This Privacy Policy (the "Policy") describes how NULLZEC Global Inc. ("Slidinn", "we", "us" or "our") collects, uses, discloses, retains and otherwise processes personal information in connection with the Slidinn website, the Slidinn mobile applications for iOS and Android, and any related features, content and services (collectively, the "Services"). By accessing or using the Services, you acknowledge that you have read and understood this Policy. Capitalised terms not defined herein have the meanings given in our Terms of Service.
1. Scope and controller
This Policy applies to personal information processed through the Services. NULLZEC Global Inc. is the controller of such information, save where a third-party platform, identity provider or payment provider acts as an independent controller under its own terms, as described in Section 5.
2. Personal information we collect
- Account information. When you register, we receive from the identity provider you select (Google or Apple) a unique account identifier, your email address and, where made available, your name and, in the case of Google, your profile photograph. You subsequently provide a username, full name, gender, age, country of residence and, at your option, a telephone number. We may propose a username derived from the account you used to register; you may amend it before it is saved.
- Profile photograph. Where your Google account includes a profile photograph, a copy is retained with your account and displayed as your Slidinn profile picture. You may remove it at any time from Your details, whereupon it is deleted and is not obtained again.
- Connected messaging account. When you authorise the connection of an Instagram account, we receive the account identifier and username, a reference to the account's profile picture, and an authorisation credential issued by the platform, which is stored in encrypted form. Message content is accessed in real time solely to display it to you and to perform the functions you request, and is not retained (see Section 4). Where you elect to connect an account by providing its login credentials, those credentials are transmitted over an encrypted connection, used solely to establish the session and are not retained; if you elect to remain connected, the resulting session is retained for up to thirty (30) days.
- Content you submit. Text you enter or images you select for the purpose of obtaining reply suggestions, and any feedback you send to us together with the related contact preference and the platform from which it was sent.
- Device, connection and security information. The network (IP) address and the description your browser or device transmits of itself (its "user agent") at registration and at your most recent sign-in; records of security-relevant events (such as sign-ins, connections, plan changes and deletions) containing the time, the nature of the event, its outcome and a pseudonymised form of the network address; and technical records of requests and errors that exclude message content, credentials and contact details.
- Subscription information. A pseudonymous customer identifier and the subscription status reported by the relevant store or payment provider, including the plan, its period, its renewal status, the date on which the current period ends and whether the transaction was a test transaction. We do not receive or store payment card details.
- Notifications. If you enable notifications, we retain the push token of your device or the push address of your browser for as long as notifications remain enabled. You may turn them off at any time in Settings or in the settings of your device or browser.
- Information stored on your device. Certain preferences (such as tone, display and accessibility settings) and, in the mobile applications, brief coaching notes concerning your use of the Services are stored locally on your device, in encrypted form where applicable, and are removed when you sign out.
3. Purposes and legal bases of processing
We process personal information for the following purposes: (a) to provide, operate and maintain the Services and your account, in performance of our contract with you; (b) to generate reply suggestions and related features at your request, in performance of that contract; (c) to administer subscriptions, billing, taxation and customer support, in performance of that contract and to comply with legal obligations; (d) to secure the Services, to detect, prevent and investigate fraud, abuse, unauthorised access and the sharing or compromise of accounts, and to enforce our Terms, on the basis of our legitimate interests in the integrity of the Services; (e) to send notifications you have enabled, on the basis of your consent, which you may withdraw at any time; and (f) to comply with applicable law and lawful requests from public authorities.
4. Message content
Conversations from a connected account are retrieved at the time you open them and are presented to you; they are not stored by us. Where you request reply suggestions, the content of the relevant conversation (or the text or image you submit) and your selected preferences are transmitted to an artificial-intelligence service provider solely to generate those suggestions, and are not retained by us thereafter. Suggestions are not sent from your account unless you review them and expressly instruct us to send them. Where a connected account is linked through a service operated on our infrastructure for accounts that cannot use the platform's official integration, a copy of recent conversations may be held on that infrastructure for the purpose of providing the Services and is deleted upon disconnection or deletion of your account.
5. Disclosure of personal information
We disclose personal information only as necessary for the purposes described in this Policy, to the following categories of recipients:
- Identity providers (Google and Apple), which authenticate you under their own privacy policies.
- Meta Platforms (Instagram), with respect to the account you choose to connect, under Instagram's privacy policy.
- Artificial-intelligence service providers, which process submitted content on our behalf solely to generate suggestions.
- App stores, payment processors and subscription-management providers, which process payments and subscription records, in some cases as independent controllers under their own terms.
- Notification delivery services, including those operated by Apple, Google and browser vendors, which deliver notifications you have enabled.
- Hosting, infrastructure, network and security providers, which operate the systems on which the Services run and through which data is transmitted.
- Authorities and other parties where disclosure is required by law, regulation or legal process, or is necessary to protect the rights, property or safety of Slidinn, our users or others; and a successor entity in connection with a merger, acquisition or transfer of assets, subject to this Policy.
We do not sell personal information, we do not share it for cross-context behavioural advertising, and we do not use it to train artificial-intelligence models of our own. Our service providers are bound by contractual obligations of confidentiality and are permitted to process personal information only on our instructions.
6. Retention
We retain personal information only for as long as necessary for the purposes for which it was collected. Account information, the profile photograph, connection details, device and connection information associated with your account, and feedback are retained until you delete your account (or, for the photograph, until you remove it). Sign-in sessions expire after thirty (30) days of inactivity and in any event no later than one hundred and eighty (180) days after sign-in. Security event records are deleted after one hundred and eighty (180) days. Subscription records may be retained for the period required by applicable accounting, tax and consumer-protection laws. Information may be retained for longer where required to comply with a legal obligation or to establish, exercise or defend legal claims.
7. Your rights and choices
- Access, rectification, erasure, restriction, objection and portability. Subject to applicable law, you may request access to, correction of, deletion of, restriction of the processing of, or a portable copy of your personal information, and you may object to processing based on our legitimate interests.
- Account deletion. You may delete your account at any time from Settings or on the Delete my data page. Deletion takes effect immediately, ends all sign-in sessions, removes the stored connection and provides a confirmation code.
- Disconnection. You may disconnect a connected account in Settings, or revoke our access through the connected platform's own settings, upon which the stored credential is deleted.
- Consent. Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.
- Residents of certain jurisdictions. Residents of the European Economic Area, the United Kingdom, California and other jurisdictions may have additional rights under the GDPR, the UK GDPR, the CCPA/CPRA or other applicable laws, including the right to lodge a complaint with a supervisory authority. We will not discriminate against you for exercising your rights.
To exercise any right, contact us at the contact address listed with this app's developer. We may need to verify your identity before acting on a request.
8. Security
We implement administrative, technical and organisational measures appropriate to the risk, including encryption of data in transit and of stored credentials, access controls, monitoring and rate limiting, designed to protect personal information against unauthorised access, loss, misuse or alteration. No method of transmission or storage is wholly secure, and we cannot guarantee absolute security. You are responsible for maintaining the security of the identity-provider account you use to sign in.
9. International transfers
Personal information may be processed in countries other than the one in which you reside, which may have data-protection laws different from those of your country. Where required, we implement appropriate safeguards, such as standard contractual clauses, for such transfers.
10. Children
The Services are not directed to, and may not be used by, persons under thirteen (13) years of age or the minimum age required in their country, whichever is higher. We do not knowingly collect personal information from such persons. If you believe a child has provided personal information to us, please contact us and we will delete it.
11. Third parties in your conversations
Conversations may contain personal information of the persons with whom you communicate. Such information is processed only to the extent necessary to provide the Services to you, as described in Section 4. You are responsible for using the Services lawfully and respectfully with regard to such persons.
12. Changes to this Policy
We may amend this Policy from time to time. Material changes will be indicated by updating the date above and, where appropriate, by notice within the Services. Your continued use of the Services after the effective date of an amendment constitutes acknowledgement of the amended Policy.
13. Contact
Enquiries and requests concerning this Policy may be directed to the contact address listed with this app's developer.