If you are not resident in California please click here unless you are resident in the EU, EEA, UK or Switzerland in which case please click here.
Effective date: 25 May 2020
This notice addresses the specific disclosure requirements under the California Consumer Privacy Act of 2018 (“CCPA”), by 9291 International LLP to provide certain information about our data processing practices to California residents in addition to the disclosures in our Privacy Notice at or before the point of collecting personal information.
If you have a visual disability, you may be able to use a screen reader or other text-to-speech or text-to-Braille tool to review the contents of this Privacy Policy.
9291 is firmly committed to the security and protection of personal information of our Users and their contacts. This Privacy Policy describes how 9291 will collect, use, share and process your personal information. Capitalized terms not defined in this Privacy Policy are defined in the 9291 Terms of Service.
If you reside in California, You are entering into the Terms of Service with 9291 International LLP and the terms of this Privacy Policy apply to You. If you are not resident in California the applicable terms are here unless you reside in the EU, EEA, UK or Switzerland in which case the applicable terms are here.
By accepting the 9291 Privacy Policy and/or using the Services You consent to the collection, use, sharing and processing of personal information as described herein. If You provide us with personal information about someone else, You confirm that they are aware that You have provided their information and that they consent to our use of their information according to our Privacy Policy. You may opt-out at any time to prevent further use of the information shared via the Services.
9291 provides disclosures for the 12 months preceding January 1, 2020 as required by the CCPA vis-à-vis California residents. For purposes of clarification, without limitation, the CCPA provides that for purposes of the disclosure requirements pertaining to the preceding 12 months, and until January 1, 2021, these disclosure requirements do not extend to:
(i) personal information collected by 9291 about a natural person in the course of the natural person acting as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or contractor of 9291 to the extent that the natural person’s personal information is collected and used by 9291 solely within the context of the natural person’s role or former role as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or a contractor of 9291; personal information that is collected by 9291 that is emergency contact information of the natural person acting as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or contractor of 9291 to the extent that the personal information is collected and used solely within the context of having an emergency contact on file; or personal information that is necessary for 9291 to retain to administer benefits for another natural person relating to the natural person acting as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or contractor of 9291 to the extent that the personal information is collected and used solely within the context of administering those benefits (“HR Exemption”), or
(ii) California residents who are not acting as an employee, owner, director, officer, or contractor of a company, partnership, sole proprietorship, non-profit, or government agency (a “Business Representative”) where 9291 holds personal information reflecting a written or verbal communication or a transaction between 9291 and the Business Representative and the communications or transaction with 9291 occur solely within the context of 9291 conducting due diligence regarding, or providing or receiving a product or service to or from such company, partnership, sole proprietorship, non-profit, or government agency (“Business-to-Business Exemption”).
California residents have certain rights under the CCPA as further described in this Privacy Policy. The CCPA provides that until January 1, 2021, the described rights do not extend to the HR Exemption or Business-to-Business Exemption.
This Privacy Policy describes the personal information we generally collect, use, and disclose about California residents. You have the right to request that we disclose what personal information we collect, use, and disclose about you specifically (“right to know”). 9291 provides many choices for You to manage your information. You can access and control Your information via our in-app Privacy Center (available under Settings>Privacy Center) where you can use tools to view, rectify, download, restrict processing or deactivate and delete your data. You may also submit a request to exercise the right to know by sending an email request to us using the Contact Information below and include “California Request to Know” in the subject line. Please specify in your request the details you would like to know, including any specific pieces of personal information you would like to access.
WE DO NOT SELL CALIFORNIA RESIDENTS’ PERSONAL INFORMATION.
Personal Information Handling Practices in 2019: Over the preceding 12 months, we disclosed certain categories of California residents’ personal information to the categories of third parties detailed in Annexure 1 of this Privacy Policy available here.
When You create a user profile in the Services and confirm being the holder of a certain number, 9291 will collect the information provided by You. In order to create a user profile, You must register Your first name, last name and phone number. Additional information that may be provided at Your option include, but is not limited to, photo, gender, street address and zip code, country of residence, email address, professional website, Facebook page, Twitter address and a short status message. 9291 may supplement the information provided by You with information from third parties and add it to the information provided by You e.g. additional contact information that is publicly available.
When You install and use the Services, 9291 will collect personal information from You and any devices You may use in Your interaction with our Services. This information may include e.g.: geo-location; Your IP address; device ID or unique identifier; device manufacturer and type; device and hardware settings; SIM card usage; applications installed on your device; ID for advertising and ad data as described in section 4.3 below, operating system; web browser; operator; IMSI; connection information; screen resolution; usage statistics; default communication applications; access to device address book; device log and event information; logs, keywords and meta data of incoming and outgoing calls and messages; version of the Services You use and other information based on Your interaction with our Services such as how the Services are being accessed (via another service, web site or a search engine); the pages You visit and features you use on the Services; the services and websites You engage with from the Services; content viewed by You, content You have commented on or sent to us; the search terms You use; order information and other usage activity and data logged by 9291’s servers from time to time.
Some information, including, but not limited to, usage information and other information that may arise from Your interaction with the Services, cannot be used to identify You, whether in combination with other information or otherwise and will not constitute personal information for the purposes of this Privacy Policy.
You may provide us with Your user identifier information regarding, or to enable Your usage of, certain third-party services (together with a mapped photo where applicable) e.g. social networking services and payment services, in order for the Services to interoperate with such third-party services. You may use such third-party services to create Your user profile or log in to our Services, share information with such third-party services, or to connect Your user profile with the respective third-party services. Such third-party services may automatically provide us with access to certain personal information retained by them about You (e.g., your payment handle, unique identification information, content viewed by You, content liked by You and information about the advertisements You have been shown or may have clicked on) and You agree that we may collect, use and retain the information provided by these third-party services in accordance with this Privacy Policy. You may be able to control the personal information You allow us to have access to through the privacy settings on the respective third-party service. We will never store any passwords created for any third-party services.
Where the 9291 mobile applications (“9291 Apps”) are obtained from other sources than Apple App Store or Google Play, You may share the names, numbers, Google ID’s and email addresses contained in Your address book (“Contact Information”) with 9291 by enabling the 9291 Enhanced Search Functionality. Where the 9291 Apps are obtained from Apple App Store or Google Play, we do not share any user Contact Information. In addition to Contact Information, if You choose to activate use of a third-party service, such as social networks services, within the Services, 9291 may collect, store and use the list of identifiers associated with said services linked to the Contact Information in order to enhance the results shared with other Users.
Please note that no other contact information other than the phone numbers and thereto attached names, Google ID’s and email addresses will be collected and used from Your address book. Other numbers or information that may be contained in Your address book will be filtered away by our safety algorithms and will therefore not be collected by 9291. Please also note that You can always choose not to share Contact Information with 9291 and if You have shared such information and changed Your mind, You can delist Your number or opt-out to render Your entire Contact Information unavailable for search in the 9291 database.
You may provide us with various information in connection with Your interaction with our Services. For example, You may through tagging functionality associate a phone number, that is not registered in the 9291 database or belongs to a User, with a business or name and You may report a phone number as spam or some other attribute to be included in spam blocking directories. 9291 may also from time to time offer You the opportunity to provide information on Your experience from using the Services or to participate in, surveys or other promotions. 9291 will collect the information You provide in connection therewith, as well as any other information You provide through the Services or when You communicate or interact with us.
9291 may use the personal information collected to provide, maintain, improve, and analyze the Services to its Users, partners and third-party providers. More specifically, 9291 may use such information to:
We use aggregated or anonymized personal information for statistical and analytical purposes. We may come to share such data with third parties for providing and improving our services.
We do not consider personal information to include information that has been made anonymous or aggregated so that it can no longer be used to identify a specific person, whether in combination with other information or otherwise.
We may use your information to provide you with non-personalized advertising, by enabling restricted data processing using Google as a service provider. We do not use your precise location or personal information to serve you personalized ads.
Subject to your settings, we may contact You for verification purposes or with information pertaining to the Services or special offers, e.g. newsletter e-mails, SMS and similar notifications about 9291’s and our business partners’ products and services. We may use your information to contact you about our Services and features or to inform you of updates including to our terms and policies.
We may use the collected information to comply with applicable laws and to enforce our agreements and protect and defend the rights or safety of 9291, its Users or any other person and verify provided User profile information with third-party providers and ensure technical service functionality and data accuracy, perform trouble-shooting and prevent or detect fraud, security breaches or illegal activities.
In addition to the sharing and disclosure of personal information that is included as part of the functionality of the Services as described in section 4 above, 9291 may disclose personal information if we believe such action is necessary to:
We transfer information to trusted vendors, service providers, and other partners who support our business and Services, such as providing technical infrastructure services, bug testing, analyzing how our Services are used, and facilitating payments as well as potential partners who may wish to work with us to provide other services. 9291 will always require these third parties to take appropriate organizational and technical measures to protect personal information and to observe applicable legislation.
We may disclose and transfer Your Information to our associated or affiliated organisations or related entities and to any third party who acquires, our business, whether such acquisition is by way of merger, consolidation or purchase of all or a substantial portion of our assets.
If a User chooses to disable the Enhanced Search Functionality, the Contact Information made available by that User is disabled and will thereafter not be available for search in the 9291 database. If any persons do not wish to have their names and phone numbers made available through the Enhanced Search or Name Search functionalities, they can exclude themselves from further queries by notifying 9291 via its website at www.9291.com or as set forth in the contact details below. You acknowledge and agree that 9291 may keep and process personal information related to such request in order to be able to honor the request. You have the right to opt-out of the sale of Your personal information. However, for avoidance of doubt, we do not sell Your personal information.
In order to provide the Services, 9291 will transfer, process and store personal information in countries, including but not limited to India, USA, and may also use cloud based services for this purpose. 9291 may also subcontract storage or processing of Your information to third parties located in countries other than Your home country. Information collected within one country may, for example, be transferred to and processed in another country, which may not provide the same level of protection for personal data as the country in which it was collected. We take all reasonable precautions to protect personal information from misuse, loss and unauthorized access. 9291 has implemented physical, electronic, and procedural safeguards in order to protect the information, including that the information will be stored on secured servers and protected by secured networks to which access is limited to a few authorized employees and personnel. However, no method of transmission over the Internet or method of electronic storage is 100% secure. You acknowledge and agree that 9291 may transfer Your personal information as described above for purposes consistent with this Privacy Policy.
9291 may on its own initiative, or at Your request, replenish, rectify or erase any incomplete, inaccurate or outdated personal information retained by 9291 in connection with the operation of the Services. When required by applicable law, You have the right to know what personal information is stored about You.
You have a right to request the deletion of personal information that we collect or maintain about You. You can access and control Your information via our in-app Privacy Center (available under Settings>Privacy Center) where you can use tools to deactivate and retain or delete your data. Alternatively, if you prefer You may submit a request to delete Your personal information, please contact us using the contact information below, and include “California Request to Delete” in the subject line. Please specify in your request the personal information about you that you would like to have deleted, which can be all of your personal information as required by the CCPA. You may not be discriminated against because you exercise any of your rights under the CCPA in violation of Cal. Civ. Code §1798.125.
Services are not intended for or designed to attract anyone under the relevant age of consent to enter into binding legal contracts under the laws of their respective jurisdictions. 9291 does not intentionally or knowingly collect personal information through the Services from anyone under that age. We encourage parents and guardians to be involved in the online activities of their children to ensure that no personal information is collected from a child without their consent.
WE DO NOT SELL THE PERSONAL INFORMATION OF MINORS UNDER 16 YEARS OF AGE.
9291 may at any time with or without a separate notice change this Privacy Policy, and You are encouraged to review this Policy from time to time. In case of substantial changes, 9291 will notify the Users by push notice or via notice in the Services. Your continued use of the Services after a notice of changes has been communicated to You or published on our Services shall constitute consent to the changed policy.
You can designate an authorized agent to make a request under the CCPA on your behalf if:
If you use an authorized agent to submit a request to exercise your right to know or your right to request deletion, addition to the steps described under Section 2 and Section 8 above, please mail a certified copy of your written declaration authorizing the authorized agent to act on your behalf using the contact information below.
If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with the CCPA.
For all requests to exercise your rights under this Privacy Policy and any enquiries you may have regarding our Services please submit an email request to email with an appropriate subject line.
We will ask that you provide certain information to verify your identity, such as a code sent to your device we may have on file for you. If you have a password-protected account with us, we may verify your identity through our existing authentication practices for your account. The information that we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue. We will respond to your request in accordance with the CCPA. If we deny your request, we will explain why.