Privacy

Kooma Privacy Policy

Thank you for visiting our website. This is the privacy policy for 4D Interactive group companies.

4D Interactive group companies, all registered in England:

4D Interactive Limited
Candywall Limited
Excel Telemedia Limited
Intermediactive Acquisitions Limited
Intermediactive Group Limited
Intermediactive Holdings Limited
Spiritual Live Services Limited
Kooma Limited

4D Interactive is committed to protecting your privacy. We use the information we collect about you to process orders and to provide a personalised service to you when you visit our website.

At 4D Interactive, we appreciate that you do not want the personal information you provide to us distributed indiscriminately and here, we explain how we collect information, what we do with it and what controls you have.

This Privacy Policy is for the websites hosted or operated by or on behalf of 4D Interactive ("we", "us" and the "Sites"). This Privacy Policy is incorporated in and subject to Our Terms.

Websites covered by this policy:

Chatboxuk.com
Chatordate.co.uk
Fonechat.co.uk
Gaynetwork.co.uk
Cardsoffortune.com
Kooma.co.uk
Kooma.com
Kooma.ie
Psychicswitchboard.co.uk
Adultphonechat.co.uk
4dinteractive.co.uk

Please read the following carefully to understand our views and practices regarding your personal information and how we will treat it. By engaging with this Site or our services (our services include all 4D Interactive Group live entertainment services provided by telephone, web call, email or SMS (the "Services"), you acknowledge you have read and understood this Privacy Policy.

We may change this Privacy Policy from time to time so please review it each time you visit the Site. You may wish to print a copy of this Privacy Policy for your future reference.

For the purposes of European data protection law, ("Data Protection Law") when you are using 4D Interactive group company websites, the data controller is 4D Interactive Limited.

Please note that calls are recorded and monitored for training and quality control purposes and to comply with applicable regulatory authorities.

1. Information we collect about you

We will collect and process the following information ("Your Data") from you each time you interact with our site or use our Services.

"Your Data" means any information about you which is personally identifiable, including, without limitation, your name, address, telephone number, email address, financial details, service access code, comments, personal descriptions, photos, video, audio, audiovisual, location data, technical information, and other information from which you can be identified and which you may disclose to us or otherwise via use of our Site or Services.

1.1 Information you give us

This is information about you that you give us directly when you interact with us.

This is information about you that you give us by filling in forms on our Site and/or Services or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our Site and/or Services, subscribe to our service, search for a product, place an order on our Sites, participate in discussion boards or other social media functions on or via our Site and/or Services, enter a competition, promotion or survey, submit a query, and when you report a problem with our Site and/or Services.

The information you give us may include your name, address, e-mail address and phone number, financial and credit card information, personal description and photograph, login and password details.

It may also include employment details if you send us a CV, resumé or other details of your employment history in connection with an advertised job vacancy or a general enquiry regarding employment opportunities with us.

1.2 Information we collect about you from your use of our Site/Services

We will automatically collect information from you each time you visit our Site/use our Services. This includes:

Technical information
Information about your visit
Location data

Technical information may include the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;

Information about your visit to our Site may include the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number or social media handle used to connect with our customer service team.

Location data - we collect information through the Sites as to your real time location to provide location services where requested or agreed to by you in order to allow elements of the services that are dependent on knowing where you are to function, namely searching for other users near you. This information may also be collected in combination with an identifier associated with your device to enable us to recognise your mobile browser or device when you return to the Sites.

Delivery of location services will involve reference to one or more of the following: (a) the coordinates (latitude/longitude) of your location; (b) look-up of your country of location by reference to your IP address against public sources; (c) your postcode or region, as provided by you; and/or (d) your Identifier for Advertisers (IFA) code for your Apple device, or the Android ID for your Android device, or a similar device identifier.

See Cookies and other technologies for more information on the use of cookies and device identifiers on the Sites.

1.3 Information we receive from other sources

We may supplement the information that you provide to us with information that we receive from third parties. This is information we receive about you:

If you use any of the other Sites we operate or the other services we provide.
From third parties we work closely with.

In this case we will have informed you when we collected that data if we intend to share your data internally and combine it with data collected on this site. We will also have told you for what purpose we will share and combine your data.

We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, and search information providers). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.

2. When do we collect Your Data?

2.1 We collect Your Data from You when you:

(a) register with any of our Sites;
(b) use any of our Services;
(c) use the Site or otherwise correspond with us in relation to use of the Service;
(d) make a complaint or enquiry or provide other feedback through Us; and
(e) disclose Your Data to us or otherwise through Us at any other point.

3. How do we use Your Data?

We may use Your Data in the following ways:

3.1 Information you give to us:

(a) Take steps in order to enter into any contract or carry out our obligations arising from any contract entered into between you and us including:
1. (i) processing your registration on and activities through the Services;
2. (ii) processing and administering your account with us;
3. (iii) verifying and carrying out financial transactions in relation to payments you make online, over the phone, or via SMS;
4. (iv) notifying you about changes to our service.
5. (v) providing you with information about our Site or Services we feel may interest you, if you have given your consent to receiving marketing material from us at the point we collected your information, where required by law or otherwise in our legitimate interests provided these interests do not override your right to object to such communications. See 'Our promotional updates and communications'.
(b) Ensure in our legitimate interests that:
1. (i) content from our site is presented in the most effective manner for you and for your computer.
2. (ii) we provide you with the information, products and services that you request from us;
3. (iii) we can develop, improve and deliver the Services.
(c) Provide the Services you have chosen to receive;
(d) Process and deal with any complaints or enquiries made by or about you;
(e) Monitor and investigate any suspected breach of our Services made by or otherwise relating to you;
(f) In the event that we or a part of our business undergoes a re-organisation or is sold to a third party, You agree that any personal information we hold about You may be transferred to that re-organised entity or third party.

3.2 Information we collect about you from your use of our Site and/or Services

We will use this information in our legitimate interests, where we have considered these are not overridden by your rights:

(a) To administer our Site and/or Services and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
(b) To keep our Site and/or Services safe and secure.
(c) To improve our Site and/or Services to ensure that content is presented in the most effective manner for you and for your computer.
(d) To allow you to participate in interactive features of our service, when you choose to do so.

3.3 Information we receive from other sources

We may combine this information with information you give to us and information we collect about you in our legitimate interests (where we have considered that these are not overridden by your rights). We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).

4. Our promotional updates and communications

Where permitted in our legitimate interest or with your prior consent where required by law, we will use your personal information for marketing analysis and to provide you with promotional update communications by telephone, web call, email or SMS about our Services.

You can object to further marketing at any time by:

checking and updating your contact details within your account,
selecting the "unsubscribe" link at the end of all our marketing and promotional update communications to you,
following the "STOP" instructions contained in each SMS, or
by sending us an email to DPO@4DInteractive.co.uk.

5. Will we pass on Your Data to third parties?

5.1 We may pass Your Data to other parties as follows:

(a) Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, who support our processing of personal data under this policy. Further information about our group can be found here
4D Interactive group companies
- 4D Interactive Limited
- Candywall Limited
- Excel Telemedia Limited
- Intermediactive Acquisitions Limited
- Intermediactive Group Limited
- Intermediactive Holdings Limited
- Spiritual Live Services Limited
- Kooma Limited
(b) Selected third parties.
1. (i) In some cases we may use a technical partner to conduct some processing of Your Data on Our behalf, but this is always subject to strict contractual control and is in compliance with UK Data Protection legislation;
  Our selected third parties may include:
  
  Organisations who process your personal data on our behalf and in accordance with our instructions and the Data Protection Law. This includes in supporting the services we offer through the Site and/or Services in particular those providing website and data hosting services, providing fulfilment services, distributing any communications we send, supporting or updating marketing lists, facilitating feedback on our services and providing IT support services from time to time. These organisations (which may include third party suppliers, agents, sub-contractors and/or other companies in our group) will only use your information to the extent necessary to perform their support functions.
  
  Analytics and search engine providers that assist us in the improvement and optimisation of our site and subject to the cookie section of this policy (this will not identify you as an individual). This may include general statistical information about our user base, sales patterns, traffic volumes and related matters.
  
  Business partners who provide services to you and with whom we have entered into agreements in relation to the processing of your personal data. This includes our technical partners, who provide the following services: broadcasting and channel recording, voice interconnection, voice short code aggregation / gateways, and MMS/SMS gateways.
  
  Accredited payment processing providers who provide secure payment processing services (note only the last 4 digits of your payment card details are stored.
(c) We will disclose your personal information to third parties:
1. (i) In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets subject to the terms of this privacy policy.
2. (ii) If the Company or substantially all of its assets are acquired by a third party, or our Company group undergoes a re-organisation, in which case personal data held by it about its customers will be one of the transferred assets.
3. (iii) If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of supply terms and other agreements with you; or to protect the rights, property, or safety of the Company, the Company group, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction and to prevent cybercrime.
4. (iv) We may disclose Your Data to the police, regulatory bodies or legal advisers in connection with any alleged criminal offence or investigation carried out by them or any suspected breach of the Our Terms by You;
5. (v) We may disclose Your Data to Phone-paid Services Authority the premium rate services regulator for regulatory purposes or to the police or other law enforcement bodies where required by law or where we deem it appropriate in connection with alleged offences or unlawful acts;
(d) Public forums

The Site and/or Services may, from time to time, make chat rooms, message boards, news groups and/or other public forums available to its users. Any information that is disclosed in these areas becomes public information and you should exercise caution when using these and avoid posting or otherwise sharing any personal information.

Always think carefully before disclosing Your Data or other information to other Services users on the Site and/or on our Services. As stated in Section 6 of Our Terms, we have no responsibility or control over the contents of communications made between users and Readers or other users of the Services.

6. Where we store your information

We store your information in the United Kingdom, and your data will not be accessed outside the European Economic Area ("EEA") that may not be subject to equivalent Data Protection Law.

7. Data Security

7.1 Server security

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology or similar. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Site and/or Services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

7.2 Payment processing

Card payment details you provide will be encrypted using secure sockets layer (SSL) technology before they are submitted to us over the internet. Payments made on the Site and/or via our Services are made through our payment gateway provider(s), Cybersource and Barclaycard. You will be providing credit or debit card information directly to Cybersource and Barclaycard which operates a secure server to process payment details, encrypting your credit/debit card information and authorising payment. Information which you supply to Cybersource and Barclaycard is not within our control and is subject Cybersource and Barclaycard's own privacy policies and terms and conditions.

7.3 Internet security

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site and/or Services; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

WE MAKE NO WARRANTIES, EITHER EXPRESS OR IMPLIED, AS TO THE SECURITY OF YOUR DATA COMMUNICATIONS, CONTENT OR POSTINGS, OR THAT THIRD PARTIES WILL NOT GAIN UNAUTHORIZED ACCESS TO OR MONITOR YOUR COMPUTER(S) OR YOUR ONLINE COMMUNICATIONS. YOU AGREE THAT WE WILL NOT BE LIABLE FOR ANY SUCH UNAUTHORIZED ACCESS OR USE OR ANY DAMAGES INCLUDING WITHOUT LIMITATION DIRECT, INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL OR OTHER DAMAGES.

8. Cookies and other technologies

This explains what you need to know about how we use cookies on our Sites, and how to choose to manage or remove them if you wish to do so.

Our Site and uses cookies and/or other similar technologies such as device-IDs, in-App codes, tracking GIFs / pixel tags, web beacons, or log files, to collect and store certain information. These typically involve pieces of information or code that a website transfers to or accesses from your computer hard drive or mobile device to store and sometimes track information about you. Cookies and similar technologies enable you to be remembered when using that computer or device to interact with websites and online services and can be used to manage a range of features and content as well as storing searches and presenting personalised content.

Our Site uses cookies and similar technologies to distinguish you from other users of our Site (and/or Services). This helps us to provide you with a good experience when you browse our site and also allows us to improve our Site and Services.

Most web browsers automatically accept cookies and similar technologies, but if you prefer, you can change your browser to prevent that. The Help menu in your browser should tell you how. For information on how to do this on the browser of your mobile phone you should refer to your handset manual. Alternatively, just search for 'how to block cookies'. We also give you information about how to disable cookies here. Please be aware that disabling cookies completely means that certain personalised features will not then be provided to that user and therefore they may not be able to make full use of all of the website's features.

A number of cookies and similar technologies we use last only for the duration of your web session and expire when you close your browser. Others are used to remember you when you return to the Site and will last for longer.

We use these cookies and other technologies on the basis that they are necessary for the performance of a contract with you, or because using them is in our legitimate interests (where we have considered that these are not overridden by your rights), and, in some cases, where required by law, where you have consented to their use.

For more information on cookies and how to disable them, you can consult the information provided by the Interactive Advertising Bureau at https://www.allaboutcookies.org

We use cookies and/or other similar technologies such as device-IDs, in-App codes, tracking GIFs / pixel tags, web beacons, or log files either alone or in combination with each other in a number of ways, including to create a unique device ID.

We use the following types of cookies:

Strictly necessary cookies. These are cookies that are required for the operation of our Sites and under our terms with you. They include, for example, cookies that enable you to log into secure areas of our Sites, use a shopping cart or make use of e-billing services. When logged in our Sites will remember your log in details. This information is not used for advertising purposes on any other sites.
Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our Sites when they are using them. This helps us for our legitimate interests of improving the way our Sites work, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies. These are used to recognise you when you return to our Sites. This enables us, subject to your choices and preferences, to personalise our content, greet you by name and remember your preferences (for example, your choice of language or region).
Targeting/Advertising cookies. These cookies record your visit to our Sites, the pages you have visited and the links you have followed. We will use this information subject to your choices and preferences to make our Sites and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

For more information about setting your advertising preferences, see Disabling cookies, below or visit https://www.youronlinechoices.com

8.1 Disabling cookies

The effect of disabling cookies depends on which cookies you disable but, in general, the Sites may not operate properly if all cookies are switched off. If you only disable third party cookies, you will not be prevented from making purchases on our Site and/or Services. If you disable all cookies, you will be unable to complete a purchase on our Site and/or Services. You can disable targeting/advertising cookies and still use our services.

If you want to disable cookies on our Sites, you need to change your website browser settings to reject cookies. How you can do this will depend on the browser you use.

Further details on how to manage cookies for the most popular browsers can be found online at websites such as https://allaboutcookies.org/how-to-manage-cookies.

Where you have not set your permissions, we may also separately prompt you regarding our use of cookies on the Site.

Except for essential cookies, all cookies used on our site will expire after 6 months.

9. Refer a Friend

When You use these facilities and provide us with personal data (e.g. the name and email address) of a third party, please ensure that You have their consent before giving us their details.

10. Other links

Please be aware that we may, from time to time, link to external sites which may be accessed by you through our Site or Services. We are not responsible for the privacy policies, content or security of such sites.

11. How long we keep your information

We retain certain personal data for as long as you have an account with us in order to meet our contractual obligations to you and for up to seven years after that to identify any issues and resolve any financial and/or legal proceedings. Personal data may be retained for a shorter period, for example where legal or similar restrictions apply. IM records are retained for no more than 12 weeks and call recordings are retained for 12 months. We may also retain aggregate information beyond this time for research purposes and to help us develop and improve our services. You cannot be identified from aggregate information retained or used for these purposes.

12. Your rights

You have the right under certain circumstances:

to be provided with a copy of your personal data held by us;
to request the rectification or erasure of your personal data held by us;
to request that we restrict the processing of your personal data (while we verify or investigate your concerns with this information, for example);
to object to the further processing of your personal data, including the right to object to marketing (as mentioned in 'Our promotional updates and communications' section);
to request that your provided personal data be moved to a third party.

You may opt out at any time from allowing further access by us to your location data by

checking and updating your contact details within your account,
selecting the "unsubscribe" link at the end of all our marketing and promotional update communications to you,
following the "STOP" instructions contained in each SMS, or
by sending us an email to DPO@4DInteractive.co.uk.

Your right to withdraw consent: Where the processing of your personal information by us is based on consent, you have the right to withdraw that consent without detriment at any time by contacting us per the information set out in Contact us below. You can also change your marketing preferences at any time as described in 'Our promotional updates and communications' section.

You can also exercise the rights listed above at any time by contacting us at DPO@4DInteractive.co.uk.

If your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority, (see https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.html). The Information Commissioner is the supervisory authority in the UK and can provide further information about your rights and our obligations in relation to your personal data, as well as deal with any complaints that you have about our processing of your personal data.

You may exercise your rights for free. However, where requests are clearly unfounded or excessive (for example, because they are repetitive) we may charge a small administration fee, or we may choose not respond to the request.

13. Changes to this policy

Any changes we make to our privacy policy in future will be posted on this page and, in relation to substantive changes, will be notified to you by e-mail. This policy was last updated on 19^th September 2024.

14. Contact us

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to:

Contact	Data Protection Officer
Address	4D Interactive Limited Suite 1, First Floor 1 Duchess Street London W1W 6AN UK
Phone (UK)	020 39407092
Phone (Int)	+44 (0)20 39407092
Email	DPO@4DInteractive.co.uk