TANDERS INC.

THUNDR PRIVACY POLICY

Welcome to the Thundr Privacy Policy (“Policy”)! This explains how we collect, store, protect, and share your information, and with whom we share it. We suggest you read this in conjunction with our Terms & Conditions of Use. While enjoying the Thundr mobile application (“App”), our website, or using our digital products and services (together, referred to in this Privacy Policy as our “Sites”), we collect some information about you. In addition, you may choose to use the App or Sites to share information with other users, including your friends and contacts (“Users”). We may also need to share your information sometimes. This Policy explains how we protect your personal data, so please read very carefully!

Who we are

The App and Sites are operated by the “Tanders, Inc.” (also referred to in this policy as “we” or “us”). Tanders, Inc. has designated a Data Protection Officer and they can be reached by emailing hello@thundr.ph or by post at the following address: #92 A. Aguirre Ave., BF Homes, Parañaque City

COLLECTION OF INFORMATION

When you download the App and create an account (“Account”), we may collect certain information (“Registration Information”) about you, such as:

  • Name;

  • Username;

  • Email address;

  • Cell number;

  • Gender identity;

  • Date of birth;

  • Sexual preference;

  • Photographs;

  • Location; and

  • Login information for social media accounts that you connect to your Thundr Account (this could include, for example, your Facebook, Apple and Google accounts).

Once you register, you will be able to review and change this information at any time just by logging in to Thundr (other than your date of birth and location (which, if you have given Thundr access to your location in your device settings, is automatically updated based on the location of your device)). It is your responsibility to ensure that your account details are kept up to date. If your phone number changes, please ensure that you update this in your account.

The information we collect helps to enhance the App and verify our Users. Registration Information such as your age, name and other pertinent data may be visible to other Users who view your profile page.

Profile Information

We recommend and encourage you (and all our members) to think carefully about the information you disclose about yourself. We also do not recommend that you put email addresses, URLs, instant messaging details, phone numbers, full names or addresses, credit card details, national identity numbers, drivers’ license details and other sensitive information which is open to abuse and misuse on your profile.

When you post information about yourself or use the messaging function to communicate with other Users, the amount of personal information you share is at your own risk.

Purchases Information

If you decide to purchase our premium services, we will process your payment information and retain this securely for the prevention of fraud and for audit/tax purposes.

Thundr uses automated decisions to prevent fraudulent payment transactions being processed as part of its anti-fraud procedures. In order to do this, our systems check payment transactions for behavior that indicates breaches of our Terms and Conditions of Use. If a transaction meets certain criteria that demonstrate that the Terms and Conditions of Use are likely to have been breached and the transaction is likely to be fraudulent, the relevant transaction may automatically be blocked. Where a transaction is blocked, the user will be notified that their transaction cannot be processed and affected Users can contact Thundr to contest the decision.

Geolocation Information

If you have given Thundr access to your location in your device settings, when you use your cell, we will collect information about WiFi access points as well as other location information about your longitude and latitude and may save your device’s coordinates to offer certain features to you. This information helps us identify your physical location and we use it to personalize the App and make it easier for you to interact with other Users, by enabling the general locality information to be displayed to Users seeing your profile and showing you the profiles of other Users who are near you.

If you have given Thundr access to your location, but wish to turn this off, you can do so by the following methods:

  1. iPhone app — settings, privacy, location services, Thundr

  2. Android — settings, location, Thundr permissions, location

Device Information

We may collect information about your device when you use the App including the unique device identifier, device model, and operating system, for a number of purposes, as set out in this policy. In addition, if you permit us to do so, the App may access your device’s address book solely in order to add someone to your contacts.

Links

We may keep track of how you interact with links available on Thundr including third party services by redirecting clicks or through other means. We may share aggregate click statistics such as how many times a particular link was clicked on.

Messages

We review the content of messages sent in the App to identify topics, sentiments, and trends across our Users. We will take steps to remove personally identifying information from such messages, prior to reviewing them. We will not share the content of User messages or information we derive from them with any third party.

When you Contact Customer Support

If you contact our Customer Support team via hello@thundr.ph , we will receive your email address, and may track your IP address, as well as the information you send to us to help resolve your query. We will keep records of our communications with you, including any complaints that we receive from you about other Users (and from other Users about you) for 6 years after deletion of your account.

Cookies and similar technologies

When you visit our Sites or when you use our App, we may collect personal data from you automatically by using cookies or similar technologies. A cookie is a small file that can be placed on your device or browser that allows us to recognize and remember you.

If you would like to find out more about cookies, including how we use them and what choices are available to you, please refer to our Cookie Policy.

USE OF YOUR INFORMATION

Our main goal is to ensure your experience on Thundr is an enjoyable one! In order to deliver an enjoyable experience to you, we may use your Registration and other information to:

  • offer you our services and features;

  • contact you with information about the App (e.g., updates and new features);

  • personalize the App/Sites and the content we deliver to you;

  • conduct research and analytics about how you use and interact with the App/Sites;

  • to test new technologies and processes designed to enhance and improve the App/Sites;

  • resolve disputes, troubleshoot problems and to enforce our Terms & Conditions;

  • investigate fraud, protect our legal rights, and to enforce our Terms & Conditions.

  • protect our Users and third parties from harm.

Our Matching Algorithms

We have developed matching algorithms to predict your compatibility with other users and so we can show you people we think are a good match for you. Our matching algorithms use the following data about you to predict your compatibility with others and generate profile recommendations: the things you tell us about yourself in your profile; information about your activity in our apps; and your device coordinates, which are necessary to understand your proximity to other members.

Moderation Practices

We use a combination of automated systems and a team of moderators to monitor and review accounts (including photos and any other information uploaded onto user profiles) and messages for content that indicates breaches of our Terms and Conditions of Use. If an account or message meets certain criteria that demonstrate that the Terms and Conditions of Use are likely to have been breached, the relevant account will be subject to a warning and the user’s access restricted and/or blocked. Affected Users can contact Thundr to contest the decision.

If you post anything that is inconsistent with our Terms and Conditions of Use, we reserve the right to terminate or restrict access to your Account.

DISCLOSURE OF INFORMATION

Our policy is to not disclose your Registration Information or personal data, except in the limited circumstances described here:

Circumstances where data may be disclosed

Disclosed data

Service Providers – We engage certain trusted third parties to perform functions and provide services to us. We may share your Registration Information or personal data with these third parties, but only for the purposes of performing these functions and providing such services. More information about this is available directly below.

This could include all data

Moderators – To monitor activity on the App and approve content.

Name and user registration details, profile information, content of messages and photographs

Marketing Services Providers – To help us serve marketing and advertising on third party websites and applications and measure the effectiveness of our advertising campaigns. More information on this is available below

estimated location (based on your IP address), age, gender and data about your visit to our Sites or App and action taken on those (for example if you downloaded our App or created an account with our App)

 

Aggregated Information – We may share aggregated information with third parties that includes your personal data (but which doesn’t identify you directly) together with other information including log data for industry analysis and demographic profiling.

MORE INFORMATION ABOUT DISCLOSURES

Service Providers

We engage certain trusted third parties to perform functions and provide services to us (“Service Providers”). The suppliers with which Thundr shares User personal data vary depending on a variety of factors, such as which of our App, Sites and services a User engages with. For example, to provide our services to Users, we typically use the following suppliers:

  • Billing services – to allow customers to purchase paid features of our App (for example, Google Play and Apple Pay)

  • Social media providers – to allow customers to create/connect their Thundr account with their account(s) on such platforms (for example Facebook, Google or Apple)

  • IT services – some of the third-party software providers used in the operation of our business may process Users’ personal data (for example, if a User contacts us via social media with a support inquiry, their inquiry is processed by our community management software provider Khoros)

We carry out due diligence on all Service Providers we engage to ensure they have adequate data protection and information security measures in place and only provide them with the personal data necessary to the service they are providing. Measures are taken to ensure that the data shared is non-attributable to the greatest extent possible and our suppliers are also subject to extensive obligations under our contractual arrangements, including strict data retention limits.

Marketing Services Providers

We partner with providers of marketing services to help us market and advertise our App and services on third party websites and applications and measure the effectiveness of our advertising campaigns. For example:

  • to exclude you from advertising campaigns aimed at finding new users, if you already have a Thundr account;

  • to show Thundr adverts to users who have visited the App/Sites but haven’t yet created an account;

  • to create an audience for our advertisements of other potential users who have similar characteristics to you based on the information the Marketing Service Providers holds about you (also known as a Lookalike Audience); or

  • to include you in a ‘custom audience’ that will receive Thundr advertising content (a custom audience is essentially a list of people who we think are most likely to be interested in a particular advertisement).

We share a limited amount of your personal data with these Marketing Services Providers, such as:

  • the advertising identifier associated with your device (this is a random number assigned by your mobile device manufacturer (for example Apple or Google) to your device to help advertisers (including the manufacturer) know when an ad has been viewed or clicked in an app, and when an ad causes a ‘conversion’ (for example, downloading the app advertised to you))

  • your estimated location (based on your IP address)

  • age and gender

  • data about your visit to our Sites or App and action taken on those (for example if you downloaded our App, created an account with our App, or details of any purchases made on Site or in App)

  • a hashed* version of your email address (to create ‘custom audiences’).

*Hashing is a way of encrypting information by turning it into a combination of random numbers and letters – this code cannot be traced back to the email address. When hashed email addresses are sent to a Marketing Service Provider, they’re then matched against the Provider’s own existing list of their own users’ hashed information and our ads are served to those of our users who have successfully been matched with the Provider’s. Matched and unmatched hashes are then deleted by the Provider.

For more information about how we use cookies and other tracking technologies, including how you can set and manage your preferences with regards to such technologies, please see our Cookie Policy.

In some cases, these third parties will also use the data that they collect for their own purposes, for example they may aggregate your data with other data they hold and use this to inform advertising related services provided to other clients.

WHAT OTHERS MAY SEE ABOUT YOU

We think our Users are awesome, and we want you to share how awesome you are with the world, so we have built certain features to enable this. Our App is designed to make it easier for you to connect with other Users and to interact with them.

When using the Thundr App, you should assume that anything you post or submit on the App may be publicly-viewable and accessible, both by Users and non-users of the App. We want our Users to be careful about posting information that may eventually be made public.

Please be careful about posting sensitive details about yourself on your profile such as your religious denomination, political views, and health details. While you may voluntarily provide these information to us when you create your profile, there is no requirement to do so. Please remember that photographs that you post on Thundr may reveal information about yourself as well. Where you do upload and choose to tell us sensitive information about yourself, you are explicitly consenting to our processing of this information and making it public to other Users.

Your Thundr profile and other information you make available via the App, including certain information added to your profile through third party accounts (such as Facebook) may be viewed and shared by Users with individuals who may or may not be users of the App. For example, a User may recommend you as a match to his or her Facebook friend(s) by taking a screenshot of your profile picture and sharing it, regardless of whether such friend(s) is also a User of the App.

If you log in to or access the App through your Facebook account or another third-party account on a device which you share with others, remember to log out of the App and the relevant third-party account when you leave the device in order to prevent other users from accessing your Thundr account.

OUR POLICY TOWARDS AGE

Although we want as many people as possible to enjoy our creation, you have to be at least 35 years old to use Thundr.

Thundr does not knowingly collect any information about or market to children, minors or anyone under the age of 18. If we become aware that a child, minor or anyone under the age of 18 has registered with us and provided us with personal information, we will take steps to terminate that person’s registration.

SECURITY

Here at Thundr, we pride ourselves on taking all appropriate security measures to help protect your information against loss, misuse and unauthorized access, or disclosure. We use reasonable security measures to safeguard the confidentiality of your personal information such as secured servers using firewalls.

Unfortunately, no website or Internet transmission is ever completely 100% secure and even we cannot guarantee that unauthorized access, hacking, data loss or other breaches will never occur, but here are some handy tips to help keep your data secure:

  1. Please make sure you log out of your Account after use as you never know who may stumble onto your Account!

  2. Please don’t share the password you use to access your Thundr Account with anyone else!

If you ever think someone has had access to your password or Account, please let us know by emailing us at hello@thundr.ph.

LINKING OTHER ACCOUNTS TO THUNDR

Using your social media details to sign in to Thundr

When you sign in to our App using your Facebook account, you give permission to Facebook to share with us your name and profile picture. Unless you opt-out, you also give permission to Facebook to share with us your email address (if there is one associated with your Facebook account), date of birth, profile photos, gender, Page likes and current town/city.

If you register or sign in with your Apple ID, you give Apple permission to share your Apple login, a name (that can be edited by you) and an email (you can choose to hide your email and Apple will create a random email address so your personal email can stay private). This email address will be linked to your Thundr account and will be used to retrieve your Thundr account.

We will then use this personal data to form your Thundr account. If you remove the Thundr app from your Facebook settings, or from your Apple ID, we will no longer have access to this data. However, we will still have the personal data that we received when you first set up your Thundr account using your Facebook or Apple ID (you must delete your Thundr account entirely for us to no longer have access to this data).

YOUR RIGHTS

Privacy laws applicable in your country may give you the following rights:

  1. Right to be informed: what personal data an organization is processing and why (we provide this information to you in this Privacy Policy).

  2. Right of access: you can request a copy of your data.

  3. Right of rectification: if the data held is inaccurate, you have the right to have it corrected.

  4. Right to erasure: you have the right to have your data deleted in certain circumstances.

  5. Right to restrict processing: in limited circumstances, you have the right to request that processing is stopped but the data retained.

  6. Right to data portability: you can request a copy of certain data in a machine-readable form that can be transferred to another provider.

  7. Right to object: in certain circumstances (including where data is processed on the basis of legitimate interests or for the purposes of marketing) you may object to that processing.

  8. Rights related to automated decision-making including profiling: there are several rights in this area where processing carried out on a solely automated basis results in a decision which has legal or significant effects for the individual. In these circumstances your rights include the right to ensure that there is human intervention in the decision-making process.

The particular rights which are applicable to you (which might include other rights not listed above) may vary depending on your country. You should make yourself aware of the rights you have under applicable privacy laws in your country.

DATA RETENTION AND DELETION

We keep your personal information only as long as we need it for the legal basis relied upon and as permitted by applicable law.

When your Account is deleted, we make sure it is no longer viewable in the App. For up to 30 days, it is still possible to restore your Account if it was accidentally deleted. After 30 days, we begin the process of deleting your personal information from our systems, unless:

  1. We must keep it to comply with applicable law (for instance, if you make purchases within the App, some personal data may be kept for tax and accounting purposes);

  2. We must keep it to evidence our compliance with applicable law (for example, if an account is blocked, we keep some account information and a record of the behavior that led to the block – this information is retained for evidential purposes in case of queries or legal claims concerning the block);

  3. there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or

  4. the information must be kept for our legitimate business interests, such as fraud prevention and enhancing Users’ safety and security (for example, information may need to be kept to prevent a user who was banned for unsafe behavior or security incidents from opening a new account).

Warning: Even after you remove information from your profile or delete your Account, copies of that information may still be viewable and/or accessed to the extent such information has been previously shared with others, or copied or stored by others. We cannot control this, nor do we accept any liability for this. If you have given third party applications or websites access to your personal information, they may retain such information to the extent permitted under their terms of service or privacy policies.

CHANGES TO THIS POLICY

As Thundr evolves, we may revise this Privacy Policy from time to time. The most current version of the policy will govern our use of your information. If we make a change to this policy that, in our sole discretion, is material, we will notify you, for example, via an email to the email associated with your Account or by posting a notice within Thundr.