Privacy Policy

Date updated: 1st of September 2024

First Beat Media Privacy Policy

Welcome to the First Beat Media Privacy Policy (“Policy”)! This explains how we collect, store, protect, and share your information, and with whom we share it. We suggest you read this in conjunction with our Terms of Use.

Whilst you’re enjoying our mobile applications (including the desktop version) (“App”), our websites and microsites or using our digital products and services (together, referred to in this Privacy Policy as our “Sites”), we collect some information about you. In addition, you may choose to use the App or Sites to share information with other users, including your friends and contacts (“Users”). We may also need to share your information sometimes.

The App and Sites are global, and your information will be sent to and used in the United States and the UK regardless of the country you reside in. This Policy explains how we protect your personal data when we transfer it overseas, so please read very carefully!

Who we are

The App and Sites are operated by the “First Beat Media Group” (also referred to in this policy as “we” or “us”) which includes First Beat Media LLC, Beano Publishing LLC, Online Connections Inc., Infinite Connections Inc., Chat Connections Inc., Real Deal Marketing, Dating Media Group, ODS Online Dating Systems LTD, Elite Marketing Solutions Inc., Hello Singles Inc., Dating Ahead Inc., Date Tek Inc., Nearby Connections Inc. and NB Social Inc., all of which are controllers of personal information collected and processed through the First Beat Media App and Sites.

The First Beat Media Group has designated a Data Protection Officer and they can be reached by emailing [email protected] or by post at the following address:

FBM Online Connections Limited
1 Elmfield Park
Bromley
Greater London BR1 1LU, UK

Updates

We reserve the right to update or modify this Privacy Policy at any time and from time to time without prior notice but you might get notification as soon as we update it. That is why we recommend you to review this policy periodically, and especially before you provide any information. This Privacy Policy was last updated on the date indicated above. Your continued use of the Services after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.

Contact Us

The easiest and quickest way to contact us is by using our online contact page.

If you wish to contact us by post, please write to:

Elite Marketing Solutions
Attn: Data Protection Officer
6919 W. Broward Blvd. #270
Plantation, FL 33317

Important info

International Company:
ODS Online Dating Systems LTD
Charges appear as: VendoStore*ODS
Dimokratias 31, 2nd Floor, Office 201
8028 Paphos
CYPRUS

1. COLLECTION OF INFORMATION

Registration Information

When you download the App and create an account (“Account”), we may collect certain information (“Registration Information”) about you, such as:

• Name;
• Username;
• Email address;
• Mobile number;
• Gender identity;
• Date of birth;
• Sexual preference;
• Photographs;
• Location; and
• Login information for social media accounts that you connect (this could include, for example, your Facebook account).

Once you register, you will be able to review and change this information at any time just by logging in to our sites (other than your date of birth and location (which, if you have given us access to your location in your device settings, is automatically updated based on the location of your device)). It is your responsibility to ensure that your account details are kept up to date. If your phone number changes, please ensure that you update this in your account.

For Users who are California residents, the data we may collect falls within the following categories of “personal information”, as defined by the California Consumer Privacy Act (CCPA):

1. Identifiers, such as name and location;
2. Personal information, as defined in the California customer records law, such as contact (including email and telephone number) and financial information;
3. Characteristics of protected classifications under California or federal law (if you choose to provide them), such as age, gender identity, marital status, sexual orientation, race, ancestry, national origin, religion, and medical conditions;
4. Commercial information, such as transaction information and purchase history;
5. Biometric information;
6. Internet or network activity information, such as browsing history and interactions with our Sites and App;
7. Geolocation data, such as mobile device location;
8. Audio, electronic, visual and similar information, such as photos and videos;
9. Professional or employment-related information, such as work history and prior employer;
10. Non-public education information; and
11. Inferences drawn from any of the personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.

Profile Information

We recommend and encourage you (and all our members) to think carefully about the information you disclose about yourself. We also do not recommend that you 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 which is open to abuse and misuse on your profile.

When you post information about yourself or use the messaging function to communicate with other Users, the amount of personal information you share is at your own risk. Please see Section 4 below for more information on who can access what you post on our sites.

Profile Verification Information (Including Biometric Information)

For safety and security and to ensure you have the best possible user experience, we require Users to verify their accounts and might ask for your phone number and, in some instances, we might also ask that you carry out photo verification. We want to make sure you are not a robot! And we also want to avoid fake accounts being created which can be used for malicious activities and cybercrime – they threaten our network and spoil things for everyone. This verification might be required by us for the prevention of fraud. You can also verify your photo on a voluntary basis (to add the blue ‘verified’ badge to your profile).

If you choose to verify your profile photo, we will scan each photo that you submit. The scan may include the use of facial recognition technology so that we can compare the photo you submit to your profile photo, to help ensure that you are who you say you are. We do not add the verification photos to your profile. We retain the scans so that we can verify you in the future and for our record-keeping purposes until we no longer need them for such purposes or for three years after your last interaction with us, whichever occurs first. After the applicable retention period expires, we take commercially reasonable steps to permanently and securely delete the scans from our systems.

Purchases Information

If you decide to purchase any of our premium services, we will process your payment information and retain this securely for the prevention of fraud and for audit/tax purposes.

First Beat Media uses automated decisions to prevent fraudulent payment transactions being processed as part of its anti-fraud procedures. In order to do this, our systems check payment transactions for behavior that indicates breaches of our Terms and Conditions of Use. If a transaction meets certain criteria that demonstrate that the Terms and Conditions of Use are likely to have been breached and the transaction is likely to be fraudulent, the relevant transaction may automatically be blocked. When a transaction is blocked, the user will be notified that their transaction cannot be processed and affected Users can contact our customer support to contest the decision.

Please note that if your account is blocked for any reason, any account(s) that you have on other sites/platforms/applications that belong to us, may also be blocked as part of our anti-spam and anti-fraud procedures.

Geolocation Information for using our Apps

If you have given us access to your location in your device settings, we will collect information about WiFi access points as well as other location information about your longitude and latitude and may save your device’s coordinates to offer certain features to you. This information helps us identify your physical location and we use it to personalize Services and make it easier for you to interact with other Users, by enabling the general locality information to be displayed to Users seeing your profile and showing you the profiles of other Users who are near you.

If you have given us access to your location, but wish to turn this off, you can do so by the following methods:

1. iPhone app — settings, privacy, location services, Name of the app you downloaded
2. Android — settings, location, Name of the app you downloaded, permissions, location

Device Information

We may collect information about your device when you use our services including the unique device identifier, device model, and operating system, for a number of purposes, as set out in this policy. In addition, if you permit us to do so, we may access your device’s address book solely in order to add someone to your contacts.

Links

We may keep track of how you interact with links available on our sites including third party services by redirecting clicks or through other means. We may share aggregate click statistics such as how many times a particular link was clicked on.

Messages

We review the content of messages sent on sites or apps to identify topics, sentiments, and trends across our Users. We will not share the content of User messages or information we derive from them with any third party.

Success Stories, Surveys and other Contributions

From time to time, we run surveys for research purposes and we may contact you to find out if you would like to take part. We may also contact you to find out if you would like to provide feedback, a testimonial or take part in marketing campaigns (for example, if you let us know that you have found a match, we may contact you to ask if you would be happy to feature in advertising). Such surveys and marketing campaigns are optional and more information will be provided at the point of contact. If you do not wish to be contacted to take part in a survey or marketing campaign, please contact our Customer Support Team.

When you Contact Customer Support

If you contact our Customer Support team via our Form, we will receive your email address, and may track your IP address, as well as the information you send to us to help resolve your query. We will keep records of our communications with you, including any complaints that we receive from you about other Users (and from other Users about you) for 5 years after deletion of your account.

Cookies and similar technologies

When you visit our Sites or when you use our App, we may collect personal data from you automatically by using cookies or similar technologies. A cookie is a small file that can be placed on your device or browser that allows us to recognize and remember you.

If you would like to find out more about cookies, including how we use them and what choices are available to you, please refer to our Cookie Policy.

Summary:

The purpose of you joining here is to find new connections with other members, and we can’t help you do that without getting some data both about you and the type of person you are looking for. Also, through your everyday activities on the Site, we will collect further information about your usage and the usage of members around you, in the hopes of creating a match. We will go into some more detail about the data we collect, store, and process below.

Information and data that you give to us:

Personal information. We may collect and store any personal information you enter on our website or provide to us in some other manner. When you create a profile and account, you supply some details that are necessary to uniquely identify yourself and allow you to access the site in future sessions. This includes identifying information, such as your name, date of birth, address, email address, and, if you transact business with us, financial information such as your payment method (for example valid credit card number, type, expiration date or other financial information). We also may request information about your interests and activities, your gender and age, and other demographic information such as your hometown, country etc for better matching possibilities.

Additional information. After creating your profile, you have the option to share additional information about yourself in the hopes of attracting the type of people with whom you wish to match. This data can include your personality, physical appearance, hobbies and interests, and entertainment preferences. You also have the option of adding photos or videos to your profile, sometimes allowing us access to your mobile device to upload them. *Profile pictures are always public and can be accessed by anyone with a direct link. We are using 3rd party CDN (Content delivery network) services that are used to scale site availability and speed. CDN services may cache images for a non defined period of time and images may be publicly available (to anyone even if they are not logged on). By uploading the photos or video(s), you certify that you have the rights on the video(s) and you`re aware that other users might download it. Some of the data you can optionally provide to us may be considered special or sensitive in some jurisdictions, such as your political affiliation, ethnicity, religion or sexual preference. Providing this information is completely optional, and by providing any of it you consent to our processing of this data.

Payment information. If you choose to upgrade your account to Premium status on our website (and not one of our mobile applications), you will need to provide us ( our Internal Payment Processor) or one of our payment service providers with payment data such as your debit/credit card number or other financial data. Sensitive payment data such as this is not stored by us indefinitely, but rather kept with our payment partners, who are fully certified to securely store this information for possible future purchases and rebills.

IMPORTANT: Payment processing for purchases you may determine to make on our Site is carried out by third parties. Each such third party payment processor has its own Privacy Policy and Terms of Use and is not governed by this Policy or our Terms of Use. When you make a purchase, you are submitting your data directly to one of such third party payment processors. As such, prior to submitting your data, you will need to review the Privacy Policy and Terms of Use for the relevant third party payment processor to learn about their data collection and retention policies.

Customer services. If you contact our customer service team, either by our contact form, live chat or phone, a record is kept of your interaction in order to better service your account.

Other information. We store preferences that you supply us for your account settings under Settings, such as which types of email communication you prefer to receive, your billing status and history, which types of members can contact you, and your internal notification feed options. We also keep a record of the last member search you performed as your default search, and you can save specific common searches you want to perform often for your convenience. We store and process your communications with other members, including flirts and messages sent to and from these members. This includes other site communication and connection features, like our Introduction Service and Rapid Match.

Information supplied to us by others:

Social media. It may be possible to use your account data from certain social media sites, like Facebook Login, in order to create a profile and login to our site. You may also optionally share photos from these services to your account here at Site.

Other users. From time to time, we may receive information about you from other users, such as complaints about account abuse or spam. We investigate these matters seriously, and reserve the right to store this data for further use, or to delete it if we find the claims to be baseless. Our Internal Fraud Detection System might keep malicious data for protecting other users from fraudental activities.

Our Partners. Sometimes, our partners will offer to create your profile on our site using information they have about your account on their own site or application. This method of account creation is always done on an explicitly opt-in basis (i.e. you must tell our partner site you want to create a profile on our site or application). We collect, store and process this data with the same security and care we do for data you supply us directly.

Information and data collected as you use the website:

Each time you log in and use our dating service, we collect data and information about your visit.

Automatically. We gather certain information automatically. This includes data like the date and time of your use, how long you spend on the site, the IP address you connected from, and other profiles you visited. This information may include browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, the content of any undeleted cookies that your browser previously accepted from us (see “Cookies” below) and/or clickstream data to analyze trends in the aggregate, and anonymously generated device identifiers and administer the site.

Cookies. We employ the use of technology like cookies, web beacons and pixels in order to recognize you and the devices you use to access our service. We do this for several reasons, including authentication on future visits, keeping track of your preferences and settings, and helping to show you more relevant advertising and offers. Depending on your web browser and other software you have installed, you may be able to better control how we use these technologies. When you visit Site, we may assign your computer one or more cookies, to facilitate access to the Site and to personalize your online experience. Through the use of a cookie, we also may automatically collect information about your online activity on our site, such as the web pages you visit, the links you click, and the searches you conduct on our site. Most browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies. If you choose to decline cookies, please note that you may not be able to sign in or use some of the interactive features offered on Site.

“Do Not Track” (or “DNT”) is a feature on certain web browsers that you may use to access our service, whereby users can activate this setting to tell responding websites they do not wish to be tracked. Not all browsers offer this “DNT” option, and not all of these signals are currently uniform, so our service does not yet respond to these signals.

Other Technologies. We may use standard Internet technology, such as web beacons and other similar technologies, to track your use of our site. We also may include web beacons in advertisements or promotional or other e-mail messages or to determine whether messages have been opened and acted upon. The information we obtain in this manner enables us to customize the services we offer our website visitors to deliver targeted advertisements and to measure the overall effectiveness of our online advertising, content, programming or other activities.

Third Parties. We may allow third-parties, including our authorized service providers, advertising companies, and ad networks, to display advertisements on Site. These companies may use tracking technologies, such as cookies, to collect information about users who view or interact with their advertisements. This information allows them to deliver targeted advertisements and gauge their effectiveness. We employ the use of a data analytics service, specifically Google Analytics, to track certain non-personally identifiable pieces of data about your visits, such as your device type, how you reached the site, your location and browser language. This data is not stored by us, but rather collected using software we have installed on our pages and apps and then stored by this analytics service and used by us to help us improve your experience on our service. If you wish to opt out of making your data available to the Site, please visit THIS page.

How We Use Your Data

We only collect and store data about you that we feel is absolutely necessary. We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:

1. deliver the products and services that you have requested so you can meet your dating goals;
2. manage your account and provide you with customer support;
3. perform research and analysis about your use of, or interest in, our services, or content
4. communicate with you by e-mail, and/ or mobile devices about services that may be of interest to you either from us, or our other companies or third parties;
5. to detect and prevent fraudulent activity on our sites and applications. We use data from all members with an internally developed fraud detection system in order to detect and eliminate bad actors from our service
6. develop and display content and advertising tailored to your interests on our site as well as offers to join trusted partner dating sites quickly and easily through cross-registration;
7. to be sure we are compliant with all legal requirements in all our operating jurisdictions and enforce our terms and conditions. This includes providing law enforcement with information they officially request from our records;
8. to improve our products and services in general so you have the best possible chance to find a perfect match.

IMPORTANT: Your username will be associated with all activities you undertake on the Site including, without limitation, messages sent and other content or information you may determine to post or share. Your gender information helps other users find you. Your gender preference(s) will be used to help identify other users that may be of interest to you. Your IP addresses, device data, and other use information are used by us in order to optimize our site for use. Your usage history may also be used to help our internal algorithm to recommend other Site users to you.

2. USE OF YOUR INFORMATION

In order to deliver an enjoyable experience to you, we may use your Registration and other information to:

1. offer you our services and features;
2. contact you with information about the App (e.g., updates and new features);
3. personalize the App/Sites and the content we deliver to you;
4. conduct research and analytics about how you use and interact with the App/Sites;
5. to test new technologies and processes designed to enhance and improve the App/Sites;
6. resolve disputes, troubleshoot problems and to enforce our Terms & Conditions;
7. investigate fraud, protect our legal rights, and to enforce our Terms & Conditions.
8. to send you information about the promotions and offers we have available (e.g., specify the types of goods/services/offers to be provided via direct marketing) by direct marketing or other modes of communication - if you’ve signed up for our communications or otherwise told us it’s OK. We will not use your information in email direct marketing unless you give us your consent during the Account creating process or via Settings in the App (you can withdraw from marketing at any time via Settings in the App or by using the opt-out mechanisms and links provided in each message); and
9. protect our Users and third parties from harm.

Our Matching Algorithms

We have developed matching algorithms to predict your compatibility with other users and so we can show you people we think are a good match for you. Our matching algorithms use the following data about you to predict your compatibility with others and generate profile recommendations: the things you tell us about yourself in your profile; information about your activity and your device coordinates, which are necessary to understand your proximity to other members. The legal basis for processing profile and proximity information is that this is necessary for the provision of our contractual services to you pursuant to Article 6(1)(b) GDPR. Where we process information about your activity, this is based on our legitimate interests pursuant to Article 6(1)(f) GDPR, and specifically our legitimate interest in generating more personalized and relevant recommendations for who you can match with. If you have chosen to include sensitive information in your profile, such as information about your beliefs, the processing of this information is based on your voluntary and explicit consent.

Moderation Practices

We use a combination of automated systems and a team of moderators to monitor and review accounts (including photos and any other information uploaded onto user profiles) and messages for content that indicates breaches of our Terms and Conditions of Use. If an account or message meets certain criteria that demonstrate that the Terms and Conditions of Use are likely to have been breached, the relevant account will be subject to a warning and the user’s access restricted and/or blocked.

If you post anything that is inconsistent with our Terms and Conditions of Use, we reserve the right to terminate or restrict access to your Account.

Lawful Basis

Under EU and UK data protection laws, we are required to tell you our lawful basis for using your data and we have set this out in the table below. Where the legal basis is consent, you can withdraw consent at any time. Where the legal basis is legitimate interests, you have a right to object to our use of your data. We explain in the relevant sections in this Policy how you can withdraw consent or opt-out of certain data uses (where applicable).

 

Purpose for which data is used	Data	Source	Legal basis
To provide you with the social networking service	Name, email address, date of birth, location (CCPA Categories A and B)	You provide your name, email address and date of birth to us. We obtain location data from the device that you use to access the service	Contractual necessity
To facilitate networking opportunities and cross sites	Optional information that you choose to provide in your profile, including through profile verification, which may include information about your sexual preferences, non-binary gender, religion, ethnic background, photos, interests, etc. (CCPA Categories B, C, H, I, J)	You provide this information to us	Contractual necessity and our legitimate interests – it is in our legitimate interests to facilitate networking opportunities.
To verify your identity and prevent fraud and to ensure the safety and security of Users	Phone number and if requested or permitted, photo provided as part of profile verification and for users based in countries where age verification is required by law: photo of Government ID + geolocation and device information (CCPA Categories A, B, C, E, F, G and H)	You provide this information to us, except for the geolocation and device information, which we obtain from the device that you use to access the service	Legitimate interests – it is in our legitimate interests to ensure that accounts are not set up fraudulently and to safeguard Users of the site
To take payment for premium services (not applicable for Users making payments via the Apple App Store)	Payment card details (CCPA Categories B and D)	You provide this information to us	Contractual necessity
To send you marketing information about our events, offers and services	Name, email address, postal address, and mobile phone number (CCPA Categories A and B)	You provide this information to us	Consent or legitimate interests and in accordance with the laws applying to our marketing activities. We have a legitimate interest in promoting our business and products
To carry out research and analysis to help us improve and to test new technologies and processes designed to enhance and improve the App/Sites	Log and usage data, including IP address, browser type, referring domain, pages accessed, mobile carrier and search terms, images and video, registration information, profile information (CCPA Categories A, F and H)	You provide photos and videos to us. We obtain the log and usage information from the device that you use to access the service	Legitimate interests – it is in our legitimate interests to analyze the way in which Users are accessing and using our services and to test new technologies so that we can further develop our features, implement security measures and improve the service
To respond to correspondence and queries that you submit to us, including social media queries	Email address and IP address, social media name, phone number (CCPA Categories B and F)	You provide your email address, social media name and phone number to us when you contact us and we obtain your IP address from the device that you use to contact us	Legitimate interests – it is in our legitimate interests to respond to your queries to ensure that we provide a good service to Users and troubleshoot problems
To investigate and block Users for reported infringements of our Terms and Conditions of Use	Name and user registration details, profile information, content of messages and photographs + usage and device data such as IP address and IP session information (CCPA Categories A, B, C, F, and H)	You provide your registration details, profile information, messages and photographs to us. We obtain the other information from the device that you use to access the service.	Legitimate interests - it is in our legitimate interests to prevent unauthorized behavior and to maintain the safety and integrity of our services
To enable Users to create and enhance their profile and log via third party accounts	Data from Facebook and other third-party accounts (CCPA Categories A, B, C, and H)	We obtain this information from Facebook, or the providers of any other accounts you use to log in or connect with your account	Legitimate interests – it is in our legitimate interests to facilitate access to our services
To block payment transactions as part of our anti-fraud procedures	Name, IP address, email address, mobile number, cardholder name, payments received, type of payment, user ID, country (CCPA Categories, A, B, and D)	You provide your name, email address, mobile number and card details to us. We obtain your IP address from the device that you use to contact us. We obtain your payment information from your interactions with our service	Legitimate interests – it is in our legitimate interests to prevent fraudulent transactions and to maintain the security of our services
To serve promo cards and advertisements on the App	Location, gender, age, and information that you have optionally provided us with via your profile (CCPA Categories A, C and G)	We obtain age, gender and profile information from you, and location data from the device that you use to access the service	Legitimate interests – it is in our legitimate interests to target advertisements so that Users see relevant advertisements and to allow us to generate income from advertising revenue
To serve advertisements on third party networks and measure the effectiveness of such ads	Data about your visit to our Sites or App and action taken on those (for example if you downloaded our App or created an account on websites), IP address (and your estimated location based on your IP address), age and gender, device ID (CCPA Categories B, C, G, F and K)	We obtain age and gender from you and we obtain other information from the device or browser that you use to access the service	Consent – as indicated by you in your Privacy Settings/Cookies Settings preferences and via your browser or device privacy preferences (where required by your device manufacturer, for example Apple devices using iOS 14.5).
To contact you in order to run surveys for research purposes and to obtain feedback, and to find out if you want to take part in marketing campaigns	Email address and cell phone number (CCPA Category B)	You provide this information to us	Legitimate interests – it is in our legitimate interests to carry out research so that we can further develop the app and improve the service
To enable video and audio call functions on apps, and the sending of images and video	Video and audio call usage data, images and video (CCPA Categories F and H)	We obtain this information from the device that you use to access the service	Legitimate interests – it is in our legitimate interests to provide these functionalities as part of the services
To defend legal claims, protect legal rights and to protect people from harm	This could include any information that is relevant to the issue	This information may be obtained directly from you, from your device or from third parties, depending on the information involved

Summary:

We only collect and store data about you that we feel is absolutely necessary. We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:

1. deliver the products and services that you have requested so you can meet your dating goals;
2. manage your account and provide you with customer support;
3. perform research and analysis about your use of, or interest in, our services, or content
4. communicate with you by email, and/ or mobile devices about services that may be of interest to you either from us, or our other companies or third parties;
5. to detect and prevent fraudulent activity on our sites and applications. We use data from all members with an internally developed fraud detection system in order to detect and eliminate bad actors from our service
6. develop and display content and advertising tailored to your interests on our site as well as offers to join trusted partner dating sites quickly and easily through cross-registration;
7. to be sure we are compliant with all legal requirements in all our operating jurisdictions and enforce our terms and conditions. This includes providing law enforcement with information they officially request from our records;
8. to improve our products and services in general so you have the best possible chance to find a perfect match.

IMPORTANT: Your username will be associated with all activities you undertake on the Site including, without limitation, messages sent and other content or information you may determine to post or share. Your gender information help other users find you. Your gender preference(s) will be used to help identify other users that may be of interest to you. Your IP addresses, device data, and other use information are used by us in order to optimize our site for use. Your usage history may also be used to help our internal algorithm to recommend other Site users to you.

Who has access to information about you

When we store information in our own systems, only the people who need it have access. Our management team has access to everything you’ve provided, but individual employees have access to only what they need to do their job.

How we share data and information with other partners, including third parties.

First and foremost, by creating your profile and sharing information about yourself, you are in turn sharing that information with other users on the Site. As we cannot control what other users do with the data you share, please only add information to your profile that you are comfortable sharing with the public. In your Contact Preferences on the Site, you will find options to limit which members can and cannot send you messages.

• Sensitive personal data like your supplied gender will help other users find you. Your gender seeking preference(s) will be used to help identify other users that may be of interest to you.
• Sometimes it is necessary to share data with trusted third-party service providers and vendors to provide you better services. Some examples of this would be our payment service providers, in order to facilitate payments for Premium access, and our email validation service, which lets us know if you provided us with a valid email address. We will never sell your personal data to a third party under any circumstances. We take much care in ensuring that our few data partners follow best practices for safeguarding data, and encourage you to reach out to our customer team if you have any questions regarding this.
• In some cases, we make your profile visible on other brands within our network of dating websites and applications (our Community). These are simply brand extensions of the Site, with the same database of users on each of these other websites and applications. This is only done for marketing purposes, usually to account for differences in terminology for certain interests in different locations.
• With your explicit permission, we will sometimes share the information you have provided us with other websites or applications that are wholly owned by our company, in order to set up a profile on that website or application for you. This is to give you the best possible chance to make a meaningful connection and enlarge your dating pool in other similar-niche websites and applications. It is enabled through cross registration process. We ONLY do this with your express consent and instruction, such as when you opt-in at the time of profile creation, or when you choose to upgrade your membership.
• We use internal service providers which sometimes pass your account data. Some examples of this would be our internal fraud detection system, which helps to eliminate bad actors on our network of websites and applications, and our internal ad serving system, which uses your demographic and interest data to show you relevant advertisements on the service. We also send anonymized data (encrypted email addresses) to our ad server to provide you better services and more options in finding your perfect match. In all these cases, this data is completely retained within the company and safeguarded with the same high level of care your data is on the Site.
• If we are ever involved in a merger or sale, control of your data may transfer to a new company or website. This will be fully disclosed to you in advance if this situation occurs. You will be notified via email.
• We reserve the right to share any and all account information with law enforcement or agencies authorized by applicable governmental authorities either in response to their written request or at our own election should we believe, in our sole discretion, that you or your account may be involved with illegal activity, or if we believe, in our sole discretion, that such disclosure is necessary to protect the rights or property of the Site, our users, and/or one or more third parties.
• Sometimes, it may become necessary to share data if that disclosure could mitigate our liability in a lawsuit, either filed or threatened. This could also happen if we need to protect the legal rights of either ourselves or of our users, or to investigate or take action regarding perceived illegal activity or fraud.

IMPORTANT: The Service and Site are not the only social connection platforms that we operate. In order to increase your opportunity for a connection, as a default, your profile on the Service will be shared with our social connection platforms as a default to increase your opportunity to meet someone. You may opt out of this sharing at any time by changing your settings under “my account” - Data Panel.

Email Preferences and Promotional Notifications

An important part of your membership is being notified of specific triggered events and special promotions that will maximize your chances of a successful dating experience on the website. We use an internal email marketing system to send you these notifications as part of your membership.

• Some examples of triggered events would be notification of a matching member coming online in your area, or a nearby match uploading a new photo, or photo request. In these cases, your personal information is used to match with others to generate these events and send you an email notification. You will also receive our matching mails, flirts, private messages, non-promotional offers, abandoned mailers, icebreakers etc which are part of our dating platform strategy so you can find what you looking for faster and easier.
• Examples of special promotional emails may be a special introductory monthly offer at a steeply discounted price, or a discounted trial offer based on an action you previously attempted that requires Premium membership. The type of promotion sent determines which personal information is processed to generate the email.
• You can select exactly what kind of emails you want to receive from us at any time inside your Email Options. We store your preferences there until you tell us you want to change them again. Also, you can choose to stop receiving all emails from us by using the Unsubscribe link that is embedded in every email that we send you.
• At any time you can choose to no longer receive commercial or promotional emails from us. You will be given the opportunity, in any commercial e-mail that we send to you, to opt out of receiving such messages in the future. It may take up to 10 days for us to process an opt-out request. We may send you other types of transactional and relationship e-mail communications, such as service announcements, administrative notices, and account information, without offering you the opportunity to opt out of receiving them. Please note that changing information in your account, or otherwise opting out of receipt of promotional email communications will only affect future activities or communications from us. If we have already provided your information to a third party (such as a service provider) before you have changed your preferences or updated your information, you may have to change your email preferences directly with that third party.

Transferring Your Data

We provide our online dating services around the world. By using Site, you authorize us to transfer and store your information outside your home country, including in the United States, for the purposes described in this policy. The privacy protections and the rights of authorities to access your information in these countries may not be the same as in your home country.

As we operate in many different countries, sometimes data needs to be transferred across borders, such as when a citizen of the European Union joins a site that we operate from the United States. We have worked to become compliant with the new EU General Data Protection Regulation (GDPR) in this situation, and as such use suitable safeguards for the transmission of this data.

3. DISCLOSURE OF INFORMATION.

Our policy is to not disclose your Registration Information or personal data, except in the limited circumstances described here:

Circumstances where data may be disclosed	Disclosed data
Service Providers – We engage certain trusted third parties to perform functions and provide services to us. We may share your Registration Information or personal data with these third parties, but only for the purposes of performing these functions and providing such services. More information about this is available directly below.	This could include all data, including all CCPA Categories listed above
Moderators – To monitor activity on the App and websites and approve content.	Name and user registration details, profile information, content of messages and photographs (CCPA Categories A, B, C, and H)
Payment Processing and Telecommunications Companies – To facilitate payments for our premium services.	Cardholder name, cardholder address, card number, payment amount, transaction date/time (CCPA Categories A, B, and D)
Law and Harm – As we mentioned in the Terms and Conditions, we think it is very important that all Users behave whilst using the App and Websites. We will cooperate with all third parties to enforce their intellectual property or other rights. We will cooperate with lawfully made law enforcement requests for information from within or outside your country of residence where we are required to by law. This may include where there is an investigation into alleged criminal behavior or to protect the vital interests of a person. We may preserve or disclose any of your information, including your Registration Information, if we believe in good faith that it is necessary to comply with a law or regulation, or when we believe in good faith that disclosure is necessary: to comply with a binding direction court order, or lawful request; to protect the safety of any person; to address fraud, security or technical issues e.g. through anti-spam providers to protect the service from criminal activity; or to protect our rights or property or those of third parties. In such cases we may raise or waive any legal objection or right available to us.	This could include any personal data that We hold about you, depending on the nature of the request or the issue that we are dealing with, including all CCPA Categories listed above
Business Transfers – In the event that a Company Group entity or any of its affiliates undergoes a business transition or change of ownership, such as a merger, acquisition by another company, re-organization, or sale of all or a portion of its assets, or in the event of insolvency or administration, we may be required to disclose your personal data.	This could include all personal data that We hold about you, including all CCPA Categories listed above
Marketing Services Providers – To help us serve marketing and advertising on third party websites and applications and measure the effectiveness of our advertising campaigns. More information on this is available below	Advertising identifier associated with your device (Device ID), estimated location (based on your IP address), age, gender and data about your visit to our Sites or App and action taken on those (for example if you downloaded our App or created an account with our App), hashed email address (for ‘custom audiences’ only) (CCPA Categories B, C, G, F and K)
Anti-Spam and Anti-Fraud – Your data may be shared with other Company Group companies, for example, to block accounts and suspected fraudulent payment transactions as part of our anti-spam and anti-fraud procedures.	Email address, phone number, IP address and IP session information, social network ID, username, user agent string, and transaction and payment data (CCPA Categories B, F and D).

Aggregated Information – We may share aggregated information with third parties that includes your personal data (but which doesn’t identify you directly) together with other information including log data for industry analysis and demographic profiling.)

MORE INFORMATION ABOUT DISCLOSURES

Service Providers

We engage certain trusted third parties to perform functions and provide services to us (“Service Providers”). The suppliers with which We share User personal data vary depending on a variety of factors, such as which of our App, Sites and services a User engages with. For example, to provide our services to Users, we typically use the following suppliers:

• Billing services – to allow customers to purchase paid features of our App (for example, Google Play)
• Authentication services – to allow customers to authenticate their account
• Social media providers – to allow customers to create/connect their account with their account(s) on such platforms (for example Facebook)
• Product improvement and market research – we use third party platforms and agencies to carry out customer surveys and market research to improve our products and services
• IT services – some of the third-party software providers used in the operation of our business may process Users’ personal data

Marketing Services Providers

We partner with providers of marketing services (such as Facebook for example) (‘Marketing Services Providers’) to help us market and advertise our App and services on third party websites and applications and measure the effectiveness of our advertising campaigns.

We share a limited amount of your personal data with these Marketing Services Providers, such as:

• the advertising identifier associated with your device (this is a random number assigned by your mobile device manufacturer (for example Apple or Google) to your device to help advertisers (including the manufacturer) know when an ad has been viewed or clicked in an app, and when an ad causes a ‘conversion’ (for example, downloading the app advertised to you))
• your estimated location (based on your IP address)
• age and gender
• data about your visit to our Sites or App and action taken on those (for example if you downloaded our App or created an account with our App)

Facebook

Where we share data with Facebook as our Marketing Service Provider (including via the Facebook “Like” function), we are Joint Data Controllers with Facebook Ireland for this processing. This arrangement means that We have to provide you this notice, but you should contact Facebook if you wish to exercise your data protection rights. Further information, including how Facebook enables you to exercise your data protection rights, and subsequently processes your information as independent data controller can be found in Facebook Ireland’s Data Policy.

This data referred to above can include actions that you take on our website such as your interactions with our Sites or other information collected from cookies or similar technologies including the Facebook pixel. This allows us to measure the effectiveness of our advertising, improve our marketing practices, and helps us deliver more relevant advertising to you and people like you (including on social media such as Facebook).

4. WHAT OTHERS MAY SEE ABOUT YOU

We think our Users are awesome, and we want you to share how awesome you are with the world, so we have built certain features to enable this. Our App is designed to make it easier for you to connect with other Users and to interact with them.

When using our Apps, you should assume that anything you post or submit on the Apps may be publicly-viewable and accessible, both by Users and non-users of the App. We want our Users to be careful about posting information that may eventually be made public.

Please be careful about posting sensitive details about yourself on your profile such as your religious denomination and health details. You may also choose to add sensitive information about yourself, such as your religion and political leanings. While you may voluntarily provide this information to us when you create your profile, including your sexual preferences, there is no requirement to do so. Please remember that photographs that you post may reveal information about yourself as well.

Important: When you upload and choose to tell us sensitive information about yourself, you are explicitly consenting to our processing of this information and making it public to other Users.

Your profile and other information you make available via the Sites or Apps, including certain information added to your profile through third party accounts (such as Facebook), may be viewed and shared by Users with individuals who may or may not be users of the Apps or Sites. For example, a User may recommend you as a match to his or her Facebook friend(s) by taking a screenshot of your profile picture and sharing it, regardless of whether such friend(s) is also a User of our Sites or Apps.

Please also note that in certain countries (currently, South Korea only), Users are provided with functionality enabling them to download a copy of their conversation history (as this is required by local laws) and that We have no control over how users may then publish or use that information.

If you log in to or access the Sites or Apps through your Facebook account or another third-party account on a device which you share with others, remember to log out of our Apps and Sites and the relevant third-party account when you leave the device in order to prevent other users from accessing your account.

5. OUR POLICY TOWARDS AGE

Although we want as many people as possible to enjoy our creation, you have to be at least 18 years old to use the App or Sites.

We do not knowingly collect any information about or market to children, minors or anyone under the age of 18. If you are less than 18 years old, we request that you do not submit information to us. If we become aware that a child, minor or anyone under the age of 18 has registered with us and provided us with personal information, we will take steps to terminate that person’s registration.

6. SECURITY

We pride ourselves on taking all appropriate security measures to help protect your information against loss, misuse and unauthorized access, or disclosure. We use reasonable security measures to safeguard the confidentiality of your personal information such as secured servers using firewalls.

Unfortunately, no website or Internet transmission is ever completely 100% secure and even we cannot guarantee that unauthorized access, hacking, data loss or other breaches will never occur, but here are some handy tips to help keep your data secure:

• Please make sure you log out of your Account after use as you never know who may stumble onto your Account!
• Please don’t share the password you use to access your Account with anyone else!
• Change your password periodically.

If you ever think someone has had access to your password or Account, please contact our Customer Support immediately. We cannot guarantee the security of your personal data while it is being transmitted to our site and any transmission is at your own risk.

Protection for your personal data and information

Protecting the data that you entrust to us is extremely important, and we are constantly striving to ensure that it is safeguarded from harm at all times. However, like at any technology company, there is always risk of unauthorized access or destruction of this data. We employ both security experts and automated protocols that are constantly analyzing our systems for any signs of intrusion or attack, and have processes in place in case of any unauthorized access, including those mandated by certain jurisdictions (such as the EU in the case of the aforementioned GDPR). At our discretion, we may suspend usage of the site pending investigation into a suspected breach. We also encourage you to reach out to our customer team immediately if you feel that you or any other account on the site has been compromised.

Notice of Breach of Security.If a security breach causes an unauthorized intrusion into our system that affects you and your personal data, we will notify you as soon as possible and later report the action we took in response.

Your Password. It is vital that you keep your password safe to prevent unauthorized access to your personal information. If you believe that someone else may have access to your password please change it immediately. Please note that your password is stored securely in an encrypted format and is never visible to our staff.

Location based services. Where we provide services that utilize your device’s location, we may permit other users of the service to block individuals in certain locations, based upon their IP, from accessing such users’ content.

7. YOUR RIGHTS REGARDING YOUR DATA

Your rights regarding your data includes compliance to GDPR (General Data Protection Regulation) which you can access on this link: https://gdpr-info.eu/

The data that we collect, store and process with regards to your account is your own, and as such you have associated rights regarding that information as detailed below. All options are available in editing of My Account that you can visit THIS page.

• You have the right to add, modify or delete data any time you want. You are the boss of your account. This will enable you to tailor exactly what others see about you at any time.
• You have the right to download an export of all the information we are currently storing in relation to your account.
• You have the right to configure your device settings to allow the level of access to your data that you choose, from the configuration options available on your specific device(s), browsers, etc. Please note that some configurations may not allow you full access to all our site features.
• You typically have the right to fully delete your information from our site and database permanently, barring a few extenuating conditions.
• In some countries and jurisdictions, including the EU, you have the right to lodge an official complaint with an applicable data protection authority. Please consult the data protection rules of your country of residence for more information about the availability of this option.

The particular rights which are applicable to you (which might include other rights not listed above) may vary depending on your country. You should make yourself aware of the rights you have under applicable privacy laws in your country.

If you want to exercise any of your rights listed above use the Form shared at the beginning of this document or email our Data Protection Officer at [email protected]. You can also contact us by post at the addresses shared in Intro. For your protection and the protection of all of our Users, we may need to request specific information from you to help us confirm your identity before we can answer the above requests.

If you have a concern about how we have processed your request or your personal data, you should contact us in the first instance via the contact details listed above.

Your CCPA Rights (USA)

For Users who are California residents, you have the following rights (in addition to those listed at section 10 below) under the California Consumer Privacy Act (CCPA), and you have the right to be free from unlawful discrimination for exercising your rights under the Act:

1. You have the right to request that we disclose certain information to you and explain how we have collected, used and shared your personal information over the past 12 months.
2. You have the right to request that we delete your personal information that we collected from you, subject to certain exceptions.

California’s “Shine the Light” law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the businesses’ practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes.

From time to time, as part of a joint promotion with a third party, we may, if you participate in such a promotion, disclose your contact information to the third party to allow them to market their products or services to you. Where this is a condition for participation in a promotion, we will always let you know before you enter the promotion. Please follow the instructions provided to you by third parties to unsubscribe from their messages.

In addition, under California law, operators of online services are required to disclose how they respond to “do not track” signals or other similar mechanisms that provide consumers the ability to exercise choice regarding the collection of personal information of a consumer over time and across third party online services, to the extent the operator engages in that collection. At this time, we do not track our Users’ personal information over time and across third-party online services. This law also requires operators of online services to disclose whether third parties may collect personal information about their users’ online activities over time and across different online services when the users use the operator’s service.

California residents are entitled to disclose a list of third parties to whom their data has been shared for direct marketing purposes over the previous year. Currently, we do not share any customer data with third parties for direct marketing purposes. If that policy were to change, we will update this section with information on how to obtain that information.

Personal Information Sales Opt-Out and Opt-In Rights. You have the right to direct us to not sell your personal information at any time (the right to opt out). Consumers who opt-in to personal information sales may opt-out of future sales at any time. To exercise the right to opt-out you may submit a request to us by reaching out to our Customer Support by email or via phone 954-944-9054. If your location on profile matches California, you will be able to see in the Website Footer Do Not Sell My Personal Information link that will lead you to the requested page. Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back into personal information sales and personalized ads at any time by editing preferences on your data panel. You don’t need to create an account with us to exercise your opt-out rights. We will use personal information provided to us to review and comply with the request.

In some cases, we may be unable to fulfill your request because we have no way to verify your identity to the standard the law and/or its associated regulations require. For example (but without limitation), if you have visited our website, but never registered, left a comment, submitted a Contact Form, completed a financial transaction with us, or interacted with us via email or other means, we probably do not have enough information to confirm your identity to even a “reasonable degree of certainty” (as the applicable regulations may define that term). Also, in addition to any other exemptions applicable law and/or regulation may provide to your rights under the CCPA (particularly with regard to the deletion of your personal information), we may be unable to delete certain information (e.g., our web host’s server, caching and error logs) for technical reasons.

Your VCDPA Rights (USA)

The Virginia Consumer Data Protection Act (“VCDPA”) went into effect on January 1, 2023. This new law provides Virginia residents certain rights for personal data collected by businesses under conditions outlined in the law.

For more information, you can access the official document on the following link: https://www.oag.state.va.us/consumer-protection/files/tips-and-info/Virginia-Consumer-Data-Protection-Act-Summary-2-2-23.pdf

Our status under the VCDPA as either a controller or processor will be the same as under the GDPR. The VCDPA terms are incorporated into our existing data protection terms, so no action is required to accept the VCDPA terms where the existing data protection terms already form part of your consent.

Your CPA Rights (USA)

The CPA grants Colorado Consumers new rights with respect to their personal data, including the right to access, delete, and correct their personal data as well as the right to opt out of the sale of their personal data or its use for targeted advertising or certain kinds of profiling.

For more information, you can access the official document on the following link: https://leg.colorado.gov/bills/sb21-190

Our status under the CPA as either a controller or processor will be the same as under the GDPR. The CPA terms are incorporated into our existing data protection terms, so no action is required to accept the CPA terms where the existing data protection terms already form part of your consent.

Your CTDPA Rights (USA)

The CTDPA gives Connecticut residents certain rights over their personal data and establishes responsibilities and privacy protection standards for data controllers that process personal data.

For more information, you can access the official document on the following link: https://portal.ct.gov/AG/Sections/Privacy/The-Connecticut-Data-Privacy-Act

Our status under the CTDPA as either a controller or processor will be the same as under the GDPR. The CTDPA terms are incorporated into our existing data protection terms, so no action is required to accept the CTDPA terms where the existing data protection terms already form part of your consent.

Your UCPA Rights (USA)

The Utah Consumer Privacy Act is the fourth state-level privacy law passed in the United States and is considered the most “business-friendly”. Utah`s privacy law is unique in that controllers don`t need to obtain opt-in consent to collect and process sensitive data. Instead, they`re required to provide a clear notice and an opportunity to opt-out.

For more information, you can access the official document on the following link: https://le.utah.gov/~2022/bills/static/SB0227.html

Your LGPD rights (Brazil)

The Lei Geral de Proteção de Dados (LGPD) is a new Brazilian privacy law that went into effect from August 16th, 2020. It applies to the processing of personal data, which can include online identifiers, of users located in Brazil. We are committed to supporting our partners as they work to comply with this regulation. The LGPD shares many concepts with the European General Data Protection Regulation (GDPR) and our services already provide features that customers can use to support their LGPD compliance efforts, including the ability to serve non-personalized ads to users regarding data processing based on a user`s geographic location.

For more information, you can access the official website of LGPD: https://lgpd-brazil.info/

Our status under the LGPD as either a controller or processor will be the same as under the GDPR. The LGPD terms are incorporated into our existing data protection terms, so no action is required to accept the LGPD terms where the existing data protection terms already form part of your consent.

Your POPIA rights (South Africa)

“POPIA” means the Protection of Personal Information Act 4 of 2013 of the Republic of South Africa that empowers citizens with enforceable rights over their personal information, requires websites, companies and organizations to live up to minimum conditions for lawful processing, and establishes the Information Regulator to supervise and enforce compliance with POPIA. It is similar to GDPR and shares most of the principles. Our processing of your Personal Information is subject to, and in compliance with, the provisions of POPIA.

You may access a copy of POPIA on the Information Regulator’s website, which, at the time of publication of this Privacy Policy, is at http://www.justice.gov.za/inforeg/

Our status under POPIA as either a controller or processor will be the same as under the GDPR. The POPI terms are incorporated into our existing data protection terms, so no action is required to accept the POPI terms where the existing data protection terms already form part of your consent.

8. DATA RETENTION AND DELETION.

We keep your personal information only as long as we need it for the legal basis relied upon and as permitted by applicable law.

When your Account is deleted, we make sure it is no longer viewable on our Admin DataBase and Sites/Apps, unless:

1. we must keep it to comply with applicable law (for instance, if you make purchases within the Sites/Apps, some personal data may be kept for tax and accounting purposes);
2. we must keep it to evidence our compliance with applicable law (for example, if an account is blocked, we keep some account information and a record of the behavior that led to the block - this information is retained for evidential purposes in case of queries or legal claims concerning the block);
3. there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or
4. 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 to prevent a user who was banned for unsafe behavior or security incidents from opening a new account).

We keep your information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and used it and/or as required to comply with applicable laws. Dating and relationships are a personal exercise for each person, and as such people tend to use our dating site at different times throughout their dating lives. For your convenience, we retain your personal information until such time as you advise us to discontinue doing so. This data will also be retained to service your account, develop new services and products related to the Service, and as otherwise provided in this Policy. Our data retention policy may be amended from time to time.

Your account can be deleted permanently if you make a request or choose that option in the data panel. This is also known as a “right to be forgotten”. Please be advised that in some instances, such as compliance with applicable laws, or in order to police fraud on our site more effectively, we may not be able to completely comply with your request. We will advise you upon your request if this is the case, and let you know the reason we cannot fully comply, as well as which data points we will need to retain. Please also note that while data may be fully and permanently erased from production (live) servers quickly, you should allow up to 30 days for data stored on backup servers to be fully deleted.

Warning: Even after you remove information from your profile or delete your Account, copies of that information may still be viewable and/or accessed to the extent such information has been previously shared with others, or copied or stored by others. 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.

AMENDMENTS TO THIS POLICY

Wow, if you have reached this part, we are amazed! Last but not least, we want to inform you that we reserve to amend, update or modify this Privacy Policy at any time by publishing it on the website and without any further notice to you. Any such amendment will be effective immediately upon publication on the website. We respect your Privacy and we are committed to protecting the privacy of the users of this website. A summary of how this personal information will be used is set out in this privacy policy and we seek to use our best endeavors when it comes to the collection and processing of personal information.

Thank you and HAPPY DATING!