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Effective date: October 13th, 2021.
NKN MANAGEMENT Inc. (“us”, “we”, or “our”) operates the Morrow Food mobile application (hereinafter referred to as the “Service”). This page informs you of our policies regarding the collection, use and disclosure of personal data when you use our Service and the choices you have associated with that data. We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.

DEFINITIONS
Service is the Morrow Food mobile application operated by NKN MANAGEMENT Inc.

Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

Usage Data is data collected automatically either generated using the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Cookies are small files stored on your device (computer or mobile device).

Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the way any personal information are, or are to be, processed. In the matter of the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.

Data Processors (or Service Providers) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers to process your data more effectively.

Data Subject (or User) is any living individual who is using our Service and is the subject of Personal Data.

INFORMATION COLLECTION AND USE
We collect several different types of information for various purposes to provide and improve our Service to you. It goes without saying, we can’t help you develop meaningful connections without some information about you, such as basic profile details and the types of people you’d like to meet. We also collect information generated as you use our services, for example access logs, as well as information from third parties, like when you access our services through a Facebook account. If you want additional info, we go into more detail below.

Types of Data Collected that you give us Personal Data While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:

– When you create an account, you provide us with at least your login credentials, as well as some basic details necessary for the service to work, such as your gender, name, e-mail, interest, and date of birth.

– When you complete your profile, you can share with us additional information, such as details on your personality, lifestyle, interests, and other details about you, as well as content such as photos and videos. To add certain content, like pictures or videos, you may allow us to access your camera or photo album. Some of the information you choose to provide us may be considered “special” or “sensitive” in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious beliefs. By choosing to provide this information, you consent to our processing of that information.

– When you answer questions in the app, Morrow will automatically use information to make us wiser so we can deliver a better product back to you.

– If you contact our customer care team, we collect the information you give us during the interaction. Sometimes, we monitor or record these interactions for training purposes and to ensure a high quality of service.

– If you ask us to communicate with or otherwise process information of other people (for example, if you ask us to send an email on your behalf to one of your friends), we collect the information about others that you give us to complete your request.

– Of course, we also process Cookies and User Data, your chats, match, path cross with other users as well as the content you publish, as part of the operation of the services.

INFORMATION WE COLLECT FROM OTHERS
In addition to the information you provide us directly, we receive information about you from others, including:

Other Users may provide information about you as they use our services. For instance, we may collect information about you from other users if they contact us about you.

Facebook login You may be able to use your Facebook Login to log into your Morrow account. This saves you from having to remember yet another username and password and allows you to share some information from your social media account with us.

Connect your Instagram account to fulfill your profile, you can connect your Instagram and share your latest post with our service. Here you’ll find Instagram’s terms of use https://help.instagram.com/581066165581870?ref=dp

ReCAPTCHA To log in and create account we’re using google invisible ReCAPTCHA Find Privacy Policy https://policies.google.com/privacy?hl=en and Terms of Use https://policies.google.com/terms?hl=en

INFORMATION WE GIVE TO THIRD PARTIES
Usage Data
When you access the Service with a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, version and language, operating system, time zones your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, information on your wireless and mobile network connection, like your service provider and signal strength; information on device sensors such as accelerometers, gyroscopes and compasses, apps settings and characteristics, app crashes, unique device identifiers, information about your activity on our services, for instance how you use them (e.g., date and time you logged in, features you’ve been using, searches, clicks and pages which have been shown to you, who and how many you like or dislike, advertising that you click on and how you interact with other users (e.g., users you connect and interact with, time and date of your exchanges, number of messages you send and receive).and other diagnostic data (“Usage Data”).

Location Data
We may use and store information about your location if you give us permission to do so (“Location Data”). We use this data to provide features of our Service, to improve and customize our Service. If you give us permission, we can collect your precise geolocation (latitude and longitude) through various means, depending on the service and device you’re using, including GPS, Bluetooth, or Wi-Fi connections. The collection of your geolocation may occur in the background even when you aren’t using the services if the permission you gave us expressly permits such collection. You can enable or disable location services when you use our Service at any time by way of your device settings.

Tracking & Cookies Data
We use cookies and similar tracking technologies to track the activity on our Service and we hold certain information. Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags, and scripts to collect and track information and to improve and analyze our Service. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Examples of Cookies we use:

Session Cookies. We use Session Cookies to operate our Service.

Preference Cookies. We use Preference Cookies to remember your preferences and various settings.

Security Cookies. We use Security Cookies for security purposes.

We as well use other services to make our marketing better:

Facebook Pixel for marketing purposes
– Their terms can be read at following link: https://www.facebook.com/legal/technology_terms

Mailchimp to send out email
– Their policies can be read at https://mailchimp.com/legal/additional-terms/

USE OF DATA
NKN MANAGEMENT Inc. uses the collected data for various purposes:

– To provide and maintain our Service

– To notify you about changes to our Service

– To allow you to participate in interactive features of our Service when you choose to do so

– To provide customer support

– To gather analysis or valuable information so that we can improve our Service

– To monitor the usage of our Service

– To detect, prevent and address technical issues

LEGAL BASIS FOR PROCESSING PERSONAL DATA UNDER THE GENERAL DATA PROTECTION REGULATION (GDPR) – ASEAN, The Association of Southeast Asia.
If you are from The Association of Southeast Asian Nations (ASEAN), NKN MANAGEMENT Inc. legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

The Data Privacy Act of 2012 (Republic Act No. 10173)  (‘the Act’) was the first comprehensive law covering data privacy in the Philippines. It became enforceable on 8 September 2012.  (GDPR)

The National Privacy Commission (‘NPC’), which was established in early 2016, later issued the Implementing Rules and Regulations of Republic Act No. 10173  (‘IRR’), which became enforceable on 9 September 2016. The IRR provides, in greater detail, the requirements that individuals and entities must comply with when processing personal data, as well as the sanctions for violations of the Act.

Read more about The Philippines Data Protection Overview here:

https://www.dataguidance.com/notes/philippines-data-protection-overview

NKN MANAGEMENT Inc. may process your Personal Data because:
– To administer your account and provide our services to you

– To connect with other users

– To improve our services and develop new meaningful ones

– We need to perform a contract with you

– You have given us permission to do so

– The processing is in our legitimate interests, and it is not overridden by your rights

– For payment processing purposes

– To comply with the law
To process your information as described above, we rely on the following legal bases:

– Provide our service to you: Most of the time, the reason we process your information is to perform the contract that you have with us. For instance, as you go about using our service to build meaningful connections, we use your information to maintain your account and your profile, to make it viewable to other users and recommend other users to you.

– Legitimate interests: We may use your information where we have legitimate interests to do so. For instance, we analyze users’ behavior on our services to continuously improve our offerings” e.g. Our recommended meetings places”, we suggest this offers we think might interest you.

– Consent: From time to time, we may ask for your consent to use your information for certain specific reasons. You may withdraw your consent at any time by contacting us at the address provided at the end of this Privacy Policy.

RETENTION OF DATA
NKN MANAGEMENT Inc. will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies. NKN MANAGEMENT Inc. will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods. Deletion of information
All information you have given us can be stored 5 years after the latest activity.

TRANSFER OF DATA
Your information, including Personal Data, may be transferred to – and maintained on – computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. If you are located outside The Philippines and choose to provide information to us, please note that we transfer the data, including Personal Data, to The Philippines and process it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. NKN MANAGEMENT Inc. will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

HOW WE SHARE INFORMATION
Our goal and existence is to help you make meaningful connections which leads to dates as a dating service, the main sharing of users’ information is, of course, with other users. We also share some users’ information with service providers and partners and in some cases, legal authorities.

– With other users You share information with other users. Please be careful with your information and make sure that the content you share is stuff that you’re comfortable being publicly viewable since neither you nor we can control what others do with your information once you share it.

– With our service providers, partners and other thirty parties We use third parties to help us operate and improve our services. These third parties assist us with various tasks, including data hosting and maintenance, analytics, customer care, marketing, advertising, payment processing and security operations. We may also share information with partners who are promoting promotions (e.g., restaurants). For instance, we may share limited information on you in hashed, non-human readable form to advertising partners. (e.g., how many people have clicked on their ad).

– For corporate transactions We may transfer your information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control.

– When required by law We may disclose your information if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government / law enforcement investigation or other legal requirements; (ii) to assist in the prevention or detection of crime (subject in each case to applicable law); or (iii) to protect the safety of any person.

– To enforce legal rights We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.

DISCLOSURE OF DATA
Legal Requirements

NKN MANAGEMENT Inc. may disclose your Personal Data in the good faith belief that such action is necessary to:

– To comply with a legal obligation

– To protect and defend the rights or property of NKN MANAGEMENT Inc.

– To prevent or investigate possible wrongdoing in connection with the Service

– To protect the personal safety of users of the Service or the public

– To protect against legal liability

Security of Data
The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security. Your Data Protection Rights under the General Data Protection Regulation (GDPR) If you are a resident of The Association of Southeast Asia (ASEAN), you have certain data protection rights. NKN MANAGEMENT Inc. aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data. If you wish to be informed about what Personal Data, we hold about you and if you want it to be removed from our systems, please contact us. In certain circumstances, you have the following data protection rights:

– The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.

– The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.

– The right to object. You have the right to object to our processing of your Personal Data.

– The right of restriction. You have the right to request that we restrict the processing of your personal information.

– The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable, and commonly used format.

– The right to withdraw consent. You also have the right to withdraw your consent at any time where NKN MANAGEMENT Inc. relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests. You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in The Association of Southeast Asia (ASEAN).

SERVICE PROVIDERS
We may employ third party companies and individuals to facilitate our Service (“Service Providers”), provide the Service on our behalf, perform Service-related services, or assist us in analyzing how our Service is used. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Analytics
We may use third-party Service Providers to monitor and analyze the use of our Service.

– Google Analytics Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. You may opt-out of certain Google Analytics features through your mobile device settings, such as your device advertising settings or by following the instructions provided by Google in their Privacy Policy: https://policies.google.com/privacy?hl=en For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

– Firebase Their terms can be read at: https://firebase.google.com/terms

– Appflyer Their terms can be read at: https://www.appsflyer.com/terms-of-use/

Payments
We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g., payment processors). We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information. The payment processors we work with are:

– Apple Store In-App Payments Their Privacy Policy can be viewed at https://www.apple.com/legal/privacy/en-ww/

– Google Play In-App Payment Their Privacy Policy can be viewed at https://play.google.com/intl/en-us_us/about/play-terms/index.html

– ALinks to Other Sites Our Service may contain links to other sites that are not operated by us. If you click a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

HOW LONG WE RETAIN YOUR INFORMATION
We keep your personal information only for as long as we need it for legitimate business purposes and as permitted by applicable law. In practice, we delete or anonymize your information upon deletion of your account or after five years of continuous inactivity, unless:
1. we must keep it to comply with applicable law (for instance, some “traffic data” is kept for one year to comply with statutory data retention obligations);
2. we must keep it to evidence our compliance with applicable law (for instance, records of consents to our Terms, Privacy Policy and other similar consents are kept for five years);
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 preventing a user who was banned for unsafe behavior or security incidents from opening a new account.
Keep in mind that even though our systems are designed to carry out data deletion processes according to the above guidelines, we cannot promise that all data will be deleted within a specific timeframe due to technical constraints.

CHILDREN’S PRIVACY
Our Service does not address anyone under the age of 17 (“Children”). We do not knowingly collect personally identifiable information from anyone under the age of 17. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

HANGES TO THIS PRIVACY POLICY
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

CONTACT US
If you have any questions about this Privacy Policy, please contact us:

NKN MANAGEMENT Inc.
Morrow Philippines
BIR: 609-951-942-000
SEC: 2021100028831-07
Address: Ayala Trianagle Gardens Tower 2 Level 6 Paseo De Roxas Cor. Makati Ave. Bel-Air, Makati, Philippines
Phone: +63 995 189 7198
Email: hello@morrowpartner.com
Web: www.morrowpartner.com / www.morrow.ph
Facebook: www.facebook.com/morrowfood
Instagram: www.instagram.com/morrowfood