Last Revised: October 15, 2019
1. PERSONAL INFORMATION WE COLLECT
1.1 Personal Data. "Personal Data" is information that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. Personal Data is required when you use the register or create an Account; purchase merchandise; request information from us; sign up for e-mails or otherwise communicate with us. We may also connect Personal Data you provide by interacting with us through social media or other forums.
1.3 Special Categories. We collect Special Categories of Personal Data about you (which may include details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, and information about your health).
2. HOW WE USE YOUR PERSONAL DATA
We will only use the details collected from you:
(a) To manage your Account;
(b) To provide you with our services, including customer services;
(c) To maintain our services (including security, troubleshooting, testing, system maintenance, support, reporting, hosting of data, and blocking users);
(d) To improve your match experience on our services, such as mutual match, recommendations, reverse match, etc.;
(e) To contact you including sending information and updates relating to our services, questions or requests and/or for the provision of customer services;
(f) To use data analytics to improve user relationships and experiences.
3. CATEGORIES AND PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
3.1 Data Categories
(i) Account Data, including your phone number, username, and password.
(ii) Contact Data, including billing address, email address and telephone numbers.
(iii) Payment Data, including payment card/account details, account verification data and transaction data.
(iv) Technical Data, including internet protocol (IP) address, your login data, device IDs, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Service.
(v) Profile Data, including your first name, last name, marital status, age, gender, other information and preferences you decide to add to your profile, including financial data and Special Categories of Personal Data, blog posts, photos used in connection with your Account, and information you provide in relation to specific services you request, such as Certified Millionaires and photograph verification.
3.2 Purpose for use.
We use your Personal Data for the following purposes:
We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
Please note that we may process your personal data without your knowledge or consent where this is required by law.
5. WHO WE SHARE YOUR DATA WITH
We share your Personal Data as follows:
(a) Service Providers. We may share your information with third-party service providers that provide business, professional, or technical support functions that make products, our Service available to you.
(b) Third-Parties. We do not share Personal Data with third-parties for their direct marketing purposes without your permission. We may share information about you with your financial service provider in order to verify and make transactions and refunds. Finally, our services consist of making your profile data available to other users of our services in order to find Matches.
(c) Legal Matters; Safety. We may access and disclose your information to respond to subpoenas, judicial processes, or government requests and investigations, or regarding an investigation on matters related to public safety, as permitted by law, or otherwise as required by law. We may disclose your information to protect the security of our Service including our servers, network systems, and databases. We also may disclose your information as necessary, if we believe that there has been a violation of our Agreement, any other legal document or contract related to our Service, or the rights of any third-party.
(d) Sale or Transfer of Business or Assets. We may sell or purchase assets during the normal course of our business. If another entity acquires us or any of our assets, the information we have collected about you may be transferred to such entity. In addition, if any bankruptcy or reorganization proceeding is brought by or against us, such information may be considered an asset of ours and may be sold or transferred to third-parties.
(e) Marketing Statistics and Analytics. We may share Aggregate Data, anonymous, or de-identified data with third-parties for their marketing or analytics uses.
(f) Our Affiliates. We may share information of blocked users with affiliated dating websites for testing purposes related to fraud prevention.
6. OUR COMMITMENT TO DATA SECURITY
To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect online. We regularly monitor our systems for possible attacks and vulnerabilities, but we can’t warrant the security of the data you send us even with the safeguards we have put in place.
We maintain (and requires our subcontractors and service providers to maintain) appropriate organizational and technical measures designed to protect the security and confidentiality of any information we process. However, no organizational or technical measures are 100% secure so you should take care when disclosing information online and act reasonably to protect yourself online.
7. YOUR CHOICES
You have the following choices regarding your Personal Data. To protect your privacy and security, we may take reasonable steps to verify your identity before any request for access or alteration of your Personal Data.
(a) How You Can Access or Correct Your Information. You can access a variety of your personally identifiable information that we collect online and maintain it either online, or by contacting our customer service representatives via the e-mail address in the Contacting Us section below. We use this procedure to better safeguard your information. You can correct factual errors in your personally identifiable information by sending us a request that credibly shows error.
(b) How You Can Cancel Your Account. You can ask us to cancel your Account at any time using the "cancel account" feature. When you ask us to cancel your account, we will remove it from our Service and it will no longer be viewable by other users or the public. Upon Account cancellation, you will be able to reactivate your account within two years, after which your Personal Data will be destroyed and/or anonymized.
(c) How You Can Request for Your Information To Be Deleted. You can ask us to delete your personal data at any time using the "delete my account and data" feature (provided it is no longer necessary for legal purposes or to provide services to you). You may also place a request by contacting our privacy team via e-mail at the e-mail address in the Contacting Us section below. We will delete and/or anonymize all your Personal Data we are not legally required to maintain within 30 days. IF YOU REQUEST YOUR PERSONAL DATA BE DELETED, ANY OUTSTANDING ORDER OR TRANSACTION WILL BE IRREVOCABLY TERMINATED AND YOU WILL NOT BE ABLE TO RESTORE YOUR ACCOUNT OR RETRIEVE YOUR PERSONAL DATA UPON DELETION.
(d) Opting out
(i) E-mail. Any subscription to various marketing e-mails can be cancelled by clicking the "unsubscribe" links in the e-mails, changing preferences in the "Your Account" area online, or sending a request to the e-mail address in the Contacting Us section below.
(ii) Location data. You can disable our collection of location data by changing the settings on your device.
8. INTERNATIONAL TRANSFERS OF INFORMATION
For users in the European Economic Area ("EEA"), Personal Data collected in the EEA may be transferred, stored and processed by us and our services providers in the United States and other countries whose data protection laws may be different than the laws of your country. These transfers are required to provide our services and to perform the agreement with you.
Please contact us at the e-mail address in the Contacting Us section below if you want further information on the specific mechanism used by us when transferring your Personal Data out of the EEA.
9. YOUR RIGHTS
You have the following rights under Data Protection laws. To protect your privacy and security, we may take reasonable steps to verify your identity before any exercise of the following rights according to applicable law.
(a) Request access to your Personal Data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
(b) Request correction of your Personal Data. Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
(c) Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
(d) Object to processing of your Personal Data. Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third-party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
(e) Request restriction of processing your Personal Data. Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (i) if you want us to establish the data’s accuracy; (ii) where our use of the data is unlawful but you do not want us to erase it; (iii) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
(f) Request transfer of your Personal Data. Request the transfer of your Personal Data to you or to a third-party. We will provide to you, or a third-party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
(g) Right to withdraw consent. Withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain features of our Services to you. We will advise you if this is the case at the time you withdraw your consent.
(h) Right to data portability. You may request us to transmit certain data we have about you (collected based on your consent or in order to provide you with our service) to another data controller in a structured, commonly used and machine-readable format (so long as this is technically feasible).
If you wish to exercise any of the rights set out above, please contact us at the e-mail address in the Contacting Us section below.
10. ADDITIONAL INFORMATION ABOUT YOUR RIGHTS
(a) No fee usually required. You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
(b) What we may need from you. We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
(c) Time limit to respond. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
11. DATA RETENTION
We will only retain your Personal Data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, audit, reporting and/or corporate compliance requirements.
To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Account and Profile data will be retained for six months after you closed your account (in case you want to re-open an account). After six months, it will be deleted. However, if you made payments, your Account data, Contact data and Payment data will be retained for seven years in order to comply with our accounting and tax obligations. Certain associated Profile and Technical Data may also be retained to protect the company against litigation.
When you close your account, we will disable the display of your photo on pages associated with your account. However, your contributions in blogs, forums or stories will remain on display unless you request us to delete this information.
Information about violations of the terms of our websites which have led to you being blocked, will be retained for 10 years together with your Account Data, Contact data and certain Technical Data, in order to prevent you from creating a new account.
12. NOTICE TO CERTAIN INTERNATIONAL MEMBERS
If you are a citizen of Canada, Brazil or Mexico and have questions about the accuracy of information that we have collected about you, you can have access to that information in order to verify and update it, unless we are permitted or required under applicable laws to refuse your access to such information. You may write or email us the e-mail address in the Contacting Us section below
13. CALIFORNIA PRIVACY RIGHTS
Section 1798.83 of the California Civil Code entitles residents of California to request a notice detailing the categories of Personal Data that we have shared with third-parties for direct marketing purposes during the preceding calendar year, as well as the identity of those third-parties. To request a copy of your Personal Data maintained by us, please contact us as at the e-mail address in the Contacting Us section below.
14. OTHER SITES LINKED TO SERVICES
15. QUESTIONS OR CONCERNS
For users in the EEA, any questions or concerns regarding the use or disclosure of Personal Data should first be directed to us via the email address provided in the CONTACT US section below. We will promptly investigate and attempt to resolve all complaints regarding our use of Personal Data. In the event we are unable to mutually resolve a complaint; we will work with you and agree to refer your complaint to an independent dispute resolution mechanism. You may also work with the Data Protection Authority in your country http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm to assist with this process as well.
18. CONTACT US