2. Information we collect
The information we collect can be divided into the following broad categories:
More specifically, we may collect and store the following information relating to you:
2.1 Anonymous data
2.2 Direct Interactions
We collect information from you when you voluntarily submit information directly to us or via our Website. For members, this refers to personal data you provide when, for example, you create an account, complete a profile, or by corresponding with us via phone, email or live chat. This personal information may include name, age, address, phone and email, as necessary to set up your account. If you connect to the Website using credentials from a third-party application (e.g., Facebook), you authorize us to collect your authentication information, such as your username and encrypted access credentials. We may also collect other information available on or through your third-party application account, including, for example, your name, profile picture, country, hometown, email address, date of birth, gender, friends' names and profile pictures, and networks.
You may decide to provide us with another person's contact information so that person may be invited to join our Service or so that we may facilitate your communication with other people through the Service (such as when you upload an address book or a contact list). You may also provide us with another person's contact information for purposes of delivering information through social networking applications. We store the information that you provide so that the respondents may be added to your network, and also to send reminders of the invitations. All invitees are provided with the option not to receive further invitations from us.
In addition to the information we may collect upon your initial registration, we may ask you for personal information at other times. We will not share that information in a manner that identifies you as an individual with any other entity unless we have your permission.
2.3 Information submitted by you for inclusion on the Website
Please remember that if you post any of your personal information in public areas of the Website, such as in online forums or chat rooms, such information may be collected and used by others over whom we have no control. We are not responsible for the use made by third parties of information you post or otherwise make available in public areas of the Website. You should take care to not use personal information in your screen name or other information that might be publicly available to other users.
2.4 Tracking technologies
2.5 Automated technologies or interactions
As you interact with our Website, we may automatically collect technical and usage data about your device, browsing actions and patterns. For example, we collect information which may include your IP address, browser type, your location, language preferences, device information and access times. While an IP address does not identify an individual by name, it may, with the cooperation of the ISP, be used to locate and identify an individual. Your IP address can reveal what geographic area you are connecting from, or which ISP you are using. Finally, other websites you visit have IP addresses, and we may collect the IP addresses of those websites and their pages. We also collect IP addresses for system administration and to report aggregate information to any sponsors. We may also receive information from our web logs, which automatically record anything a web server sees, which may include email addresses you enter into a form or pages viewed by a user at a particular IP address. We collect this personal data by using cookies, pixel tags and other similar tracking technologies. The sole purpose of passively collecting your information is to improve your experience when using our Website.
2.6 Payment data
If you purchase a subscription to our Service or make other purchases through the Website, your credit or debit card information (such as card type and expiration date) and other financial data that we need to process your payment may be collected and stored by us and/or the payment processors with which we work. We may also collect some limited information, such as your postal code, mobile number, and details of your transaction history, all of which are necessary to process your purchase. In addition, the payment processors generally provide us with some limited information related to you, such as a unique token that enables you to make additional purchases using the information they've stored, and your card's type, expiration date, and certain digits of your card number.
2.7 Promotions & surveys
2.8 Information received from our service providers and partners
We may also receive information about you from our service providers and partners, which we use to personalize our Service, to measure ad quality and responses to ads, to display ads that are more likely to be relevant to you, and to offer you opportunities to purchase products or services that we believe may be of interest to you.
3. How we use the information we collect
We have set out below, in a table format, a description of all the ways we process your personal data, and the legal basis we rely on to do so.
|Purpose/Activity||Type of Data||Legal Basis|
|To allow you to visit the Website||Technical Data, Usage Data||Consent|
|To allow you to create an account||Identity Data,Usage Data||Consent|
|To register you as a paid member and process renewal of your membership||Financial Data, Identity Data||Consent|
|To manage our relationship with you. For example general enquiries such as how the Website works, complaints and payment queries||Any data you choose to share with us or request us to view||Consent|
|To administer and protect the Website (including troubleshooting, fraud prevention, spam prevention, security incident prevention and correction, data analysis, testing, system maintenance, support, reporting and hosting of data), operate the Website (including notifying you of any changes), optimize your user experience, and send you service and support messages such as updates, patches and security alerts||Financial Data, Identity Data, Technical Data, Usage Data||Consent|
|To send you promotional messages, marketing, advertising and other such information we think may be of interest to you, either directly or through one of our partners; you may opt out from receiving certain messages, as described in Section 7||Financial Data, Identity Data, Technical Data, Usage Data||Consent|
|To enable you to partake in a prize draw, competition, referral scheme, rewards program, promotional activities, events, complete a survey or invite you to participate in Website testing||Financial DataIdentity DataTechnical Data||Consent|
|To analyze your use of the Website and deliver relevant website content and third-party advertisements, for example by providing customized, personalized, or localized content, recommendations, features, and advertising.||Usage Data||Consent|
|To enable third parties to advertise products or services in which you may be interested, including via emails||Identity Data, Usage Data, Technical Data||Consent|
|To maintain and retain records in connection with actual and potential legal claims and regulatory investigations; and for governance & compliance purposes||Financial Data, Identity Data, Usage Data, Technical Data||Necessary for the compliance with a legal obligation to which we are subject|
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, in compliance with the above rules, where this is required or permitted by law.
4. How we share the information we collect
This section describes how the information collected or generated through your use of the Website may be shared by us with third parties.
4.1 Marketing and advertising
We share information with advertising partners in order to send you promotional communications about our Website or to show you more tailored content, including relevant advertising for third-party products and services that may be of interest to you, and to understand how users interact with advertisements. We also share personally identifiable information with third-party advertisers to enable them to provide you with opportunities to learn of products or services in which you may be interested.
We may also share aggregate user information in a non-personally identifiable manner with advertisers and other third parties in order to present to users more targeted advertising, products and services.
4.2 Service providers
To provide you with the best experience on our Website, we use third parties who automatically process your Usage Data on our behalf. Where possible, we will make sure this data is anonymized.
For your information, click here to view some examples of how third parties process your personal data.
4.3 Affiliate networks
If you access our Website through an offer that you received or purchased from a third party, we may also share information with that third party about your use of the Website, such as whether and to what extent you have used the offer, activated an account, or actively used our Service.
4.4 Promotions and surveys
When one or more of our business partners co-sponsor a service, promotion, contest/sweepstakes, or survey, we may share some or all of the information collected in connection with such service, promotion, contest/sweepstakes, or survey with the co-sponsor(s). If we intend to share such information, you will be notified prior to the collection of that information. If you do not want your information to be shared, you will be able to choose not to allow the transfer by not using or signing up for that particular service, promotion, contest/sweepstakes, or survey.
5. Cookies and other tracking technologies
A cookie is a small text file that is placed on your computer, mobile phone, or other device when you visit a website. The cookie will help website providers to recognize your device the next time you visit their website. There are other similar technologies such as pixel tags (transparent graphic images placed on a web page or in an email, which indicate that a page or email has been viewed), web bugs (similar to pixel tags), and web storage, which are used in desktop software or mobile devices.
There are also technologies such as mobile device identifiers and SDK integrations to help companies recognize your device when you return to an app or otherwise use a service.
Our policy regarding cookies can be found here.
6. Information collected by third parties
Please read these third parties' privacy policies to find out how they collect and process your personal information.
7. Email Opt-out
Users who no longer wish to receive our email updates or other notifications may opt out of receiving these communications by following the instructions contained in the applicable email or by logging in and changing their account settings. Please know that such a decision will not stop advertising or content that is generated prior to the time when we can accomplish the removal of your information.
8. Credit Card Processing
Credit card transactions are handled by a third-party processor that receives credit card numbers and other personally identifying information only to verify credit card accounts and process transactions.
Credit card security is an important aspect of the online experience. We use encryption technology to keep your credit card information safe. To ensure that your information is even more secure, once we receive your credit card information, it is stored on a server that isn't accessible from the Internet.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, altered or disclosed, used or accessed in an unauthorized way. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know it. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. However, the transmission of data via the internet is not completely secure and we cannot guarantee that unauthorized parties will not be able to defeat those measures: unauthorized entry or use, hardware or software failure, and other factors may compromise the security of our user information at any time.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
10. Children and COPPA compliance
We believe that parents should supervise their children's online activities and consider using parental control tools available from online services and software manufacturers that help provide a kid-friendly online environment. These tools can also prevent children from otherwise disclosing online their name, address and other personal information without parental permission.
11. Business transitions
12. California user consumer rights
If you are a California resident, you have the rights set forth in this Section. Please see the “Exercising Your Rights” paragraph below for instructions regarding how to exercise these rights.
You have the right to request certain information about our collection and use of your personal data over the past 12 months. In response, we will provide you with the following information:
If we have disclosed your personal data to any third parties for a business purpose over the past 12 months, we will identify the categories of personal data shared with each category of third party recipient. If we have sold your personal data over the past 12 months, we will identify the categories of personal data sold to each category of third party recipient.
You have the right to request that we delete the personal data that we have collected about you. Under the California Consumer Privacy Act (“CCPA”) this right is subject to certain exceptions: for example, we may need to retain your personal data to provide you with the Service or complete a transaction or other action you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request.
12.3 Exercising Your Rights
To exercise the rights described above, you or your Authorized Agent (defined below) must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected personal data, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use personal data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.
We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.
You may submit a Valid Request using the following methods:
You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.
12.4 Personal Data Sales Opt-Out and Opt-In
Under the CCPA, the definition of “sale” is very broad. It includes the transfer or sharing of personal information with a third party for any value, monetary or not. While we do not sell personal information for monetary value, we do sometimes transfer it to third parties as part of a business relationship. Accordingly, we refer to the “sale” of personal information as “data sharing”. If you are a California resident, you have the right to opt out of the sharing of your personal data with third parties (subject to certain exceptions). It is important to note that sharing personal information with service providers who provide goods and services or perform other business functions on our behalf is not a “sale.” For purposes of this Section, a service provider is not a “third party.” It is also not a “sale” if a consumer directs us to share personal information with a third party or otherwise intentionally interacts with a third party via our Website.
We sell your personal data to the following categories of third parties:
Over the past 12 months, we have sold the following categories of your personal data to categories of third parties listed below:
You have the right to opt out of the sale of your personal data. You can opt-out using the following methods:
Once you have submitted an opt-out request, we will not ask you to reauthorize the sale of your personal data for at least 12 months.
To our knowledge, we do not collect or sell the personal data of minors under 16 years of age.
12.5 We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA
We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA. However, we may offer different tiers of our Service as allowed by applicable data privacy laws (including the CCPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of personal data that we receive from you.
12.6 Annual Records
This chart provides statistics about our responses to requests from California residents over the past calendar year:
|Requests to Know||Requests to Delete||Requests to Opt-Out|
|Requests complied with:||0||0||0|
|Median response time (in days):||0||0||0|
In accordance with California Civil Code Sec. 1789.3, California resident users are entitled to know that they may file grievances and complaints regarding our Service with the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs, in writing at 1625 North Market Blvd., Sacramento, CA 95834, by telephone at (916) 445-1254 or (800) 952-5210, or by email to firstname.lastname@example.org.
In addition, under California law you are entitled to be advised how we handle “Do Not Track” browser signals. We do keep track of your browsing activities when we serve you content, which enables us to tailor what advertisements we present to you. We do not currently take actions to respond to Do Not Track signals because a uniform technological standard has not yet been developed. We continue to review new technologies and may adopt a standard once one is created.
13. Nevada users: Your privacy rights
Nevada law requires website operators to provide a way for Nevada consumers to opt out of the sale of certain information that the website operator may collect about them. If you are a Nevada resident and wish to submit such a request, please contact us at email@example.com
14. Users located outside of the United States
15. EU users' rights under the GDPR
If you are located in the European Union, or if the EU's General Data Protection Regulation ("GDPR") otherwise applies to your data as processed by us, you have the right to:
If you wish to exercise any of the rights set out above or request details about the specific legal basis we are relying on to process your personal data, please email us at firstname.lastname@example.org using the Subject Access Request Form.
We will respond to you within 30 days of receipt of your request. Occasionally it may take us longer than 30 days 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.
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 your other legal rights). This is a security measure to ensure that your personal data is not disclosed to any person who does not have the 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.
You will not have to pay a fee to access your personal data (or to exercise any of your other legal 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.
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please email us at email@example.com in the first instance.
16. Data retention
If you are located in the European Union, or if the GDPR otherwise applies to your data as processed by us, we will only retain your personal data for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or internal reporting 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.
In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for compliance, governance, legal and/or regulatory purposes in which case we may use this information indefinitely without further notice to you.
17. Cooperation with law enforcement; fraud protection
We fully cooperate with law enforcement agencies in identifying those who use our Website or Service for illegal activities. We reserve the right to disclose information about members who we believe are in violation of applicable laws or regulations, or as required to respond to a subpoena, court orders or other legal process requiring such disclosure. We also reserve the right to report to law enforcement agencies any activities that we reasonably believe to be unlawful and to exchange information with other companies and organizations for fraud protection.
Please note that if you opt out of receiving notices from us, change notices will still govern your use of the Website, and you are responsible for reviewing such legal notices for changes, as posted on the Website.