1. Introduction

This Privacy Policy sets out how we, Presence Network Inc. (“Presence”), use and protect your personal data that you provide to us, or that is otherwise obtained or generated by us, in connection with your use of our services (the “Services”). For the purposes of this Privacy Policy, ‘we’, ‘us’ and ‘our’ refers to Presence, and ‘you’ refers to you, the user of the Services.

1.1 Privacy Principles

Presence has two fundamental principles when it comes to collecting and processing private data:

• We don't share your data with third-parties.
• We only store the data that Presence needs to function.
• We don’t track you outside Presence.

1.2. Terms of Service

This Privacy Policy forms part of our Terms of Service, which describes the terms under which you use our Services and which are available at https://presence.is/en/terms. Privacy Policy should therefore be read in conjunction with those terms.

1.3. Table of Contents

This Privacy Policy explains the following:

• the legal basis for processing your personal data;
• what personal data we may collect from you;
• how we keep your personal data safe;
• what we may use your personal data for;
• who your personal data may be shared with; and
• your rights regarding your personal data.

1.4. EEA

If you live in a country in the European Economic Area (EEA), the Services are still provided by Presence, which for the purposes of applicable data protection legislation is the data controller responsible for your personal data when you use our Services.

2. Legal Ground for Processing Your Personal Data

We process your personal data on the ground that such processing is necessary to further our legitimate interests (including: (1) providing the Services to our users; and (2) to detect, prevent or otherwise address fraud or security issues in respect of our provision of Services), unless those interests are overridden by your interest or fundamental rights and freedoms that require protections of personal data.

3. What Personal Data We Use

3.1. Basic Account Data

Presence is a social communication service. You provide your mobile number and basic account data (which may include profile name, profile picture and about information) to create an account on our platform. To make it easier for your contacts and other people to reach you and recognize who you are, the screen name you choose, your profile pictures, and your username are always public. We don't want to know your real name, gender, age, interests and other informations. We do not require your screen name to be your real name.

3.2. Your Messages

3.2.1. Chats

Chats use end-to-end encryption. This means that all data is encrypted with a key that only you and the recipient know. There is no way for us or anybody else without direct access to your device to learn what content is being sent in those messages. We do not store your chats on our servers. We also do not keep any logs for messages, so we don’t even know who or when you have messaged.

3.2.2. Media in Chats

When you send photos, videos or files via chats, before being uploaded, each item is encrypted. The recipient can then download and decipher the file. This means that the file is technically on one of Presence’s servers, but it looks like a piece of random indecipherable garbage to everyone except for you and the recipient. We don’t know what this random data stands for and we have no idea which particular chat it belongs to.

3.3. Phone Number and Contacts

Presence uses phone numbers as unique identifiers so that it is easy for you to find all your contacts on the platform. Of course, we ask your permission before syncing your contacts. After initial signup, we store your up-to-date contacts in order to notify you as soon as one of your contacts signs up for Presence and to properly display names in notifications. We only need the number and name (first and last) for this to work and store no other data about your contacts. We use phone numbers as unique identifiers of our users to also be able to effectively ban abusive users after you will report them to us.

3.4. Cookies

The only cookies we use are those to operate our website. We do not use cookies for profiling or advertising. You may choose to block cookies with your web browser.

4. Keeping Your Personal Data Safe

4.1. End-to-End Encrypted Data

Your messages, media and files from chats are processed only on your device and on the device of your recipient. Before this data reaches our servers, it is encrypted with a key known only to you and the recipient. While Presence servers will handle this end-to-end encrypted data to deliver it to the recipient, we have no ways of deciphering the actual information.

4.2. Retention

Unless stated otherwise in this Privacy Policy, the personal data that you provide us will only be stored for as long as it is necessary for us to fulfill our obligations in respect of the provision of the Services.

5. Processing Your Personal Data

5.1. Safety and Security

Presence supports massive communities which we have to police against abuse and Terms of Service violations. To improve the security of your account, as well as to prevent spam, abuse, and other violations of our Terms of Service, we may collect metadata such as your IP address, devices and Presence apps you've used, history of username changes, etc. If collected, this metadata can be kept for 12 months maximum.

5.2. Spam and Abuse

To prevent phishing, spam and other kinds of abuse and violations of Presence’s Terms of Service, our moderators may check messages that were reported to them by their recipients. Since messages are encrypted, we will receive a screenshot of the allegedly abusive messages. If a spam report on a message you sent is confirmed by our moderators, your account may be banned temporarily or permanently. You can send an appeal.

5.3. Client-driven Ads and anonymity

We might use data for ad targeting. However, unlike other services, these informations are saved only on the phone, not on our servers, and user identity is kept anonymous. The client sends to the server a list of interests and the server sends back to the client a list of promoted contents. No user data is stored, mined or analyzed on our servers to display ads. The list of interests is sent to our server by using an alphanumeric token, not user’s real identity. The request is served and discarded. This means we don’t know your tastes or what you see on the platform.

6. Who Your Personal Data May Be Shared With

6.1. Other Presence Users

Other users of our Services with whom you choose to communicate with and share certain information, who may be located outside the EEA. Note that by entering into the Terms of Service and choosing to communicate with such other users of Presence, you are instructing us to transfer your personal data, on your behalf, to those users in accordance with this Privacy Policy. We employ all appropriate technical and organizational measures (including encryption of your personal data) to ensure a level of security for your personal data that is appropriate to the risk.

6.2. Law Enforcement Authorities

Chats and media file are end-to-end encrypted. This means that nobody can read this data, not even us. However, if Presence receives a court order that confirms you're a terror suspect, we may disclose your IP address and phone number to the relevant authorities.

7. Your Rights Regarding the Personal Data You Provide to Us

7.1. Your Rights

Under applicable data protection legislation, in certain circumstances, you have rights concerning your personal data. You have a right to: (1) request a copy of all your personal data that we store and to transmit that copy to another data controller; (2) delete (see section 10 below) or amend your personal data; (3) restrict, or object to, the processing of your personal data; (4) correct any inaccurate or incomplete personal data we hold on you; and (5) lodge a complaint with national data protection authorities regarding our processing of your personal data.

7.2. Exercising Your Rights

If you wish to exercise any of these rights, kindly contact us using the details in section 12 below.

7.3. Data Settings

You can control how your data is used from the Settings screen of our mobile application. Sadly, if you're not OK with Presence's modest minimum requirements, it won't be possible for us to provide you with our Services. You can delete your Presence account from the Setting page of our mobile application.

8. Deleting data

8.1. Accounts

If you would like to delete your account, you can do this from the Setting page of our mobile application. Deleting your account removes every other piece of data is stored on our server. This action cannot be undone. You can also request deletion of your account and/or personal data at any time by sending us an email at privacy@presence.is. We will verify your identity and process your request.

9. Changes to this Privacy Policy

We will review and may update this Privacy Policy from time to time. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on our privacy page.

10. Questions and concerns

If you have any questions about privacy and our data policies, please write us at privacy@presence.is