OUR COMMITMENT TO YOU

 

At Match Group, your privacy is a top priority. Your privacy is at the core of the way we design and build the services and products you know and love, so that you can fully trust them and focus on building meaningful connections.

We appreciate that you put your trust in us when you provide us with your information and we do not take this lightly.

We do not compromise with your privacy. We design all of our products and services with your privacy in mind. We involve experts from various fields, including legal, security, engineering, product design and others to make sure that no decision is taken without respect for your privacy.

We strive to be transparent in the way we process your data. Because we use many of the same online services you do, we know that insufficient information and overly complicated language are common issues in privacy policies. We take the exact opposite approach: we have written our Privacy Policy and related documents in plain language. We actually want you to read our policies and understand our privacy practices!

We work hard to keep your information secure. We have teams dedicated to keeping your data safe and secure. We constantly update our security practices and invest in our security efforts to enhance the safety of your information.

 

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PRIVACY POLICY

 

Welcome to Affiny’s Privacy Policy. Thank you for taking the time to read it.

We appreciate that you trust us with your information and we intend to always keep that trust. This starts with making sure you understand the information we collect, why we collect it, how it is used and your choices regarding your information.  This Policy describes our privacy practices in plain language, keeping legal and technical jargon to a minimum.

This Privacy Policy applies beginning May 25, 2018.  The previous version of this Privacy Policy, available here, will apply until then.

 

EFFECTIVE DATE: May 25, 2018

 

 

  1. WHO WE ARE
  2. WHERE THIS PRIVACY POLICY APPLIES
  3. INFORMATION WE COLLECT
  4. COOKIES AND OTHER SIMILAR DATA COLLECTION TECHNOLOGIES
  5. HOW WE USE INFORMATION
  6. HOW WE SHARE INFORMATION
  7. CROSS-BORDER DATA TRANSFERS
  8. YOUR RIGHTS
  9. HOW WE PROTECT YOUR INFORMATION
  10. HOW LONG WE RETAIN YOUR INFORMATION
  11. CHILDREN’S PRIVACY
  12. PRIVACY POLICY CHANGES
  13. HOW TO CONTACT US

 

 

 

1.     WHO WE ARE

If you live in the European Union, the company that is responsible for your information under this Privacy Policy (the “data controller”) is:

MIL

C/O Skadden 40 Bank Street, Canary Wharf, London, E14 5DS

 

2.     WHERE THIS PRIVACY POLICY APPLIES

This Privacy Policy applies to websites, apps, events and other services operated by Affiny.  For simplicity, we refer to all of these as our “services” in this Privacy Policy. To make it extra clear, we’ve added links to this Privacy Policy on all applicable services.

Some services may require their own unique privacy policy. If a particular service has its own privacy policy, then that policy — not this Privacy Policy — applies.

 

3.     INFORMATION WE COLLECT

It goes without saying, we can’t help you develop meaningful connections without some information about you, such as basic profile details and the types of people you’d like to meet. We also collect information generated as you use our services, for example access logs, as well as information from third parties, like when you access our services through a social media account. If you want additional info, we go into more detail below.

Information you give us

You choose to give us certain information when using our services. This includes:

Information we receive from others

In addition to the information you provide us directly, we receive information about you from others, including:

Other users may provide information about you as they use our services. For instance, we may collect information about you from other users if they contact us about you. Also, if a user asks us to access contacts from his/her phonebook and you happen to be one of those, we may use it to reach out to you on behalf of the user.

You may be able to use your social media login (such as Facebook Login) to create and log into your Affiny account.  This saves you from having to remember yet another user name and password and allows you to share some information from your social media account with us.

We may receive info about you from our partners, for instance when Affiny accounts can be created through a partner’s websites (in which case they pass along registration information to us) or where Affiny ads are published on a partner’s websites and platforms (in which case they may pass along details on a campaign’s success).

 

Information collected when you use our services

When you use our services, we collect information about which features you’ve used, how you’ve used them and the devices you use to access our services.  See below for more details:

We collect information about your activity on our services, for instance how you use them (e.g., date and time you logged in, features you’ve been using, searches, clicks and pages which have been shown to you, referring webpage address, advertising that you click on) and how you interact with other users (e.g., users you connect and interact with, time and date of your exchanges, number of messages you send and receive).

We collect information from and about the device(s) you use to access our services, including:

If you give us permission, we can collect your precise geolocation (latitude and longitude) through various means, depending on the service and device you’re using, including GPS, Bluetooth or Wi-Fi connections.  The collection of your geolocation may occur in the background even when you aren’t using the services if the permission you gave us expressly permits such collection.  If you decline permission for us to collect your geolocation, we will not collect it.

Similarly, if you consent, we may collect your photos and videos (for instance, if you want to publish a photo, video or streaming on the services). We may also collect your  phonebook (for instance, if you want us to reach out to your friends on your behalf).

 

4.     COOKIES AND OTHER SIMILAR DATA COLLECTION TECHNOLOGIES

We use and may allow others to use cookies and similar technologies (e.g., web beacons, pixels) to recognize you and/or your device(s). You may read our Cookie Policy link for more information on why we use them (such as authenticating you, remembering your preferences and settings, analyzing site traffic and trends, delivering and measuring the effectiveness of advertising campaigns, allowing you to use social features) and how you can better control their use, through your browser settings and other tools.

Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) have a “Do Not Track” (“DNT”) feature that tells a website that a user does not want to have his or her online activity tracked.  If a website that responds to a DNT signal receives a DNT signal, the browser can block that website from collecting certain information about the browser’s user.  Not all browsers offer a DNT option and DNT signals are not yet uniform.  For this reason, many businesses, including Affiny, do not currently respond to DNT signals.

 

5.     HOW WE USE INFORMATION

The main reason we use your information is to deliver and improve our services.  Additionally, we use your info to help keep you safe and to provide you with advertising that may be of interest to you.  Read on for a more detailed explanation of the various reasons we use your information, together with practical examples.

To administer your account and provide our services to you

To help you connect with other users

To ensure a consistent experience across your devices

To serve you relevant offers and ads

To improve our services and develop new ones

To prevent, detect and fight fraud or other illegal or unauthorized activities

To ensure legal compliance

To process your information as described above, we rely on the following legal bases:

 

6.     HOW WE SHARE INFORMATION

Since our goal is to help you make meaningful connections, the main sharing of users’ information is, of course, with other users. We also share some users’ information with service providers and partners who assist us in operating the services, with other Match Group companies and, in some cases, legal authorities. Read on for more details about how your information is shared with others.

You share information with other users when you voluntarily disclose information on the service (including your public profile). Please be careful with your information and make sure that the content you share is stuff that you’re comfortable being publically viewable since neither you nor we can control what others do with your information once you share it.

If you choose to limit the audience for all or part of your profile or for certain content or information about you, then it will be visible according to your settings.

We use third parties to help us operate and improve our services.  These third parties assist us with various tasks, including data hosting and maintenance, analytics, customer care, marketing, advertising, payment processing and security operations.

We may also share information with partners who distribute and assist us in advertising our services. For instance, we may share limited information on you in hashed, non-human readable form to advertising partners.

We follow a strict vetting process prior to engaging any service provider or working with any partner.  All of our service providers and partners must agree to strict confidentiality obligations.

Affiny is part of the Match Group family of businesses which, as of the date of this Privacy Policy, includes websites and apps such as Tinder, OkCupid, Plenty of Fish, Match, Meetic, BlackPeopleMeet, LoveScout24, OurTime, Pairs, ParPerfeito, and Twoo (for more details, click here).

We share your information with other Match Group companies to benefit you in two respects:

We may also share information with other Match Group companies for legitimate business purposes such as corporate audit, analysis and consolidated reporting as well as compliance with applicable laws.  We may also share user information with other Match Group companies to remove users who violate our terms of service, or have been reported for criminal activity and/or bad behavior. In some instances, we may remove that user from all platforms.

We may transfer your information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control.

We may disclose your information if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government / law enforcement investigation or other legal requirements; (ii) to assist in the prevention or detection of crime (subject in each case to applicable law); or (iii) to protect the safety of any person.

We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.

We may ask for your consent to share your information with third parties. In any such case, we will make it clear why we want to share the information.

We may use and share non-personal information (meaning information that, by itself, does not identify who you are such as device information, general demographics, general behavioral data, geolocation in de-identified form), as well as personal information in hashed, non-human readable form, under any of the above circumstances.  We may also share this information with other Match Group companies and third parties (notably advertisers) to develop and deliver targeted advertising on our services and on websites or applications of third parties, and to analyze and report on advertising you see. We may combine this information with additional non-personal information or personal information in hashed, non-human readable form collected from other sources. More information on our use of cookies and similar technologies can be found in our Cookie Policy link.

Starting with iOS 14.5, Apple requires app publishers to receive their users’ permission through Apple’s AppTrackingTransparency (ATT) framework to track them or access their device’s advertising identifier and we are not showing Apple’s ATT prompt on our services because we do not take those actions for such iOS users.

7.     CROSS-BORDER DATA TRANSFERS

Sharing of information laid out in Section 6 sometimes involves cross-border data transfers, for instance to the United States of America and other jurisdictions. As an example, where the service allows for users to be located in the European Economic Area (“EEA”), their personal information is transferred to countries outside of the EEA. We use standard contract clauses approved by the European Commission or other suitable safeguard to permit data transfers from the EEA to other countries.  Standard contractual clauses are commitments between companies transferring personal data, binding them to protect the privacy and security of your data.

 

8.     YOUR RIGHTS

We want you to be in control of your information, so we have provided you with the following tools:

We want you to be aware of your privacy rights. Here are a few key points to remember:

For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer the above requests.

Keep in mind, we may reject requests for certain reasons, including if the request is unlawful or if it may infringe on trade secrets or intellectual property or the privacy of another user.  If you wish to receive information relating to another user, such as a copy of any messages you received from him or her through our service, the other user will have to contact our Privacy Officer to provide their written consent before the information is released.

Also, we may not be able to accommodate certain requests to object to the processing of personal information, notably where such requests would not allow us to provide our service to you anymore.  For instance, we cannot provide our service if we do not have your date of birth.

9.     HOW WE PROTECT YOUR INFORMATION

We work hard to protect you from unauthorized access to or alteration, disclosure or destruction of your personal information.  As with all technology companies, although we take steps to secure your information, we do not promise, and you should not expect, that your personal information will always remain secure.

We regularly monitor our systems for possible vulnerabilities and attacks and regularly review our information collection, storage and processing practices to update our physical, technical and organizational security measures.

We may suspend your use of all or part of the services without notice if we suspect or detect any breach of security.  If you believe that your account or information is no longer secure, please notify us immediately here.

 

10.  HOW LONG WE RETAIN YOUR INFORMATION

We keep your personal information only as long as we need it for legitimate business purposes (as laid out in Section 5) and as permitted by applicable law. To protect the safety and security of our users on and off our services, we implement a safety retention window of one year following account deletion. During this period, account information will be retained although the account will of course not be visible on the services anymore.

In practice, we delete or anonymize your information upon deletion of your account (following the safety retention window) or after two years of continuous inactivity, unless:

  1. we must keep it to comply with applicable law (for instance, some “traffic data” is kept for one year to comply with statutory data retention obligations);
  2. we must keep it to evidence our compliance with applicable law (for instance, records of consents to our Terms, Privacy Policy and other similar consents are kept for five years);
  3. there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or
  4. the 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.

Keep in mind that even though our systems are designed to carry out data deletion processes according to the above guidelines, we cannot promise that all data will be deleted within a specific timeframe due to technical constraints.

 

11.  CHILDREN’S PRIVACY

Our services are restricted to users who are 18 years of age or older.  We do not permit users under the age of 18 on our platform and we do not knowingly collect personal information from anyone under the age of 18.  If you suspect that a user is under the age of 18, please use the reporting mechanism available through the service.

12.  PRIVACY POLICY CHANGES

Because we’re always looking for new and innovative ways to help you build meaningful connections, this policy may change over time.  We will notify you before any material changes take effect so that you have time to review the changes.

 

13.  HOW TO CONTACT US

If you have questions about this Privacy Policy, here’s how you can reach us:

Online: here

By post:

Privacy Officer

MIL

C/O Skadden 40 Bank Street, Canary Wharf, London, E14 5DS