Azora Wellbeing (Azora)
Privacy Policy
UK Company Registration No. 13688639
Last modified: Sept 10, 2020
Respect for your privacy is coded into our DNA. Since we started Azora, we've aspired to build our services with a set of strong privacy principles in mind.
Our Privacy Policy ("Privacy Policy") helps explain our information (including message) practices, including the information we process to support our Services. For example, we talk about what information we collect and how this affects you. We also explain the steps we take to protect your privacy - like building Azora so delivered messages aren't stored and giving you control over who you communicate with on our Services.
This Privacy Policy applies to all of our Services unless specified otherwise.
Information We Collect
Azora must receive or collect some information to operate, provide, improve, understand, customize, support, and market our Services, including when you install, access, or use our Services. The types of information we receive and collect depend on how you use our Services.
Information You Provide
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Your Account Information. You provide your mobile phone number and basic information (including a profile name) to create an Azora account. You provide us, all in accordance with applicable laws, the phone numbers in your mobile address book on a regular basis, including those of both the users of our Services and your other contacts. You may provide us an email address. You may also add other information to your account, such as a profile picture and about information.
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Your Messages. We do not retain your messages in the ordinary course of providing our Services to you. Once your messages (including your chats, photos, videos, voice messages, files, and share location information) are delivered, they are deleted from our servers. Your messages are stored on your own device. If a message cannot be delivered immediately (for example, if you are offline), we may keep it on our servers for up to 30 days as we try to deliver it. If a message is still undelivered after 30 days, we delete it. To improve performance and deliver media messages more efficiently, such as when many people are sharing a popular photo or video, we may retain that content on our servers for a longer period of time. We also offer end-to-end encryption for our Services, which is on by default, when you and the people with whom you message use a version of our or any third part app. End-to-end encryption means that your messages are encrypted to protect against us and third parties from reading them.
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Your Connections. To help you organize how you communicate with others, we may help you identify your contacts who also use Azora, and you can create, join, or get added to groups and broadcast lists, and such groups and lists get associated with your account information.
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Customer Support. You may provide us with information related to your use of our Services, including copies of your messages, and how to contact you so we can provide you customer support. For example, you may send us an email with information relating to our app performance or other issues.
Automatically Collected Information
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Usage And Log Information. We collect information about your activity on our Services, like service-related, diagnostic, and performance information. This includes information about your activity (including how you use our Services, your Services settings, how you interact with others using our Services, and the time, frequency, and duration of your activities and interactions), log files, and diagnostic, crash, website, and performance logs and reports. This also includes information about when you registered to use our Services, the features you use like our messaging, calling, Status, or groups features, profile photo, about information, whether you are online, when you last used our Services (your "last seen"), and when you last updated your about information.
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Device And Connection Information. We collect device and connection-specific information when you install, access, or use our Services. This includes information like hardware model, operating system information, battery level, signal strength, app version, browser information, and mobile network, connection information including phone number, mobile operator or ISP, language and time zone, and IP, device operations information, and identifiers like device identifiers.
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Location Information. We collect device location information if you use our location features, like when you choose to share your location with your contacts, view locations nearby or those others have shared with you, and the like, and for diagnostics and troubleshooting purposes such as if you are having trouble with our app's location features. We use various technologies to determine location, including IP, GPS, Bluetooth signals, and information about nearby Wi-Fi access points, beacons, and cell towers.
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Cookies. We use cookies to operate and provide our Services, including to provide our Services that are web-based, improve your experiences, understand how our Services are being used, and customize our Services. For example, we use cookies to provide Azora for web and desktop and other web-based services. We may also use cookies to understand which of our FAQs are most popular and to show you relevant content related to our Services. Additionally, we may use cookies to remember your choices, like your language preferences, to provide a safer experience, and otherwise to customize our Services for you.
Third-Party Information
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Information Others Provide About You. We receive information about you from other users and businesses. For example, when other users or businesses you know use our Services, they may provide your phone number, name, and other information (like information from their mobile address book or in the case of businesses, additional information about you such as unique identifiers), just as you may provide theirs, or they may send you a message, send messages to groups to which you belong, or call you. We require each of these users and businesses to have lawful rights to collect, use, and share your information before providing any information to us.
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Businesses On Azora. Businesses you interact with using Azora provide us information about their interactions with you. A business on Azora may also use another company to assist it in storing, reading, and responding to your messages on behalf of and in support of that business. Please note that when businesses use third-party services, their own terms and privacy policies will govern your use of those services and their use of your information on those services.
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Third-Party Service Providers. We work with third-party service providers to help us operate, provide, improve, understand, customize, support, and market our Services. For example, we work with companies to distribute our services, provide our infrastructure, delivery, and other systems, supply location, map, and places information, process payments, help us understand how people use our Services, market our Services, help you connect with businesses using our Services, conduct surveys and research for us, and help with customer service. These companies may provide us information about you in certain circumstances; for example, app stores may provide us reports to help us diagnose and fix service issues.
How We Use Information
We use the information we have (subject to choices you make) to operate, provide, improve, understand, customize, support, and market our Services. Here's how:
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Our Services. We use the information we have to operate and provide our Services, including providing customer support, and improving, fixing, and customizing our Services. We understand how people use our Services and analyse and use the information we have to evaluate and improve our Services, research, develop, and test new services and features, and conduct troubleshooting activities. We also use your information to respond to you when you contact us.
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Safety And Security. We verify accounts and activity, and promote safety and security on and off our Services, such as by investigating suspicious activity or violations of our Terms, and to ensure our Services are being used legally.
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No Third-Party Banner Ads. We do not allow third-party banner ads on Azora. We have no intention to introduce them, but if we ever do, we will update this policy.
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Commercial Messaging. We will allow you and third parties, like businesses, to communicate with each other using Azora, such as through order, transaction, and appointment information, delivery and shipping notifications, product and service updates, and marketing. Messages you may receive containing marketing could include an offer for something that might interest you. We do not want you to have a spammy experience; as with all of your messages, you can manage these communications, and we will honor the choices you make.
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Measurement, Analytics, And Other Business Services. We help businesses who use Azora measure the effectiveness and distribution of their services and messages, and understand how people interact with them on our Services.
Information You And We Share
You share your information as you use and communicate through our Services, and we share your information to help us operate, provide, improve, understand, customize, support, and market our Services.
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Send Your Information To Those You Choose To Communicate With. You share your information (including messages) as you use and communicate through our Services.
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Account Information. Your phone number, profile information, about information, last seen information, and receipts may be available to anyone who uses our Services, although you can configure your Services settings to manage certain information available to other users and businesses with whom you communicate.
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Your Contacts And Others. Users and businesses with whom you communicate may store or reshare your information (including your phone number or messages) with others on and off our Services. You can use your Services settings and the block feature in our Services to manage the users of our Services with whom you communicate and certain information you share.
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Businesses On Azora. We help businesses who use Azora measure the effectiveness and distribution of their services and messages, and understand how people interact with them on our Services.
How The General Data Protection Regulation Applies To Our European Region Users
Our Legal Bases For Processing Information
We collect, use, and share the information we have as described above:
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as necessary to fulfil our Terms;
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consistent with your consent, which you can revoke at any time;
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as necessary to comply with our legal obligations;
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occasionally to protect your vital interests, or those of others;
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as necessary in the public interest; and
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as necessary for our (or others') legitimate interests, including our interests in providing an innovative, relevant, safe, and profitable service to our users and partners, unless those interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data.
How You Exercise Your Rights
Under the General Data Protection Regulation or other applicable local laws, you have the right to access, rectify, port, and erase your information, as well as the right to restrict and object to certain processing of your information. This includes the right to object to our processing of your information for direct marketing and the right to object to our processing of your information where we are performing a task in the public interest or pursuing our legitimate interests or those of a third party. You can access tools to rectify, update, and erase your information directly in-app as described in the Managing and Deleting Your Information section. If we process your information based on our legitimate interests or those of a third party, or in the public interest, you can object to this processing, and we will cease processing your information, unless the processing is based on compelling legitimate grounds or is needed for legal reasons. Where we use your information for direct marketing for our own Services, you can always object and opt out of future marketing messages by notifying or changing your privacy setting in any of our apps, mailshots or by email notification to admin@azorahub.com.
Managing And Deleting Your Information
We store information until it is no longer necessary to provide our services, or until your account is deleted, whichever comes first. This is a case-by-case determination that depends on things like the nature of the information, why it is collected and processed, and relevant legal or operational retention needs.
If you would like to manage, change, limit, or delete your information, we allow you to do that through the following tools:
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Services Settings. You can change your Services settings to manage certain information available to other users. You can manage your contacts, groups, and broadcast lists, or use our block feature to manage the users with whom you communicate.
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Changing Your Mobile Phone Number, Profile Name And Picture, And About Information. You must change your mobile phone number using our in-app change number feature and transfer your account to your new mobile phone number. You can also change your profile name, profile picture, and about information at any time.
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Deleting Your Azora Account. You may delete your Azora account at any time (including if you want to revoke your consent to our use of your information) using our in-app delete my account feature. When you delete your Azora account, your undelivered messages are deleted from our servers as well as any of your other information we no longer need to operate and provide our Services. Be mindful that if you only delete our Services from your device without using our in-app delete my account feature, your information may be stored with us for a longer period. Please remember that when you delete your account, it does not affect the information other users have relating to you, such as their copy of the messages you sent them.
Law And Protection
We collect, use, preserve, and share your information if we have a good-faith belief that it is reasonably necessary to: (a) respond pursuant to applicable law or regulations, to legal process, or to government requests; (b) enforce our Terms and any other applicable terms and policies, including for investigations of potential violations; (c) detect, investigate, prevent, and address fraud and other illegal activity, security, or technical issues; or (d) protect the rights, property, and safety of our users, to prevent death or imminent bodily harm.
Updates To Our Policy
We will notify you before we make changes to this Privacy Policy and give you the opportunity to review the revised Privacy Policy before you choose to continue using our Services.
How We Process Your Information
Under European law, companies must have a legal basis to process data. You have particular rights available to you depending on which legal basis we use, and we've explained these below. You should know that no matter what legal basis applies, you always have the right to request access to, rectification of, and erasure of your data under the General Data Protection Regulation (the "GDPR").
For all people who have legal capacity to enter into an enforceable contract, we process data as necessary to perform our contracts with you (the Terms of Service, the "Terms"). The core data uses necessary to provide our contractual services are:
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To provide, improve, customize, and support our Services as described in "Our Services";
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To promote safety and security;
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To transfer, transmit, store, or process your data,
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To communicate with you, for example, on Service-related issues.
Your Consent:
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For collecting and using information you allow us to receive through the device-based settings when you enable them (such as access to your GPS location, camera, or photos), so we can provide the features and services described when you enable the settings.
When we process data you provide to us based on your consent, you have the right to withdraw your consent at any time and to port that data you provide to us, under the GDPR. To exercise your rights, visit your device-based settings, your in app-based settings like your in-app location control.
Our legitimate interests or the legitimate interests of a third party, where not outweighed by your interests or fundamental rights and freedoms ("legitimate interests"):
For people under the age of majority (under 18, in most EU countries) who have a limited ability to enter into an enforceable contract only, we may be unable to process personal data on the grounds of contractual necessity. Nevertheless, when such a person uses our Services, it is in our legitimate interests:
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To provide, improve, customize, and support our Services
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To promote safety and security; and
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To communicate with you, for example, on Service-related issues.
The legitimate interests we rely on for this processing are:
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To create, provide, support, and maintain innovative Services and features that enable people under the age of majority to express themselves, communicate, discover, and engage with information and businesses relevant to their interests, build community, and utilize tools and features that promote their well-being;
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To secure our platform and network, verify accounts and activity, combat harmful conduct, detect and prevent spam and other bad experiences, and keep our Services and free of harmful or inappropriate content, and investigate suspicious activity or violations of our terms or policies and to protect the safety of people under the age of majority, including to prevent exploitation or other harms to which such individuals may be particularly vulnerable.
For all people, including those under the age of majority:
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For providing measurement, analytics, and other business services where we are processing data as a controller. The legitimate interests we rely on for this processing are:
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To provide accurate and reliable reporting to businesses and other partners, to ensure accurate pricing and statistics on performance, and to demonstrate the value our partners realize using our Services; and
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In the interests of businesses and other partners to help them understand their customers and improve their businesses, validate our pricing models, and evaluate the effectiveness and distribution of their services and messages, and understand how people interact with them on our Services.
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To share information with others including law enforcement and to respond to legal requests. The legitimate interests we rely on for this processing are:
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To prevent and address fraud, unauthorized use of Azora products, violations of our terms and policies, or other harmful or illegal activity; to protect ourselves (including our rights, property or Products), our users or others, including as part of investigations or regulatory inquiries; or to prevent death or imminent bodily harm.
Compliance with a legal obligation:
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For processing data when the law requires it, including, for example, if there is a valid legal request for certain data.
Protection of your vital interests or those of another person:
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The vital interests we rely on for this processing include protection of your life or physical integrity or that of others, and we rely on it to combat harmful conduct and promote safety and security, for example, when we are investigating reports of harmful conduct or when someone needs help.
Scope: Azora adheres to the Privacy Principles for the following areas of our business:
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Azora Business Products: Azora creates apps, services, features, APIs, software, or website that enable businesses to interact with users of Azora's products and services (“Business Products”). Partners (the data controllers) may submit personal information about their customers to Azora using Azora's Business Products. While Partners decide what information to submit, it typically includes things like customer phone numbers and other information under the Partner's control. For more information, customers may contact the relevant Partner. Azora uses the personal data provided by Partners to provide Business Products in accordance with the terms applicable to the relevant Business Product and otherwise with the Partners' instructions. Azora works with its Partners to ensure that individuals are offered appropriate choices in accordance with the Privacy Principles.
Access. Within the scope of our authorization to do so, and in accordance with our commitments under Privacy Principles, Azora will work with its Partners to provide individuals access to personal data about them that Azora holds on behalf of its Partners. Azora will also take reasonable steps to enable individuals, either directly or in connection with the Partners, to correct, amend, or delete personal data that is demonstrated to be inaccurate.
Third Parties. Azora may transfer data within the Azora group and to third parties, including service providers and other partners. In accordance with the Privacy Principles, Azora is liable for any processing of personal data by such third parties that is inconsistent with the Privacy Principles unless Azora was not responsible for the event giving rise to any alleged damage.
Legal Requests. Personal data that is transferred to us by our Partners may be subject to disclosure pursuant to legal requests or other judicial and government process, such as subpoenas, warrants, or orders. For more information, review the “Law and Protection” section of the Azora Privacy Policy.
Enforcement. Azora's compliance with the Privacy Principles is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.
For more information about Azora's privacy practices please contact us.
Intellectual Property Policy: Your Copyrights and Trademarks
Azora ("Azora," "our," "we," or "us") is committed to helping people and organizations protect their intellectual property rights. Our users agree to our Terms of Service ("Terms") by installing, accessing, or using our apps, services, features, software, or website (together, "Services"). Our Terms do not allow our users to violate someone else's intellectual property rights when using our Services, including their copyrights and trademarks.
As explained in more detail in our Privacy Policy, we do not retain our users' messages in the ordinary course of providing our Services. We do, however, host our users' account information, including our users' profile picture, profile name, or status message, if they decide to include them as part of their account information.
Copyright
To report copyright infringement and request that Azora remove any infringing content it is hosting (such as a Azora user's profile picture, profile name, or status message), please email a completed copyright infringement claim to admin@azorahub.com (including all of the information listed below).
Before you report a claim of copyright infringement, you may want to send a message to the relevant Azora user you believe may be infringing your copyright. You may be able to resolve the issue without contacting Azora.
Trademark
To report trademark infringement and request that Azora remove any infringing content it is hosting, please email a complete trademark infringement claim to admin@azorahub.com (including all of the information listed below).
Before you report a claim of trademark infringement, you may want to send a message to the relevant Azora user you believe may be infringing your trademark. You may be able to resolve the issue without contacting Azora.
What to include in your copyright or trademark infringement claim to Azora
Please include all of the following information when reporting a copyright or trademark infringement claim to Azora:
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Your complete contact information (full name, mailing address, and phone number). Note that we regularly provide your contact information, including your name and email address (if provided), the name of your organization or client who owns the rights in question, and the content of your report to the person whose content you are reporting. You may wish to provide a professional or business email address where you can be reached.
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A description of the copyrighted work or trademark that you claim has been infringed.
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A description of the content hosted on our Services that you claim infringes your copyright or trademark.
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Information reasonably sufficient to permit us to locate the material on our Services. The easiest way to do this is by providing us the phone number of the individual who has submitted the infringing content on our Services.
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A declaration that:
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You have a good faith belief that use of the copyrighted or trademarked content described above, in the manner you have complained of, is not authorized by the copyright or trademark owner, its agent, or the law;
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The information in your claim is accurate; and
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You declare, under penalty of perjury, that you are the owner or authorized to act on behalf of the owner of an exclusive copyright or trademark that is allegedly infringed.
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Your electronic signature or physical signature.