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Privacy Policy

Effective Date: 01 October 2025

Introduction

UnderTones (“we,” “our,” “us”) respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use the UnderTones mobile application (the “App”), in accordance with:

  • The Protection of Personal Information Act, 2013 (POPIA) of South Africa
  • The General Data Protection Regulation (GDPR) of the European Union
  • The California Consumer Privacy Act (CCPA) and other international standards

By using the App, you agree to the terms of this Privacy Policy. If you do not agree, please discontinue use of the App.

1. Information We Collect

a. Information You Provide Directly

  • Account Information: Name, email address, username, and password.
  • Reviews & Ratings: Content of reviews, ratings, tags (e.g., “profiling”).
  • Feedback & Communications: When you contact us for support or submit feedback.

b. Information Collected Automatically

  • Device Information: IP address, operating system, device model, unique identifiers.
  • Usage Information: App activity, search history, interactions with businesses.
  • Location Data: Approximate or precise location (with your permission) to show nearby businesses.

c. Information from Third Parties

  • Business Data: Information from OpenStreetMap, Google Places, or other external sources to display business listings.
  • Social Logins: If you sign in using a third-party account (e.g., Google, Apple), we receive basic profile details.

2. How We Use Your Information

  • Provide and improve the App.
  • Display businesses, reviews, and inclusivity scores.
  • Facilitate community contributions (posting, searching, sharing).
  • Personalize recommendations and highlight inclusive spaces.
  • Maintain safety (moderation, detecting harmful or fake reviews).
  • Communicate with you (updates, security alerts, customer support).
  • Comply with legal obligations.
  • Review and moderate user-generated content, and remove content that violates our policies or applicable laws.

3. Legal Basis for Processing

  • POPIA (South Africa): Lawful, reasonable, minimal, and purpose-specific processing.
  • GDPR (EU/UK users): Consent, contractual necessity, legal obligation, legitimate interest.
  • CCPA (California users): Right to know, delete, opt-out of sale (we do not sell personal data).

4. Sharing of Information

  • Service Providers: Cloud hosting, analytics, content moderation, and security services.
  • Business Listings: Your reviews may appear publicly on business profiles.
  • Legal Authorities: When required by law, regulation, or to protect rights and safety.
  • With Your Consent: If you opt-in to share data with third-party apps or services.

5. User-Generated Content

  • Reviews, ratings, and tags you post are publicly visible.
  • You may choose to post reviews anonymously.
  • You are responsible for ensuring your contributions comply with our Community Guidelines.
  • Users may report reviews that are abusive, discriminatory, or otherwise inappropriate. Reported content may be reviewed and removed.

6. Data Retention

  • Account data is retained while your account is active.
  • Reviews remain visible even after account deletion but may be anonymized.
  • We delete or anonymize data when it is no longer necessary for the purposes collected.

7. Your Privacy Rights

  • Access: Request a copy of your personal information.
  • Correction: Request updates or corrections.
  • Deletion: Request deletion of your account and data.
  • Objection: Object to processing for certain purposes.
  • Consent Withdrawal: Withdraw consent at any time (e.g., location data).
  • Data Portability (GDPR): Receive a structured copy of your data.
  • Do Not Sell My Info (CCPA): You may opt out of any data sale (we do not sell data).
  • South African users may also lodge complaints with the Information Regulator of South Africa.

To exercise your rights, contact us at support@undertones.co.za.

8. Data Security

We apply reasonable technical and organisational safeguards, including encryption, access controls, and secure storage. However, no system is fully secure, and we cannot guarantee absolute protection.

9. International Data Transfers

Your data may be processed outside your home country, including in jurisdictions that may not provide the same level of protection. We ensure safeguards (such as Standard Contractual Clauses) are in place when transferring data internationally.

10. Children’s Privacy

  • The App is not intended for children under 18.
  • We do not knowingly collect personal information from minors.
  • If you believe a child has provided us with data, please contact us for deletion.

11. Changes to This Policy

We may update this Privacy Policy from time to time. Updates will be posted in the App with a revised “Effective Date.” Continued use of the App after changes constitutes acceptance.

12. Contact Us

If you have questions or requests about this Privacy Policy or your personal data, contact us at:

UnderTones
Email: support@undertones.co.za