Privacy Policy
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Last updated: Jul 16, 2025
TABLE OF CONTENTS
1. WHO WE ARE
2. WHEN YOU ACCEPT THIS PRIVACY POLICY
3. AGE RESTRICTION
4. WHAT DATA WE COLLECT AND HOW
INFORMATION YOU PROVIDE TO US
INFORMATION ABOUT HOW YOU USE OUR SERVICES
INFORMATION FROM YOUR CONTENT
YOUR COMMUNICATIONS WITH US AND OTHER USERS
PERSONAL DATA WE COLLECT AUTOMATICALLY
PERSONAL DATA WE COLLECT USING COOKIES AND SIMILAR TECHNOLOGIES
IF YOU FAIL TO PROVIDE PERSONAL DATA
5. HOW WE USE YOUR PERSONAL DATA
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
AGGREGATED DATA
AUTOMATED DECISION MAKING AND PROFILING
AI FUNCTIONS
MARKETING
CHANGE OF PURPOSE
6. DISCLOSURES OF YOUR PERSONAL DATA
OUR SERVICE PROVIDERS AND STAFF
PARTNERSHIPS, AFFILIATES AND AUDIT
TRANSFER OF BUSINESS
LEGAL DEFENSE
INTERNATIONAL TRANSFERS
7. HOW LONG WILL WE KEEP YOUR PERSONAL DATA
EXCEPTIONS
DATA DELETION REQUESTS
8. CHANGES TO YOUR PROFILE AND OPT-OUT FROM COMMUNICATION
HOW TO MAKE CHANGES IN YOUR PROFILE
HOW TO OPT-OUT FROM E-MAIL MESSAGES
9. YOUR LEGAL RIGHTS
IF YOU ARE IN EU
IF YOU ARE IN US
IF YOU ARE IN JAPAN
10. CONTACT US
11. MISCELLANEOUS
LINKS TO OTHER WEBSITES AND APPS
INTELLECTUAL PROPERTY
YOUR LIABILITY
We have appointed a Data Protection Officer (“DPO”) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise YOUR LEGAL RIGHTS, please contact the DPO using the details set out in the CONTACT US section down below.
If you believe that we have collected, used or disclosed personal data of a person under the age of 18 (or the age of majority in your jurisdiction), please contact our support team via the CONTACT US section down below so that we can take appropriate action.
INFORMATION YOU PROVIDE TO US
When you register, use or subscribe to our Services or take part in any interactive features of the Services (such as any communications with virtual companions, our promotions, quizzes, surveys, research or other services or features), we may collect a variety of information, including:
We may collect information about your participation and actions during your use of our Services. This may include information such as the pages you view, how you browse our platform. It can also include the various functions and features that you use, the connections you make, other friends or contacts you invite to the Services and profile searches you perform, or your use of our applications.
INFORMATION FROM YOUR CONTENT
When you upload any content photos, videos or other information to our Services, we may collect information about the content, such as the time, date and place the photo or content was taken or uploaded (also known as metadata), and how you use them, who views them or with whom you share. We may also scan and analyze the photos, videos, and other content you provide to us using third party services for several purposes, including for anti-fraud purposes, for the assessment of whether the photos are consistent with our Terms, to help identify your interests and activities, such as if your photo includes pets, sports, or trips, and to help us provide better services for you.
YOUR COMMUNICATIONS WITH US AND OTHER USERS
We collect communications you send to us (such as email, phone, sms, push notifications, Whatsapp, Facebook, Wechat, QQ and any other messengers), comments that you post on the pages we have on a third-party service, such as our Instagram, Twitter, Whatsapp, Facebook and other pages, as well as messages that you send us directly through those services (“Communication Data”). We may also collect and analyze any comments, photos, messages or other content or communications you and other users share on our Services or send to each other.
PERSONAL DATA WE COLLECT AUTOMATICALLY
When you access our Services, we and our third party partners automatically record information from your device and its software, in particular, we collect:
We use cookie technology on the Website as part of the statistical reporting. It contains personal data used by the Website to personalize your experience (e.g. rotating profiles on the {domain} home page) and to gather statistical data, such as which pages are visited, what is downloaded during your experience, the domain name and country of the internet provider that you have come from (e.g.‘aol’, or ‘umich.edu’), and addresses of those websites you have visited just before and after the Website. Nevertheless, we do not associate any of this personal data with you as an individual. Only an aggregate measure is taken. Cookie personal data allows us to follow your “clickstream” activity (i.e., how visitors navigate our Website as they move from page to page). It is important to note that cookies never capture your individual email address or any of your private personal data.
We also operate standard web server log files to assist in counting visitor numbers and analyzing our Service technical capability. This personal data is used to establish how many people use our Services, enable us to organize our Services for the best usability, make our Services suitable for your browser, and ensure that our Services are working at their full potential. Although we collect personal data on online traffic, we do not record personal data on particular visitors of our Services, which means that no personal data about you as an individual is retained or used. You are able to browse the Website without cookies by configuring your browser to reject all cookies, or to alert you when a cookie is sent. Since each browser is different, you should refer to the “Help” menu of your browser to learn how to change your cookie preferences.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where you do not provide the personal data detailed in this Privacy Policy, you may not be able to use our Services. Please note that providing incorrect, outdated, or false information may result in our services not functioning properly or at all. To ensure the best experience, we encourage you to provide accurate and up-to-date data.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out in the table below a description of the ways we plan to use your personal data, and which of the legal grounds we rely on to do so. Please CONTACT US if you need details about the specific legal ground we are relying on to process your personal data where more than one legal ground has been set out in the table below.
AGGREGATED DATA
We may create aggregated data for internal use or for improving Services and creating new features. Aggregated data is anonymous and is not linked to any personal data. Aggregated information helps understand trends and customer needs so that new products and services can be considered and so existing products and services can be tailored to customer desires. We may share such aggregated data with our partners, without restriction, on commercial terms that we can determine in our sole discretion.
AUTOMATED DECISION MAKING AND PROFILING
Automated Decision-Making (“ADM”) is when a decision is made solely on automated processing (including profiling) which produces legal effects or significantly affects an individual. Generally, ADM is prohibited when a decision has a legal or similar significant effect on an individual unless (a) you provide us with your consent, (b) ADM is authorized by law or (c) ADM is necessary for the performance of or entering into a contract.
We use ADM for:
If you believe that ADM acted inappropriately or want to be serviced by a human, please CONTACT US.
AI FUNCTIONS
Our Service may offer you different AI-based functions, like suggesting possible messages in communication, automatic photo verification, translation of live conversations or analysing personal data within the additional services that designed to enhance your experience—such as matching based on certain personal data (e.g., date of birth, place of birth, gender, preferences, etc.). This list may be enlarged in future. For that purpose we may transfer your respective data to the relevant AI model provided to us by the trusted partner. Your data are safe and will be processed only for the purposes of providing the respective services to you.
MARKETING
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. Where you have interacted with us, we will send you marketing communications from time to time. If you do not want to receive marketing communications, please refer to HOW TO OPT-OUT FROM E-MAIL MESSAGES down below. You may also select the “unsubscribe” link in the communication we send to you.
When you receive communications from Us, including marketing communications, we may share your personal data with third party companies who help us conduct marketing activities. For example, we may use a third party to help us send email messages to you and help us understand how you have interacted with that email.
You hereby agree that we may at our own discretion use any available channels of communication (including, but not limited to Email, phone, sms, push notifications, Whatsapp, Facebook, Wechat, QQ and any other messengers) for customer support and/or marketing purposes if you have provided us with such. You may at any time withdraw your consent on such communication by contacting our support team via CONTACT US link down below.
CHANGE OF PURPOSE
We will generally only use your personal data for the purposes for which we collected it. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
The personal data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Data controller, in some cases, the personal data may be accessible to certain types of persons in charge, involved with the operation of our Services (administration, sales, marketing, legal, system administration) or external parties (such as third party technical service providers, mail carriers, hosting providers, IT companies, communication agencies) appointed, if necessary, as Data Processors by the Data controller.
We may share your personal data you provide to us with specially selected service providers who assist us in delivering the products and services we offer for the sole purpose of providing the services or when we consider their services or products to be of interest to you. These service providers must adhere to strict confidentiality and data transfer obligations in a way that is consistent with this Privacy Policy and the agreements we enter into with them. We may cooperate with external service providers to:
We may disclose your personal data to other third parties such as our partners, consultors, group companies and affiliates, external audit and assessment providers provided they ensure the required level of confidentiality and privacy according to the applicable laws.
TRANSFER OF BUSINESS
We may transfer or share a copy of your personal data in cases where the Data Controller or one of its properties, affiliates, or subsidiaries is part of a business transition, such as a merger, being acquired by another company, or selling part of its assets, or in the event of bankruptcy, dissolution, divestiture or any related or similar proceedings.
LEGAL DEFENSE
We may share your personal data to, in our discretion, (i) satisfy any applicable law, regulation, subpoena/court order, legal process or other government request, (ii) enforce our Terms, including the investigation of potential violations thereof, (iii) investigate and defend ourselves against any third party claims or allegations, (iv) protect against harm to the rights, our property or safety, our users or the public as required or permitted by law and (v) detect, prevent or otherwise address criminal (including fraud or stalking), security or technical issues.
INTERNATIONAL TRANSFERS
We may share personal data internally within Data Controller’s subsidiary, affiliated and partner companies or with third parties for purposes described in this Privacy Policy. Personal data collected within the European Economic Area (“EEA”) may, for example, be transferred to countries outside of the EEA for the purposes as described in this Privacy Policy. We utilize standard contractual clauses approved by the European Commission, adopt other means under European Union law (such as, where applicable, corporate binding rules), and obtain your consent to legitimize data transfers from the EEA to the United States and other countries.
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.
The Personal data is processed at the Data controller’s operating offices and in any other place where the parties involved with the processing are located. We also retain backups of the Services, including your personal data, on a rolling basis according to our internal data retention, disaster recovery, and business continuity policies. Our backups are stored off-site in the European Union, United Stated and other countries where we operate, in secure facilities in order to help ensure the protection of your personal data, and the Services.
EXCEPTIONS
We retain blacklists of fraudulent activity or security threats indefinitely in order to protect the security of our Services and your personal data. We share these blacklists with third party service providers in order to continue to improve the security of our Services and your personal data.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research, statistical or other purposes in which case we may use this information indefinitely without further notice to you.
DATA DELETION REQUESTS
If you wish to delete personal data we have collected during your use of our Services, You should send a request to our support team via CONTACT US link down below. Processing of your request will take some time to take effect. Thank you for your patience.
Please note that changing or deleting your personal data will only change or delete the data in our database for the purposes of future activities and for managing future communications. These changes and deletions may not entirely change or delete emails or personal data our Services may have already forwarded to other users or credit card companies or any other third parties, as they might still retain part of the data for their legitimate or lawful purposes.
Further, if you delete your personal data from our Services, but continue to use other Linked Services, you may receive emails from us regarding those Linked Services. Please refer to the MARKETING section above for further details.
We may keep your personal data, subject to the requirements of the law and legitimate interests of the Data Controller, please refer to the HOW WE USE YOUR PERSONAL DATA section above for further details. In case of your request to delete all your personal data, you agree that your email will be stored in our database to avoid creation of duplicate accounts and for identification purposes. The email will not be used in marketing activities, nor forwarded to any Linked Services or third parties.
Please note that, even after termination of Services and deletion of any personal data, as well as termination of any license granted hereunder, some content may continue to exist because of cached internet pages beyond our control.
HOW TO MAKE CHANGES IN YOUR PROFILE
You have the right, at any time, to change or delete your personal data in your profile. Please reach our support team via CONTACT US section down below and they will guide you through the process.
HOW TO OPT-OUT FROM E-MAIL MESSAGES
You can decide which correspondence to receive from us. To stop receiving correspondence you can:
Please note that local regulations may provide other or additional rights to the above as following:
IF YOU ARE IN EU
If you are located in the European Union, you have several rights under General Data Protection Regulation (“GDPR”):
If you are located in the United States, the local Data Privacy Acts give you the right to exercise the following rights in addition to the above:
IF YOU ARE IN JAPAN
If you are located in Japan, you have certain rights under the Act on the Protection of Personal Information (“APPI”) in addition to the above:
Please send all the requests, including exercise of rights for EU, US and other users regarding personal data, as well as communications, inquiries, clarifications and provision of information to our support team via chat in application (for registered users only) or via email at [email protected].
Please visit our Help Center page for information regarding the Website or App and your actions there.
If you click on a link that takes you away from our Services to another website or application, you should remember that the Terms, Refund and Cancellation Policy and Privacy Policy of our Services no longer apply to the new website or application you visit. All your activity on any other website or application, including those with a link on the Services, is subject to the rules and regulations of that other website or application. Therefore, we recommend that you read all the policies of new websites and applications you visit to fully understand their rules and regulations for collecting, using, and sharing your personal data.
INTELLECTUAL PROPERTY
By posting any content, messages, photos and/or videos to any public area of our Services you automatically grant, represent and warrant that you have the right to grant us an irrevocable, perpetual, non-exclusive, fully paid, worldwide license to use, copy, perform, display, and distribute such personal data and content and to prepare derivative works of, or incorporate into other works, such personal data and content, and to grant and authorize sublicenses of the foregoing.
For the content that is covered by intellectual property rights, like photos and videos (the “IP content”), you specifically give us the following permission, subject to your privacy and application settings: you grant us a non-exclusive, transferable, sub-licensable, royalty-free, worldwide license to use any IP content that you post on or in connection with the Services (IP License). This IP License ends when you terminate our Services and we, according to this Privacy Policy, Refund and Cancellation Policy the Terms, delete your IP content unless your content has been shared with others, and they have not deleted it.
YOUR LIABILITY
We reserve the right to replace, modify or amend this Privacy Policy at our own discretion. It is your responsibility to review this page and check for any Privacy Policy updates. Please note the latest modification date at the bottom of the Privacy Policy.
TABLE OF CONTENTS
1. WHO WE ARE
2. WHEN YOU ACCEPT THIS PRIVACY POLICY
3. AGE RESTRICTION
4. WHAT DATA WE COLLECT AND HOW
INFORMATION YOU PROVIDE TO US
INFORMATION ABOUT HOW YOU USE OUR SERVICES
INFORMATION FROM YOUR CONTENT
YOUR COMMUNICATIONS WITH US AND OTHER USERS
PERSONAL DATA WE COLLECT AUTOMATICALLY
PERSONAL DATA WE COLLECT USING COOKIES AND SIMILAR TECHNOLOGIES
IF YOU FAIL TO PROVIDE PERSONAL DATA
5. HOW WE USE YOUR PERSONAL DATA
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
AGGREGATED DATA
AUTOMATED DECISION MAKING AND PROFILING
AI FUNCTIONS
MARKETING
CHANGE OF PURPOSE
6. DISCLOSURES OF YOUR PERSONAL DATA
OUR SERVICE PROVIDERS AND STAFF
PARTNERSHIPS, AFFILIATES AND AUDIT
TRANSFER OF BUSINESS
LEGAL DEFENSE
INTERNATIONAL TRANSFERS
7. HOW LONG WILL WE KEEP YOUR PERSONAL DATA
EXCEPTIONS
DATA DELETION REQUESTS
8. CHANGES TO YOUR PROFILE AND OPT-OUT FROM COMMUNICATION
HOW TO MAKE CHANGES IN YOUR PROFILE
HOW TO OPT-OUT FROM E-MAIL MESSAGES
9. YOUR LEGAL RIGHTS
IF YOU ARE IN EU
IF YOU ARE IN US
IF YOU ARE IN JAPAN
10. CONTACT US
11. MISCELLANEOUS
LINKS TO OTHER WEBSITES AND APPS
INTELLECTUAL PROPERTY
YOUR LIABILITY
- WHO WE ARE
We have appointed a Data Protection Officer (“DPO”) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise YOUR LEGAL RIGHTS, please contact the DPO using the details set out in the CONTACT US section down below.
- WHEN YOU ACCEPT THIS PRIVACY POLICY
- AGE RESTRICTION
If you believe that we have collected, used or disclosed personal data of a person under the age of 18 (or the age of majority in your jurisdiction), please contact our support team via the CONTACT US section down below so that we can take appropriate action.
- WHAT DATA WE COLLECT AND HOW
INFORMATION YOU PROVIDE TO US
When you register, use or subscribe to our Services or take part in any interactive features of the Services (such as any communications with virtual companions, our promotions, quizzes, surveys, research or other services or features), we may collect a variety of information, including:
- Contact Information such as your name, user ID, email address, phone number, and address (“Contact Data”).
- Sensitive Information such as race, ethnicity, sexual preferences and experiences, political affiliation, religious affiliation, union memberships you may provide through the use of our Services (your “Sensitive Personal Data”).
- Other information such as birth date, videos, password, demographic information, place of work or education, your personal interests and background, gender, age, dating age range preference, physical characteristics, personal description, life experiences, geographic location, your photos, videos and any information derived from them (collectively “Extended Data”), and any other information you share during the use of our Services, including in course of communication with virtual companions.
- Information disclosed through communication with our support team. You may also provide us with other personal data through your participation in user-to-user communications, chats, or when you otherwise communicate with us regarding our Services;
- Mandatory information we are required or authorized by applicable laws to collect and process in order to authenticate or identify you or to verify the personal data we have collected.
We may collect information about your participation and actions during your use of our Services. This may include information such as the pages you view, how you browse our platform. It can also include the various functions and features that you use, the connections you make, other friends or contacts you invite to the Services and profile searches you perform, or your use of our applications.
INFORMATION FROM YOUR CONTENT
When you upload any content photos, videos or other information to our Services, we may collect information about the content, such as the time, date and place the photo or content was taken or uploaded (also known as metadata), and how you use them, who views them or with whom you share. We may also scan and analyze the photos, videos, and other content you provide to us using third party services for several purposes, including for anti-fraud purposes, for the assessment of whether the photos are consistent with our Terms, to help identify your interests and activities, such as if your photo includes pets, sports, or trips, and to help us provide better services for you.
YOUR COMMUNICATIONS WITH US AND OTHER USERS
We collect communications you send to us (such as email, phone, sms, push notifications, Whatsapp, Facebook, Wechat, QQ and any other messengers), comments that you post on the pages we have on a third-party service, such as our Instagram, Twitter, Whatsapp, Facebook and other pages, as well as messages that you send us directly through those services (“Communication Data”). We may also collect and analyze any comments, photos, messages or other content or communications you and other users share on our Services or send to each other.
PERSONAL DATA WE COLLECT AUTOMATICALLY
When you access our Services, we and our third party partners automatically record information from your device and its software, in particular, we collect:
- data about your interaction with our Services and your communications with us. This is personal data we receive from devices (including mobile devices) you use when you access our Services. This personal data may include the following: device number, device ID or unique identifier, device type, unique device token, operating system, application crash-data, IP address, user agent, platform, Software Development Kit version, anonymous User ID, application version, device identifiers such as: IDFA (Identifier For Advertisers), Android ID (Android device), referrer url (Google Play Store), Google Advertiser ID, device model, manufacturer, OS version, in-app events, network status (WiFi/4G), login source, application use, age, gender, whether the profile is linked to Facebook/Google and their profile photo, notification status, internet navigation details (for example, how your mouse moves on a screen which tells us if you’re a bot or real person) registration date, credits bought, date of last payment and use of services (“Technical Data”);
- Real location data, including physical location data from your mobile device including specific geographic locations through IP, GPS, Bluetooth, or WiFi signals (“Location Data”).
We use cookie technology on the Website as part of the statistical reporting. It contains personal data used by the Website to personalize your experience (e.g. rotating profiles on the {domain} home page) and to gather statistical data, such as which pages are visited, what is downloaded during your experience, the domain name and country of the internet provider that you have come from (e.g.‘aol’, or ‘umich.edu’), and addresses of those websites you have visited just before and after the Website. Nevertheless, we do not associate any of this personal data with you as an individual. Only an aggregate measure is taken. Cookie personal data allows us to follow your “clickstream” activity (i.e., how visitors navigate our Website as they move from page to page). It is important to note that cookies never capture your individual email address or any of your private personal data.
We also operate standard web server log files to assist in counting visitor numbers and analyzing our Service technical capability. This personal data is used to establish how many people use our Services, enable us to organize our Services for the best usability, make our Services suitable for your browser, and ensure that our Services are working at their full potential. Although we collect personal data on online traffic, we do not record personal data on particular visitors of our Services, which means that no personal data about you as an individual is retained or used. You are able to browse the Website without cookies by configuring your browser to reject all cookies, or to alert you when a cookie is sent. Since each browser is different, you should refer to the “Help” menu of your browser to learn how to change your cookie preferences.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where you do not provide the personal data detailed in this Privacy Policy, you may not be able to use our Services. Please note that providing incorrect, outdated, or false information may result in our services not functioning properly or at all. To ensure the best experience, we encourage you to provide accurate and up-to-date data.
- HOW WE USE YOUR PERSONAL DATA
- Where we need to perform the contract we are about to enter into or have entered into with you for the Services.
- Where you have given consent for us to use your personal data and, where applicable, your Sensitive Personal Data to provide certain Services (you may withdraw your consent for some uses of the data at any time in your Profile or via CONTACT US section down below).
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out in the table below a description of the ways we plan to use your personal data, and which of the legal grounds we rely on to do so. Please CONTACT US if you need details about the specific legal ground we are relying on to process your personal data where more than one legal ground has been set out in the table below.
Purpose/Activity | Type of personal data | Legal grounds for processing personal data |
To register you with our services | (a) Profile Data, such as name, age, sexual orientation, marital status, number of children, and location, date of birth, place of birth (if applies) (b) Contact Data such as email address, phone number, or Social Media User account, as limited by your privacy settings (c) Data from Social Media Sites (If you use Facebook or Google to log-in to the Services), including any interests or other data imported from your Social Media Sites (d) Technical Data, such as device ID or IP Address, including timestamps (e) Extended Data | (a) Performance of a contract with you (b) With your consent in the case of sensitive personal data. |
To provide the Services to you, including: (a) Maintaining a profile, answering questions, and providing information about yourself; (b) Analyzing your personal data to match you with other users; (c) Allowing you to communicate with other users; and (d) Enabling you to pay for the Services. | (a) Profile Data, such as name, age, sexual orientation, race, marital status, number of children, and location, date of birth, place of birth (if applies) (b) Contact Data such as email address, phone number, or social media user account (c) Transaction Data,such as name, address, transaction ID, timestamps, email address, currency, and routing number (d) Communications Data, including the content of messages, the name and ID of the recipients of the communications, the timestamp, IP address and/or Device ID of the parties to the messages (e) Photos, including various analytics and scoring results (f) Contact Data (g) Analytics Data (h) Technical Data (i) Extended Data | (a) Performance of a contract with you (b) With your consent (with regard to your Sensitive Personal Data) |
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or Privacy Policy (b) Communicating with you | (a) Profile Data (b) Transaction Data (c) Contact Data (d) Communications Data (e) Photos (f) Extended Data | (a) Performance of a contract with you (b) Necessary to comply with a legal obligation |
To administer and protect our business, our Services, contravention or unauthorized use of our Services and your personal data (including security, fraud, court proceedings, troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). For any legal proceedings these rights may be exercised by the Data controller and any of its affiliates, subsidiaries, directors, etc. | (a) Profile Data (b) Contact Data (c) Technical Data (d) Communications Data (e) Third party data provided to us by trusted partners, including proprietary scores, red flags, demographic information, usage data, and other information used to determine whether your account is being used improperly, accessed by an unauthorized third party, or represents a security or fraud risk to the Services or their users. (f) Extended Data (g) Any personal data related to the user in communication with support team or companion | (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, cybersecurity, to prevent fraud and in the context of a business reorganization or group restructuring exercise) (b) Necessary to comply with a legal obligation |
To deliver relevant content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | (a) Email address (b)Device ID (c) IP Address (d) Location (at country, state, city, or postal code level) (e) Gender (f) Age (g) Technical Data (h) Cookies, pixels, or advertising tags | (a) Necessary for our legitimate interests to deliver your Service-related content and communication as well as study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy (b) With your consent for targeted advertising and profiling to serve more accurate advertising content to you. |
To use data analytics to improve our Services and products, marketing, customer relationships and experiences | (a) Profile Data (b) Technical Data (c) Communications Data | Necessary for our legitimate interests, such as: to define types of customers for our products and services, to keep our Services updated and relevant, to develop our business and to inform our marketing strategy. |
To respond to requests from law enforcement, including banks, card processing companies and investigation authorities | (a) Profile Data (b) Transaction Data (c) Communications Data (d) Location Data (at country, state, city, or postal code level) (e) Technical Data (f) Extended Data (g) Any other information we are compelled to provide by law or by terms of use of the respective organization. | Necessary to comply with our legal obligations |
AGGREGATED DATA
We may create aggregated data for internal use or for improving Services and creating new features. Aggregated data is anonymous and is not linked to any personal data. Aggregated information helps understand trends and customer needs so that new products and services can be considered and so existing products and services can be tailored to customer desires. We may share such aggregated data with our partners, without restriction, on commercial terms that we can determine in our sole discretion.
AUTOMATED DECISION MAKING AND PROFILING
Automated Decision-Making (“ADM”) is when a decision is made solely on automated processing (including profiling) which produces legal effects or significantly affects an individual. Generally, ADM is prohibited when a decision has a legal or similar significant effect on an individual unless (a) you provide us with your consent, (b) ADM is authorized by law or (c) ADM is necessary for the performance of or entering into a contract.
We use ADM for:
- matching the users and the companion,
- suggesting topics, time and other aspects for the conversation between the users and companions,
- assessing the quality of companions' communication, and
- blocking or limiting features for the users when we detect prohibited content or violations of our Terms.
If you believe that ADM acted inappropriately or want to be serviced by a human, please CONTACT US.
AI FUNCTIONS
Our Service may offer you different AI-based functions, like suggesting possible messages in communication, automatic photo verification, translation of live conversations or analysing personal data within the additional services that designed to enhance your experience—such as matching based on certain personal data (e.g., date of birth, place of birth, gender, preferences, etc.). This list may be enlarged in future. For that purpose we may transfer your respective data to the relevant AI model provided to us by the trusted partner. Your data are safe and will be processed only for the purposes of providing the respective services to you.
MARKETING
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. Where you have interacted with us, we will send you marketing communications from time to time. If you do not want to receive marketing communications, please refer to HOW TO OPT-OUT FROM E-MAIL MESSAGES down below. You may also select the “unsubscribe” link in the communication we send to you.
When you receive communications from Us, including marketing communications, we may share your personal data with third party companies who help us conduct marketing activities. For example, we may use a third party to help us send email messages to you and help us understand how you have interacted with that email.
You hereby agree that we may at our own discretion use any available channels of communication (including, but not limited to Email, phone, sms, push notifications, Whatsapp, Facebook, Wechat, QQ and any other messengers) for customer support and/or marketing purposes if you have provided us with such. You may at any time withdraw your consent on such communication by contacting our support team via CONTACT US link down below.
CHANGE OF PURPOSE
We will generally only use your personal data for the purposes for which we collected it. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
- DISCLOSURES OF YOUR PERSONAL DATA
The personal data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Data controller, in some cases, the personal data may be accessible to certain types of persons in charge, involved with the operation of our Services (administration, sales, marketing, legal, system administration) or external parties (such as third party technical service providers, mail carriers, hosting providers, IT companies, communication agencies) appointed, if necessary, as Data Processors by the Data controller.
We may share your personal data you provide to us with specially selected service providers who assist us in delivering the products and services we offer for the sole purpose of providing the services or when we consider their services or products to be of interest to you. These service providers must adhere to strict confidentiality and data transfer obligations in a way that is consistent with this Privacy Policy and the agreements we enter into with them. We may cooperate with external service providers to:
- oversee a customer personal data database;
- help us in sending out emails, sms (message and data rates may apply) and presents;
- help us with direct marketing;
- assist us with storage and data analysis;
- prevent from fraudulent activities;
- help us in maintaining, developing and improving our systems/websites/applications/services;
- collect payments.
We may disclose your personal data to other third parties such as our partners, consultors, group companies and affiliates, external audit and assessment providers provided they ensure the required level of confidentiality and privacy according to the applicable laws.
TRANSFER OF BUSINESS
We may transfer or share a copy of your personal data in cases where the Data Controller or one of its properties, affiliates, or subsidiaries is part of a business transition, such as a merger, being acquired by another company, or selling part of its assets, or in the event of bankruptcy, dissolution, divestiture or any related or similar proceedings.
LEGAL DEFENSE
We may share your personal data to, in our discretion, (i) satisfy any applicable law, regulation, subpoena/court order, legal process or other government request, (ii) enforce our Terms, including the investigation of potential violations thereof, (iii) investigate and defend ourselves against any third party claims or allegations, (iv) protect against harm to the rights, our property or safety, our users or the public as required or permitted by law and (v) detect, prevent or otherwise address criminal (including fraud or stalking), security or technical issues.
INTERNATIONAL TRANSFERS
We may share personal data internally within Data Controller’s subsidiary, affiliated and partner companies or with third parties for purposes described in this Privacy Policy. Personal data collected within the European Economic Area (“EEA”) may, for example, be transferred to countries outside of the EEA for the purposes as described in this Privacy Policy. We utilize standard contractual clauses approved by the European Commission, adopt other means under European Union law (such as, where applicable, corporate binding rules), and obtain your consent to legitimize data transfers from the EEA to the United States and other countries.
- HOW LONG WILL WE KEEP YOUR PERSONAL DATA
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.
The Personal data is processed at the Data controller’s operating offices and in any other place where the parties involved with the processing are located. We also retain backups of the Services, including your personal data, on a rolling basis according to our internal data retention, disaster recovery, and business continuity policies. Our backups are stored off-site in the European Union, United Stated and other countries where we operate, in secure facilities in order to help ensure the protection of your personal data, and the Services.
EXCEPTIONS
We retain blacklists of fraudulent activity or security threats indefinitely in order to protect the security of our Services and your personal data. We share these blacklists with third party service providers in order to continue to improve the security of our Services and your personal data.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research, statistical or other purposes in which case we may use this information indefinitely without further notice to you.
DATA DELETION REQUESTS
If you wish to delete personal data we have collected during your use of our Services, You should send a request to our support team via CONTACT US link down below. Processing of your request will take some time to take effect. Thank you for your patience.
Please note that changing or deleting your personal data will only change or delete the data in our database for the purposes of future activities and for managing future communications. These changes and deletions may not entirely change or delete emails or personal data our Services may have already forwarded to other users or credit card companies or any other third parties, as they might still retain part of the data for their legitimate or lawful purposes.
Further, if you delete your personal data from our Services, but continue to use other Linked Services, you may receive emails from us regarding those Linked Services. Please refer to the MARKETING section above for further details.
We may keep your personal data, subject to the requirements of the law and legitimate interests of the Data Controller, please refer to the HOW WE USE YOUR PERSONAL DATA section above for further details. In case of your request to delete all your personal data, you agree that your email will be stored in our database to avoid creation of duplicate accounts and for identification purposes. The email will not be used in marketing activities, nor forwarded to any Linked Services or third parties.
Please note that, even after termination of Services and deletion of any personal data, as well as termination of any license granted hereunder, some content may continue to exist because of cached internet pages beyond our control.
- CHANGES TO YOUR PROFILE AND OPT-OUT FROM COMMUNICATION
HOW TO MAKE CHANGES IN YOUR PROFILE
You have the right, at any time, to change or delete your personal data in your profile. Please reach our support team via CONTACT US section down below and they will guide you through the process.
HOW TO OPT-OUT FROM E-MAIL MESSAGES
You can decide which correspondence to receive from us. To stop receiving correspondence you can:
- Click the unsubscribe link found at the bottom of each email you receive or
- by emailing your request to us at {unsubscribeEmailLink} or
- by changing the settings in your profile.
- YOUR RIGHTS
- Access data we process about you,
- Correct and/or complete your data,
- Delete your data subject to section HOW LONG WILL WE KEEP YOUR PERSONAL DATA,
- Object to or restrict data processing according to the applicable laws and regulations, and
- Be informed about any activity of the above.
Please note that local regulations may provide other or additional rights to the above as following:
IF YOU ARE IN EU
If you are located in the European Union, you have several rights under General Data Protection Regulation (“GDPR”):
- You have the right to obtain confirmation if your personal information is being processed by us.
- You have the right to receive your personal information which you provided us with in a structured,commonly used and machine-readable format and have the right to transmit those data to another company, where: (a) the processing is based on your consent or on a contract; and (b) the processing is carried out by automated means.
- You have the right to withdraw your consent for processing of your personal information at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
- You have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of your personal information infringes GDPR.
If you are located in the United States, the local Data Privacy Acts give you the right to exercise the following rights in addition to the above:
- Right to prohibit sale of your personal data. Please note that we do not sell your personal data.
- Right to object profiling and targeted advertising. You may submit a verifiable request to be opted-out from each of the above actions. Please note that these measures may negatively affect your customer experience with our website, app and third party services.
IF YOU ARE IN JAPAN
If you are located in Japan, you have certain rights under the Act on the Protection of Personal Information (“APPI”) in addition to the above:
- you shall have the right to object at any time to the processing of personal data for direct marketing purposes.
- You have the right to submit a complaint with our support team via the CONTACT US section of this Privacy Policy if you consider that the processing of your personal information infringes the APPI, the relevant laws and this Privacy Policy.
- When You have requested notification or disclosure of the purpose of use of their personal information to the contact address set forth in the CONTACT US link of this Privacy Policy, we shall disclose to you the personal data held by us after confirmation of your identity; provided, however, that this shall not apply if we are not obligated to disclose such personal data under the APPI or other applicable laws. In some cases, we may charge a separate fee for the disclosure of such personal data.
- If, as a result of the disclosure of personal data as described above, the content of the personal data is found to be inaccurate, and we receive a request for correction, addition, or deletion of the personal data from the person concerned, addressed to our support team via the CONTACT US section of this Privacy Policy, in accordance with the procedures prescribed by us, we shall, after confirming the identity of you, conduct an investigation to the extent necessary without delay and, based on the results of the investigation, correct, add, or delete the content of the relevant personal data.
- If we receive a request from you to suspend the use of or delete their personal data in accordance with the provisions of the APPI, addressed to our support team specified in CONTACT US section of this Privacy Policy, we shall, after confirming the identity of you, suspend the use or delete the relevant personal data to the extent necessary without delay; provided, however, that this shall not apply if it is found that there is no reason for the request.
- CONTACT US
Please send all the requests, including exercise of rights for EU, US and other users regarding personal data, as well as communications, inquiries, clarifications and provision of information to our support team via chat in application (for registered users only) or via email at [email protected].
Please visit our Help Center page for information regarding the Website or App and your actions there.
- MISCELLANEOUS
If you click on a link that takes you away from our Services to another website or application, you should remember that the Terms, Refund and Cancellation Policy and Privacy Policy of our Services no longer apply to the new website or application you visit. All your activity on any other website or application, including those with a link on the Services, is subject to the rules and regulations of that other website or application. Therefore, we recommend that you read all the policies of new websites and applications you visit to fully understand their rules and regulations for collecting, using, and sharing your personal data.
INTELLECTUAL PROPERTY
By posting any content, messages, photos and/or videos to any public area of our Services you automatically grant, represent and warrant that you have the right to grant us an irrevocable, perpetual, non-exclusive, fully paid, worldwide license to use, copy, perform, display, and distribute such personal data and content and to prepare derivative works of, or incorporate into other works, such personal data and content, and to grant and authorize sublicenses of the foregoing.
For the content that is covered by intellectual property rights, like photos and videos (the “IP content”), you specifically give us the following permission, subject to your privacy and application settings: you grant us a non-exclusive, transferable, sub-licensable, royalty-free, worldwide license to use any IP content that you post on or in connection with the Services (IP License). This IP License ends when you terminate our Services and we, according to this Privacy Policy, Refund and Cancellation Policy the Terms, delete your IP content unless your content has been shared with others, and they have not deleted it.
YOUR LIABILITY
We reserve the right to replace, modify or amend this Privacy Policy at our own discretion. It is your responsibility to review this page and check for any Privacy Policy updates. Please note the latest modification date at the bottom of the Privacy Policy.
