We are committed to protecting and respecting your privacy. This policy (together with our terms and conditions of use and any other documents referred to in it) sets out on the basis of personal data we collect from you, will be used by us. By accepting this policy when signing up to use our Services, and/or by your continued use of the Services, you agree to bound by this policy as updated from time to time. This policy is going to tell you about: Who we are Your rights to access and/or amend data held and opt out of consenting to uses of your data What data we collect What we do with this data Where we store this data How long we store your data for Steps taken to keep data safe We may require to access your real time location Our right to amend our policy Special rules on children and data 1. WHO WE ARE We are the owner of this website and we are the data controller, maintaining a data controller registration with the Information Commissioner. 2. YOUR RIGHTS TO ACCESS/AMEND THE DATA WE HOLD ON YOU & OPT OUT (a) Accessing the data we hold on you You can make a Subject Access Request at any time in writing, by following this simple process. By law, we have up to 40 days to respond to you and reserve the right to make a small charge for this service. When you are making a Subject Access Request, please write to us enclosing a photocopy of a photographic ID (e.g. passport or driving license) and utility bill (to provide proof of your address). We promise your private information will only circulate among us or a third party that you expressly authorized. Please write to us at the address stated above if you wish to make a subject access request. (c) Changing your consent and opting out It’s ok to change your mind about what data you are allowing us to keep and what you don’t want us to keep. You can amend your settings through your account at any time, or contact our Supportive team. We have to advise you however, that opting out of some data processing/storage will result in reduce user experience and a loss of functionality. 3. WHAT INFORMATION WE COLLECT ABOUT YOU We may collect and process different types of information about you. Part of the data is considered to be Personal (that means you can be identified by it including Sensitive Personal Data) and Anonymous(that is data that you cannot be identified from). (a) Information we collect when you sign up to our Services We will collect your personal details including but not limited to full real name, user name, address, telephone, email address, date of birth, race, religion, sexual orientation and any other information you submit when you create a profile and sign up to our Services. (b) Data we collect in respect of customer service and support If you contact customer supportive we will keep all the information you provide to us including records of correspondence. If you provide feedback to us, or take part in customer survey, participate in competitions, we will keep all the information you provide. (c) Data we collect/you upload from your activity across our Services When you use our Services to search for other users, explore our Services, or interact with other users, we will gather data related to these activities including: All information you populate your profile with including photographs; All messages that you send or receive through our sites; A record of your activities including winks, block lists and search histories for example is also stored by us; Details of any transactions that you carry out, including all the information we require to provide the products or services that you sign up to; Data from your other social network accounts if they are linked to our sites; Your location according to the IP address assigned to your computer machine or mobile device by your Internet Service Provider, and mobile location data; Usage data about how you use our site, this is what we consider Anonymous Data, which we collect using Cookies. (d) Information we collect from other social networks that you use Some of our Services have the ability to link your use of the Services to other social networks you might have accessed. If you have an account with another social network. Let’s use Facebook for example, you can share the data you have on our site with that network. To enhance your experience and create a personalized service we may ask you to login to your Facebook account. By doing so you grant us access to your information stored on your Facebook profile including personal information, photographs, videos, interests and locations. When you login to the other network or install our app, we will receive the basic information including your name, photos, gender, networks, user ID, friends list and any other information you make public and your email address. If you have logged into other social networks and linked them to any of our profiles you grant permission for us to post updates, including location information, please exercise caution. You can turn off location data – see below. (e) Information we collect about your location When accessing the Services from a mobile device, it means you allow to share the location with our application. We can track your IP address if you are using a computer to access the Services. We use GPS with an accuracy range of 20 to 100 metres, Although location data is anonymous and can’t identify you, it can be shown to other users so please exercise caution if you do not wish to publicize your location. If you choose to change or turn off location sharing, in order to provide you with a more localized service and localized matches, we will show you as being at a randomly generated location within the postal code area that you have provided. We also use your location data to research our own Services, develop new products and improve our Services, including using third parties to help us either provide the Services to you or develop new ones, and target advertising to suit your user experience. Your devices can give us lots of information about the device including the brand, model, version of operating system, installed app details, email accounts, mobile carrier and so on. (f) Information we collect about your Contacts Some features of the Services allow you to share with people you know (“your Contacts”), and invite them to join in. When given the option to do so you can choose to upload your Contacts information; we will request their name and email address. If you give us your password to upload these Contacts through a web based email provider we shall not store your password after you have uploaded your Contacts’ addresses. 4A. HOW WE USE YOUR INFORMATION – AN OVERVIEW We process data we collect from you for the following core purposes: To administer your user account with us (including notifying you of any compatible matches, tips, announcements, updates, special offers or services, should you consent to this); To allow you to participate in any interactive features of the Services (including the features that require the mobile phone number); To help personalize your repeat visits to and usage of the Services; To notify you of any compatible matches or any matches who are near your location; To provide you with information on products or services or news and offers that you request from us (see below under 'Marketing' for more information); To answer any questions you may raise or respond to any comments you may send to us; To notify you about changes to our service or the functionality of the Site; To ensure that you are complying with the terms and conditions of use and to comply with our statutory and regulatory obligations. Providing our products and services We use the information we collect about you: (1) To fulfill your requests for our products, programs, and services; (2) To respond to your inquiries about our offerings; (3) To provide, personalize, and improve our offerings; and We use the information that you provide about others to allow us to send them invitations, gifts, cards, or other content on your behalf or through our Website. Occasionally, we also may use this information to offer products, programs, or services to them. Mobile device data usage When you access our Website on a mobile device, we may use the information collected for any purpose stated in this privacy policy. Use of non-personal information We use aggregate information about our users and non-personal information that we collect to improve the design, functionality, and content of our Website and to allow us to personalize your experience with our Website and offerings. We use this information (1) To provide, maintain, personalize, protect, improve, and develop our products, programs, and services and to operate our business; (2) To analyze usage and performance of our Website (including to perform ad tracking and website or mobile application analytics); and Safety and security We may monitor your user activities to ensure that you and other users are complying with our terms of use and our privacy policy, and to monitor any suspicious activity on our sites. This may including user's photos, content, profiles, message and chat histories, and all other user activity on our sites. 4B. HOW WE USE YOUR INFORMATION – IN DETAIL (a) Creation of duplicate profiles across our Partner Sites When you sign up to any one of our Services we will send you an email shortly afterwards advising that we have created a duplicate profile on our Partner Sites to enhance your chance of finding a suitable match. When we email you about this you will have the option to decline this service, which costs nothing extra. (b) Important notice about how we use your photographs As we explain in our terms and conditions, when you upload a photo to any of our Services you are allowing us to use that photo for advertising and other commercial purposes, royalty free. (c) How we use your information about your Contacts If you choose to upload your Contact’s name and email address and/or mobile number you are allowing us to send an email or social network or mobile invitation on your behalf, inviting your Contact to join the Services. We will store your Contact’s name and email address solely for the purposes of inviting them to sign up to our Services and for associating your Contact with you and other people they may know. We will not store your Contacts information after invitations (up to a maximum of 3) have been sent. Your Contacts will then only receive future emails from us if they choose to accept the invitation and join our Services. 5. MARKETING (a) When we market to you directly about our products and services We may share your information with our Partner Sites and Group Companies to develop and deliver targeted advertising to you of our Partner Sites and Group Companies’ products and services, or to help us to prepare marketing reports. We may send you information about our Partner Sites and Group Companies’ products and services, news and offers, and selected third party products and services that we think may be of interest to you. We may do this by contacting you through your email address or mobile phone number that you have provided. Any communication received from us, as consented to by you, will clearly state that it is being sent by us. You have the option to opt-out of our marketing communications at any time (see below). (b) Opting Out of Marketing If you change your mind about the marketing consent you have granted to us, you can amend your preferences under the “My Account” section of your chosen Site or emailing our support team. 6. HOW LONG WE KEEP YOUR DATA FOR (a) Active Users If you are an Active User we will store your data until you cancel your account. (b) Inactive Users If you are not active for a long time, we will continue to store your data until you cancel your account, including continue to market to you if you have consented to marketing. We hope you will return to use the Services regularly and we want your information to be there for your convenience so you should be aware that you will still appear in our search results for other users, and your profile will remain visible. The responsibility to change your preferences or cancel your account lies with you. (c) Cancelled Users If you canceled the services, we will delete all of your data 9 months after the date of cancellation. It is important that we retain your data for this short period after cancellation to ensure that we can answer any payment or other account related queries, or provide information to third parties in line with our disclosure provisions outlined in this policy e.g. assisting police investigations. Even after you remove information from your profile or delete your account, copies of that information may still be viewable and/or accessed on the Internet to the extent such information has been previously shared with others, or copied or stored by other users or to the extent such information has been shared with search engines. 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. (d) Deactivated users If you select to 'Deactivate my account' / 'Hide my profile' in the account settings. Your profile and personal data will continue to be stored, allowing you to reactivate your account. When you use this option, your account / profile will be temporarily invisible to other users, and will remain so until you cancel your account or reactivate your profile. De-activating your profiles does NOT cancel your paid subscriptions, to ensure you are not further charged you must properly cancel your account, not simply de-activate it. Google Play or other application platforms authorized by application. (e) Storage of activity data Whilst we retain your Personal Data, Sensitive Personal Data and Anonymous Data as outlined at (a) to (c) above, there are some features of our Services that we store data in respect of, for different periods of time. All other profile and activity information including photographs, blocked list, search histories etc. are stored until 9 months after your account is cancelled. (f) Banned and terminated users If your account is ever terminated by us, or you are detected as a potential or actual scammer, or a potential or otherwise threat to our business or our users, your email address will be retained on our internal blacklist for as long as we deem necessary to protect the business and its users. 7A. HOW WE KEEP YOUR DATA SECURE We will do our best to protect your personal data, We take reasonable administrative, physical, and electronic measures designed to safeguard and protect your information from unauthorized access or disclosure. This includes using Secure Sockets Layer (SSL) software, which encrypts the personal information you input, and storing your information in encrypted form behind a firewall designed to block access from outside our network. Although we use commercially reasonable efforts to safeguard the privacy of your information, transmissions on the Internet cannot be made absolutely secure. However, we cannot assure you that your information that we collect will not be used or disclosed inconsistently with this privacy policy. We assume no responsibility or liability for disclosure of any of your information due to errors in transmission, unauthorized third-party access, or other causes beyond our reasonable control. 7B. HOW YOU CAN HELP KEEP YOUR OWN DATA SECURE We have designed the Website to make it easy for you to find, connect, and interact with other members of the Website by posting information about yourself. You can also use our electronic messaging system, which allows you to communicate with other users provided you are both subscribers. We recommend and encourage you (and all our members) to think carefully about the information they disclose about themselves. 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 in your profile is not recommended. Please be careful about posting sensitive details about yourself on your profile such as your religious denomination and health details. While you may voluntarily provide this information to us when you create your profile, including your sexual preferences and ethnic background, there is no requirement to do so. Please remember that photographs or any video clips that you post on the Website may reveal these kinds of sensitive personal data. Where you do upload and choose to tell us sensitive information about yourself, you are explicitly consenting to our processing your information and making this public to other users. When you post information about yourself or use the messaging service, the amount of personal information you share is at your own risk. In addition, these postings may appear on other websites or in searches on the subject matter of your posting. Whenever you voluntarily disclose personal information on publicly viewable webpages, you make that information publicly available and others can collect and use that information. 7.We May Require to Access Your Real Time Location As our app enables the display of users' locations on a map, to help you find users nearby you, and before display your information, we would request for your permission, you have right to reject it and don’t use the feature, if you turn on the location sharing, then keep an eye on unfriendly person and fake information. 8. OUR RIGHTS TO AMEND THIS POLICY We keep our privacy policy under regular review and will post any changes to it on this page. We encourage you to regularly review our privacy policy to ensure you are always aware of what information we collect, how we use it and under what circumstances, if any, we may share it with other parties. We may also contact you from time to time to advise of any changes if we feel such notification is necessary depending on the extent of the changes. We will update the “last updated date” at the top of these terms, and we will inform you by email using the last known email address we hold for you if the changes are material. It is your responsibility to check this privacy policy and terms and conditions regularly. 9. ADDITIONAL PRIVACY PROTECTIONS FOR CHILDREN USING THE INTERNET We do not solicit or target persons younger than legal age for collection of information online. Our Site does not permit children under the age of 18 to become users. By submitting information to us represent that you are over 18 years old. We encourage minors to seek the consent of their parents before providing any information about themselves or their households to anyone on the Internet. We encourage parents to take an active role to protect the privacy and security of their children and to prevent the inappropriate use of information about their children. We support the development of technologies that help parents to control the collection and use of personal information from children who use online services in their households. Please remember there is no tolerance for objectionable content or abusive users. 10. SUBSCRIPTIONS Please note that with all services: • The app is free to download and use but some in-app items will require payment. • Your service payment will be charged to your iTunes account. • Your service will automatically renew and your iTunes account will be charged for renewal 24-hours prior to the end of your current one/three/twelve month subscription period. • You can turn off the auto-renewal of your service through the App Store on your Apple device or through the iTunes store on your computer. Once you turn off auto-renewal, your service will expire at the end of the current service period.
