Plasma Messenger

Plasma Messenger

Privacy Notice

Published: September 10, 2020

Thank you for choosing to be part of our community at Plasma Messenger. company-name ("Company", "we", "us", "our") a Cyprus company with incorporation number HE409180, built the Plasma Messenger App as a Free to download app. We are committed protecting your personal information and your right to privacy. If you have any questions or concerns about this privacy notice, or our practices with regards to your personal information, please contact us at When you use our mobile application, namely Plasma Messenger (the "App") as the case may be and more generally, use any of our services (the "Services", which include the App), we appreciate that you are trusting us with your personal information. We take your privacy very seriously. In this privacy notice, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy notice that you do not agree with, please discontinue use of our Services immediately. This privacy notice applies to all information collected through our Services (which, as described above, includes our App). Please read this privacy notice carefully as it will help you understand what we do with the information that we collect. Please also read Plasma’s Terms and Conditions (“Terms”), which describes the terms under which you use our Services.

1. WHAT INFORMATION DO WE COLLECT?

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the App or otherwise when you contact us. The personal information that we collect depends on the context of your interactions with us and the App, the choices you make and the products and features you use. The personal information we collect may include the following: Personal Information Provided by our affiliate companies and partners We collect the username, the avatar and the technical id number (which is not the Identification number of the user, we just use this number for technical reasons to distinguish the user) from our affiliate companies and/or partners. This information is necessary for the provision our services to you.


Information collected through our App. By using our App, we also collect the following information: • IP: We will collect information with regards to your IP from your mobile device, either continuously or while you are using our App, to provide certain location-based services. • Push Notifications: We may request to send you push notifications regarding your account or certain features of the App. If you wish to opt-out from receiving these types of communications, you may turn them off in your device's settings. • Messages and photos: We will never store any of your messages, voice messages, video messages and/or photos you exchange with other users through the App in our servers. The only exception applies when the recipient device is unable to receive the message, voice message, video message or photo (e.g. the recipient device is offline). In that case we will store the message in our servers with the purpose of delivering it to the recipient as soon as the device is back online. The stored message will be encrypted and stored in our servers for a maximum period of 30 days. If a message is still undelivered following the 30 days period, we will delete it. Once the recipient device becomes available the message will be delivered and removed immediately from our servers. The messages are stored exclusively on your own device during the usage of our App. Subsequently, once you delete a conversation, delete your account and/or delete the App all conversations will be deleted and will not be restorable. This information is primarily needed to maintain the security and operation of our App and for troubleshooting purposes.

Sensitive Data. We do not currently process any sensitive data.

2. HOW DO WE USE YOUR INFORMATION?

We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent. We use personal information collected via our App for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive: • To facilitate logon process. If you choose to connect in a channel or start a conversation through a QR code provided by one of our affiliates and/or partners, we use the information you allowed us to collect from those third parties to facilitate logon process for the performance of the services. • Request feedback. We may use your information to request feedback and to contact you about your use of our App. • To enable user-to-user communications. We may use your information in order to enable user-to-user communications with each user's consent. • To manage user accounts. We may use your information for the purposes of managing your account and keeping it in working order. • To send administrative information to you. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies. • To protect our Services. We may use your information as part of our efforts to keep our App safe and secure (for example, for fraud monitoring and prevention). • To enforce our terms, conditions and policies for business purposes, to comply with legal and regulatory requirements or in connection with our contract. • To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond. • To deliver and facilitate delivery of services to the user. We may use your information to provide you with the requested service. • To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services. • No third-party banners ads. We do not allow third-party banners ads on Plasma Messenger and we do not intent to introduce them at the moment. If we ever decide to allow third-party banner ads, we will update this Privacy Policy.

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations. We may process or share your data that we hold based on the following legal basis: Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose. Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests. Fulfillment of our Terms: Where you have accepted our Terms, we may process your personal information to fulfill the Terms. Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements). Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved. More specifically, we may need to process your data or share your personal information in the following situations: Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honour this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with company-name. We may share your information with affiliates and partners for the performance of any contract with them with regards to the provision of services offered through Plasma Messenger. Other Users. When you share personal information (for example, by exchanging messages with other users through the App) or otherwise interact with public areas of the App, such personal information may be viewed by all users joined the same channel and may be publicly made available outside the App. Other users with whom you communicate may store or reshare your information with others on and off our Services. Some of our external third parties may be based outside the European Economic Area (“EEA”) so the processing of your personal data may involve a transfer of data outside the EEA. Whenever we transfer your data outside the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: a) We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. b) Where we use service providers outside the EEA, we may use specific contracts approved by the European Commission which give personal data the same protection it has in the European Union. c) Where we use providers based in the US, we may transfer data to them if they are part of the EU-US Privacy Shield, which requires them to provide similar protection to personal data shared between the European Union and the US. We may additionally, in rare occasions, transfer your personal data to a party outside the EEA where we have your prior explicit consent to do so or where such transfer is necessary for the provision of our services to you.

4. HOW LONG DO WE KEEP YOUR INFORMATION?

We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law. We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information. We will never store any kind of communication between the users in our servers (with the only exception mentioned in paragraph 1 of the Privacy Policy).

5. HOW DO WE KEEP YOUR INFORMATION SAFE?

We aim to protect your personal information through a system of organizational and technical security measures. We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our App is at your own risk. You should only access the App within a secure environment.

6. DO WE COLLECT INFORMATION FROM MINORS?

Our Services are not intended for children under the age of 13. Therefore, we do not knowingly collect personal information via our websites, applications, services, or tools from anyone under 13. The App is accessible only through the QR codes available through affiliates, partners and contractors. The responsibility for verifying the age and imposing age restrictions to specific channels available through a specific QR code lays with the organization responsible for issuing the QR code connected to that channel. For residents of the EEA, where the processing of personal information is based on consent, users between 13 and 16 years old of age should use Plasma Messenger only subject to parental consent. By continuing using the App, Plasma Messenger assume that the necessary consents by the guardians/parents have been provided. If we learn that we are engaged in that processing with such users without the parental consent, we will halt such processing and will take reasonable measures to promptly remove applicable information from our records. If you become aware of any user being under the age of 13, please contact us immediately at .

7. WHAT ARE YOUR PRIVACY RIGHTS?

Subject to local law, you have certain rights regarding the personal data we collect, use or disclose and that is related to you. We want to make sure you are aware of your rights in relation to the personal data we process about you. We have described those rights and the circumstances in which they apply further below. Right to Access: This enables you to get access or receive a copy of the personal data that we hold about you and to check that we are lawfully processing it.
 Right to Data Rectification and Correction: If you believe that any of the information that we hold about you is inaccurate or incomplete, you have a right to request that we correct the inaccurate personal information.
 Right to be Forgotten / Erasure: You may request that we delete your personal information if you believe that: a) we no longer need to process your information for the purposes for which it was provided; b) we have requested your permission to process your personal information and you wish to withdraw your consent; or c) we are not using your information in a lawful manner. Right to object: You have the right to object to processing of your personal data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground. If you exercise your right to object, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedom or for the establishment, exercise and defence of legal claims.
 Depending on the circumstances, we may need to restrict or cease processing your personal data altogether or, where requested, delete your personal data. Please note that if you object us processing your personal data, we may have to suspend the services we provide to you. Right to Restriction of Processing: You have the right to request the restriction of processing of your personal data. This enables you to ask us to restrict the processing of your personal data if: a) it is not accurate; or b) it has been used unlawfully but you do not want us to delete it; or c) it is not relevant anymore, but you want us to keep it for use in possible legal claims; or d) you have already asked us to stop using your personal data, but you are waiting for us to confirm if we have legitimate grounds to use your personal data. Please note that if you request us to restrict processing of your personal data, we may have to suspend the services we provide to you. Right to data portability: Where we have requested your permission to process your personal data or you have provided us with information for the purposes of entering into a contract with us, you have the right to receive the personal data you provided to us in a portable format. You may also request us to provide it directly to a third party, if technically feasible. We are not responsible for any such third party’s use of your account information, which will be governed by their agreement with you and any privacy statement they provided to you. If we ask for your consent to use your personal data, you can withdraw your consent at any time. Please note that in case of a withdrawal of your consent you may no longer be able to use several functionalities of our App. Please note that some requests to delete certain personal data will require the deletion of your account as a user of Plasma messenger. Also note that it is possible that we require additional information from you in order to verify your authorization to make the request and to honour your request. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances. Moreover, we may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. To exercise any of your rights, or if you have any other questions about our use of your personal data, please contact us electronically by sending us an email at 

8. DO WE MAKE UPDATES TO THIS NOTICE?     

Yes, we will update this notice as necessary to stay compliant with relevant laws. We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information as we dot guarantee that a notification will be sent every time there is an amendment to this Privacy Policy.

9. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?    

If you have questions or comments about this notice, you may email us at