promotions, offers and/or discounts on products and services.
Choice: Accessing Your Information and Opt-in/Opt-out Requests
When you access our mobile application, you may be asked whether you will allow us to access your location while you are not using the app and/or whether you would like to receive notifications on your mobile device. If you click “allow” but change your mind at any time in the future and no longer wish to allow us to access your location and/or to receive notifications, you will be able to opt out by updating the privacy settings on your mobile device.
To help you review, edit, and control how we use much of the information we collect about you, click on accounts on the mobile application. You can also update certain information and unsubscribe from receiving specific types of email messages and telephone calls, including autodialed or prerecorded telemarketing calls placed by us or a third party on our behalf. You cannot, however, unsubscribe from receiving certain emails, such as account status and billing related emails, unless you close your account and fulfill any existing contractual obligations. You can also ask us whether we are keeping information about you; ask how your information is being used; ask us to update or correct your information; or opt-out of our collection and use of certain information by sending an email to tunsheyapp@gmail.com specifying the nature and scope of your request. We may require proof of your identity before we provide you with the requested information. We allow you to challenge the data that we hold about you and, where appropriate, you may have certain data erased, rectified, amended, or completed. Approved requests will be processed within ten (10) working days of the date on which we receive the request.
Data Security, Integrity and Access
Tunshey has implemented reasonable security measures designed to protect the information collected via our mobile application from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Access to data and technology relating to user information is password protected and limited to authorized personnel and those vendors that require access to the information in order to furnish services to our Company. In addition, the Company uses industry standard technology to keep users’ information secure while residing on Tunshey’s server(s).
However, despite these measures, our IT systems could be compromised by parties seeking
unauthorized access to our data or users’ data, by a technological malfunction or by an error by an employee, officer, vendor or contractor. In addition, the transmission of information via the Internet or mobile data networks could be intercepted by third-parties. As a result, our efforts to protect our data and users’ data from unauthorized access may be unsuccessful and we cannot assure you that the security measures we have adopted will provide absolute certainty. By using, accessing or registering on our mobile application, you agree that the Company is not responsible or liable for any loss or damage of any sort arising from or relating to any breach of our security, circumvention of any privacy settings or security measures, or interception of your transmissions (see also Terms of Use). Any transmission by you is at your own risk. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to our mobile application or certain functions within our app, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Credit Card Information
We may share credit card information with trusted third parties in order to bill you for our service. We use third parties for secure credit card transaction processing, and we send billing information to those third parties to process your orders and payments or to validate your credit card information on file. Credit card information is encrypted during transmission and whenever stored within our systems or with our vendors. In addition to utilizing encryption that meets the government approved certifications, such as FIPS 140-2, we take care to store only the amount of information required to bill you for services.
Our credit card processing vendors use security measures to protect your information both during the transaction and after it is complete. Credit card processing vendors are certified as compliant with multiple industry-standard compliance frameworks.
Children’s Information
Our Company does not intend the mobile application to be used by individuals under the age of majority within the jurisdiction within which they reside without the supervision of a parent or guardian of majority age. Tunshey relies upon such parents or guardians to determine if the mobile application is appropriate for the viewing, access, or participation by such individuals under the age of majority. If an individual under the age of majority uses the mobile application, such individual may only use the application under the supervision of a parent or guardian of majority age. We do not seek or knowingly collect any Personal Information about children under 13 years of age. If we become aware that we have unknowingly collected Personal Information from a child under the age of 13, we will make commercially reasonable efforts to delete such information from our database. If you are the parent or guardian of a minor child who has provided us with Personal Information, you may contact us on info@sameriltd.org to request it be deleted.
International Users
The Company and the mobile application is based in the United Kingdom and, regardless of where you access the mobile application, the information collected as part of that use will be transferred to and maintained on servers located in the United Kingdom. Any information we obtain about you will be stored in accordance with U.K. privacy laws, regulations, and standards, which may not be equivalent to the laws in your country of residence. By using the mobile application, you consent to this collection, transfer, storage, and processing of information to and in the United Kingdom in accordance with the foregoing. If you are an International User, the GDPR (and related International regulations) requires Tunshey to inform you of its use of automated decision-making tools. Our Company uses various tools, such as Google Analytics®
You may contact us via email on info@sameriltd.org with any questions, or to request a list of third parties to whom we may disclose information for marketing purposes and the categories of information we may disclose.
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