Skrilo Limited ("Skrilo") recognises that its’ customers, visitors and users, want to know their privacy rights. Skrilo provides this Privacy Policy to help you make an informed decision about whether to use or continue using the Skrilo Site, Skrilo software and/or the Skrilo Product. If you do not agree to our practices, please do not use the Skrilo Site, Skrilo software, or Skrilo Product.

This Privacy Policy is incorporated into and is subject to the Skrilo Terms and Conditions. Your use of the Skrilo Site, Skrilo software and the Skrilo Product and any personal information you provide on the Skrilo Site or Skrilo Product remains subject to the Terms and Conditions of this Privacy Policy and our Terms and Conditions.

What Does This Privacy Policy Cover?

This Privacy Policy is part of Skrilo’s Terms and Conditions and covers the treatment of user information, including personally identifying information, obtained by Skrilo, including information obtained when you access the Skrilo’s Site, use the Skrilo Product or any other software provided by Skrilo. This Privacy Policy does not apply to the practices of companies that Skrilo does not own or control, or to individuals whom Skrilo does not employ or manage, including any of the third parties to which Skrilo may disclose user information where the consent has been explicitly obtained and as set forth in this Privacy Policy.

The Information Skrilo Collects
Skrilo may obtain the following types of information from or concerning you or your mobile phone device, which may include information that can be used to identify you as specified below (“Personally Identifiable Information”):

User Provided Information: 
You agree that Skrilo Limited will collect your IMEI number for fraud detection and prevention.

You provide certain Personally Identifiable Information, such as your mobile phone number, any personal details as described in the profile section of the Application, deal preferences, push notification name (if applicable), billing information (if applicable), any account information, location information and mobile device information to Skrilo when choosing to participate in various uses of the Skrilo Product, such as registering as a user, updating your status or requesting status for your contacts. We may log your opt-in and opt-out behaviour to sponsor messages in order to showcase relevant deals, offers, products and services to you from our business partners.

Cookies Information: 
When you visit the Skrilo Site, we may send one or more cookies - a small text file containing a string of alphanumeric characters - to your computer that uniquely identifies your browser. Skrilo may use both session cookies and persistent cookies. A persistent cookie remains after you close your browser. Persistent cookies may be used by your browser on subsequent visits to the Site. Persistent cookies can be removed by following your web browser help file directions. A session cookie is temporary and disappears after you close your browser. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, the Skrilo Site may not function properly if the ability to accept cookies is disabled.

Log File Information: 
When you use the Skrilo Site, our servers automatically record certain information that your web browser sends whenever you visit any website. These server logs may include information such as your web request, Internet Protocol ("IP") address, browser type, browser language, referring / exit pages and URLs, platform type, number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time of your request, one or more cookies that may uniquely identify your browser, your phone number, phone number you are requesting the status of and various status information. When you use the Skrilo Product, our servers log certain general information that our Application sends whenever a message is sent or received, or if you update or request any status information, including time and date stamps and the mobile phone numbers the messages were sent from and to.

The Way Skrilo Uses Information
If you submit Personally Identifiable Information to us through the Skrilo Site, or Skrilo Product, then we use your personal information to operate, maintain, and provide to you the features and functionality of the Skrilo Site and Skrilo Product. In particular, your mobile phone number is essential to your use of the Skrilo Product and will be retained. Skrilo offers you an opportunity to engage with products and services from our sponsors by opting in via features that request for more information, request for a call-back option, or saving of coupons. However, you may opt out of any of these options and simply collect additional chances for viewing the sponsor messages. Your opt-in choice would trigger your name, email id or phone number to be shared with the sponsor, whose product or service you have expressed interest in. This is only enabled when you voluntarily wish to hear back from them. Hence, the "Send Me Info" and "Call Me Back" are options that trigger your acceptance to share the limited data with the business partner to enable your request. We may, however, use your mobile phone number (or email address, if provided) without further consent for non-marketing or administrative purposes (such as notifying you of major Skrilo Site or Skrilo Product changes or for customer product purposes). We may use both your Personally Identifiable Information and certain non-personally-identifiable information (such as anonymous user usage data, cookies, IP addresses, browser type, clickstream data, etc.) to improve the quality and design of the Skrilo Site and Skrilo Product and to create new features, promotions, functionality, services and products by storing, tracking, and analysing user preferences and trends. We may also retain your account information to which any winnings have been transferred to ensure we have a log and history for any regulatory audits. We may use cookies and log file information to: (a) remember information so that you will not have to re-enter it during your visit or the next time you use the Skrilo Product or Skrilo Site; (b) provide custom, personalised content and information; (c) monitor individual and aggregate metrics such as total number of visitors, pages viewed, etc.; and (d) track your entries, submissions, views and such.

When Skrilo Discloses Information
We do not sell or share your Personally Identifiable Information (such as mobile phone number) with other third-party companies for their commercial or marketing use without your consent, except as part of a specific product or feature for which you will have the ability to opt-in or opt-out. If, on viewing a sponsor message that you wish to be called by the merchant or business for a further engagement, you understand that we will need to share your name and mobile number to enable this interaction. We may share your Personally Identifiable Information in a limited manner with third party product providers to the extent that it is reasonably necessary to perform, improve or maintain the Skrilo Product to the advantage of all stakeholders. We may share non-personally-identifiable information (such as anonymous user usage data, aggregate data insights, referring / exit pages and URLs, platform types, asset views, number of clicks, etc.) with interested third-parties to assist them in understanding the usage patterns for certain content, products, advertisements, promotions, and/or functionality on the Skrilo Site. We may collect and release Personally Identifiable Information and/or non-personally-identifiable information if required to do so by law, or in the good-faith belief that such action is necessary to comply with state and federal laws (such as U.S. Copyright Law), international law or respond to a government agency, court order, subpoena, or search warrant or equivalent, or where in our reasonable belief, an individual’s physical safety may be at risk or threatened. Skrilo also reserves the right to disclose Personally Identifiable Information and/or non-personally-identifiable information that Skrilo believes, in good faith, is appropriate or necessary to enforce our Terms and Conditions, take precautions against liability, to investigate and defend itself against any third-party claims or allegations, to assist government enforcement agencies, to protect the security or integrity of the Skrilo Site or our servers, and to protect the rights, property, or personal safety of Skrilo, our employees and users or others.

Your Choices
You may, of course, decline to submit Personally Identifiable Information through the Skrilo Site or the Skrilo Product, in which case Skrilo may not be able to provide certain products to you. If you do not agree with our Privacy Policy or Terms and Conditions please delete your account, uninstall the Skrilo mobile application and discontinue use of the Skrilo Product; your continued usage of the Skrilo Product will signify your assent to and acceptance of our Privacy Policy and Terms and Conditions. To protect your privacy and security, we take reasonable steps (such as SMS authentication in certain cases) to verify your identity before registering your mobile phone number and granting you access to the Skrilo Product. Please contact Skrilo using our contact details available on our website with your comments about this Privacy Policy, your personal information, your consent, or your participation choices to the sponsor messages in the form of rich media.

Our Commitment To Data Security
Skrilo uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your personal information. We cannot, however, ensure or warrant the security of any information you transmit to Skrilo and you do so at your own risk. Using unsecured wifi or other unprotected networks to submit messages through the Skrilo Product is not recommended. Once we receive your transmission of information, Skrilo makes commercially reasonable efforts to ensure the security of our systems. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. If Skrilo learns of a security systems breach, then we may attempt to notify you electronically so that you can take appropriate protective steps. Skrilo may post a notice on the Skrilo Site or through the Skrilo Product if a security breach occurs.

Our Commitment To Children’s Privacy
Protecting the privacy of young children is especially important. For that reason, Skrilo does not knowingly collect or maintain Personally Identifiable Information or non-personally-identifiable information on the Skrilo Site or Skrilo Product from persons under 18 years of age, and no part of the Skrilo Product is directed to or intended to be used by persons under 18. If you are under 18 years of age, then please do not use the Skrilo Product or access the Skrilo Site at any time or in any manner. If Skrilo learns that Personally Identifiable Information of persons under 18 years of age has been collected on the Skrilo Site or Skrilo Product, then Skrilo may de-activate the account and/or make the status submissions inaccessible.

In the Event of Merger, Sale, or Bankruptcy
In the event that Skrilo is acquired by or merged with a third party entity, we reserve the right to transfer or assign the information we have collected from our users as part of such merger, acquisition, sale, or other change of control. In the unlikely event of our bankruptcy, insolvency, reorganisation, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors' rights generally, we may not be able to control how your personal information is treated, transferred, or used.

Changes and updates to this Privacy Notice
This Privacy Policy may be revised periodically and this will be reflected by the "effective date" below. Please revisit this page to stay aware of any changes. Your continued use of the Skrilo Site and Skrilo Product constitutes your agreement to this Privacy Policy and any amendments.

Version: This Privacy Policy was last modified 8th May, 2018