Privacy Policy

Last updated: 17 May 2024.

Welcome to Dating App (the “Platform”). The Platform is provided and controlled by Communications, Inc. (“Communications”, “we” or “us”). We are committed to protecting and respecting your privacy. This Privacy Policy covers the experience we provide for users age 14 and over on our Platform.

Capitalized terms that are not defined in this policy have the meaning given to them in the Terms of Service.

What information do we collect?

We collect information when you create an account and use the Platform, More information about the categories and sources of information is provided below. 

Information you choose to provide

For certain activities, such as when you register, upload content to the Platform, or contact us directly, you may provide some or all of the following information:

• Registration information, such as age, username and password, language, and email or phone number

• Profile information, such as name, account information, and profile image

• User-generated content, including  posts, texts, comments, photographs that you choose to upload or broadcast on the Platform (“User Content”)

• Your opt-in choices and communication preferences

• Information to verify an account 

• Information in correspondence you send to us

Information we obtain from other sources

We may receive the information described in this Privacy Policy from other sources, such as:

Social Media. if you choose to link or sign up using your social network (such as Google), we may collect information from these social media services, including your contact lists for these services and information relating to your use of the Platform in relation to these services.

Third-Party Services. We may collect information about you from third-party services, such as advertising partners and analytics providers.

Others Users of the Platform. Sometimes other users of the Platform may provide us information about you, including through customer service inquiries. 

Information we collect automatically

We automatically collect certain information from you when you use the Platform, including internet or other network activity information such as your IP address, geolocation-related data (as described below), unique device identifiers. 

We collect information regarding your use of the Platform and any other User Content that you generate through and broadcast on our Platform. We also link your subscriber information with your activity on our Platform across all your devices using your email, phone number, or similar information.

Device Information 

We collect information about the device you use to access the Platform, including your IP address, unique device identifiers, model of your device, your mobile carrier, time zone setting, screen resolution, operating system, app and file names and types, keystroke patterns or rhythms, and platform.

Location data

We collect information about your location, including location information based on your IP address. With your permission, we may also collect Global Positioning System (GPS) data.

Metadata

When you upload User Content, you automatically upload certain metadata that is connected to the User Content. Metadata describes other data and provides information about your User Content that will not always be evident to the viewer. In connection with your User Content the metadata can describe how, when, and by whom the piece of User Content was collected and how that content is formatted. It also includes information, such as your account name, that enables other users to trace back the User Content to your user account. Additionally, metadata will consist of data that you chose to provide with your User Content, e.g. any hashtags used to mark keywords to the captions.

We may aggregate or de-identify the information described above.  Aggregated or de-identified data is not subject to this Privacy Policy.

How we use your information

As explained below, we use your information to fulfill and enforce our Terms of Service, to improve and administer the Platform, and to allow you to use its functionalities. We may also use your information to, among other things, show you suggestions, promote the Platform, and customize your ad experience.

We generally use the information we collect:

• to fulfill requests for products, services, Platform functionality, support and information for internal operations, including troubleshooting, data analysis, testing, research, statistical, and survey purposes and to solicit your feedback

• to customize the content you see when you use the Platform. For example, we may provide you with services based on the country settings you have chosen or show you content that is similar to content that you liked or interacted with

• to send promotional materials from us or on behalf of our affiliates and trusted third parties

• to improve and develop our Platform and conduct product development

• to measure and understand the effectiveness of the advertising we serve to you and others and to deliver targeted advertising

• to make suggestions and provide a customized ad experience

• to support the social functions of the Platform, including to permit you and other users to connect with each other through the Platform and for you and other users to share, download, and otherwise interact with User Content posted through the Platform

• to use User Content as part of our advertising and marketing campaigns to promote the Platform

• to understand how you use the Platform, including across your devices

• to infer additional information about you, such as your age, gender, and interests

• to help us detect abuse, fraud, and illegal activity on the Platform

• to ensure that you are old enough to use the Platform (as required by law)

• to communicate with you, including to notify you about changes in our services

• to announce you as a winner of our contest, sweepstakes, or promotions if permitted by the promotion rule, and to send you any applicable prizes

• to enforce our terms, conditions, and policies

• consistent with your permissions, to provide you with location-based services, such as advertising and other personalized content

• to inform our algorithms

• to combine all the information we collect or receive about you for any of the foregoing purposes

• for any other purposes disclosed to you at the time we collect your information or pursuant to your consent.

How we share your information

We are committed to maintaining your trust, and while Dating App does not sell personal information to third parties, we want you to understand when and with whom we may share the information we collect for business purposes. 

For Legal Reasons

We may disclose your information to respond to subpoenas, court orders, legal process, law enforcement requests, legal claims, or government inquiries, and to protect and defend the rights, interests, safety, and security of Dating App Inc., the Platform, our affiliates, users, or the public. We may also share your information to enforce any terms applicable to the Platform, to exercise or defend any legal claims, and comply with any applicable law. 

With Your Consent

We may share information for other purposes pursuant to your consent or with your further direction.

If you access third-party services, such as Google to login to the Platform or to share information about your usage on the Platform with others, these third-party services may be able to collect information about you, including information about your activity on the Platform, and they may notify your connections on the third-party services about your use of the Platform, in accordance with their privacy policies.

If you choose to engage in public activities on the Platform, you should be aware that any information you share may be read, collected, or used by other users. You should use caution in disclosing personal information while engaging. We are not responsible for the information you choose to submit.

Your Rights

You may submit a request to access or delete the information we have collected about you by sending your request to us at the email or physical address provided in the Contact section at the bottom of this policy. We will respond to your request consistent with applicable law and subject to proper verification. And we do not discriminate based on the exercise of any privacy rights that you might have.

Your Choices

• You can switch off GPS location information functionality on your mobile device if you do not wish to share GPS information.

• If you have registered for an account you may access, review, and update certain personal information that you have provided to us by logging into your account and using available features and functionalities.

Security

We use reasonable measures to help protect information from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction. You should understand that no data storage system or transmission of data over the Internet or any other public network can be guaranteed to be 100 percent secure.

Children

The Platform otherwise is not directed at children under the age of 14. If we become aware that personal information has been collected on the Platform from a person under the age of 14 we will delete this information and terminate the person’s account. If you believe that we have collected information from a child under the age of 14 on the Platform, contact us at: info@comunication.org

Other Rights

Sharing for Direct Marketing Purposes (Shine the Light)

If you are a California resident, once a calendar year, you may be entitled to obtain information about personal information that we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information, as well as the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year. To submit a request, contact us at: info@comunication.org

Content Removal for Users Under 14

Users of the Platform who are are under 14 years of age may request and obtain removal of User Content they posted by contacting us at: info@comunication.org. All requests must be labeled "Removal Request" on the email subject line. All requests must provide a description of the User Content you want removed and information reasonably sufficient to permit us to locate that User Content. We do not accept Removal Requests via postal mail, telephone, or facsimile. We are not responsible for notices that are not labeled or sent properly, and we may not be able to respond if you do not provide adequate information. Please note that your request does not ensure complete or comprehensive removal of the material. For example, materials that you have posted may be republished or reposted by another user or third party.

Changes

We may update this Privacy Policy from time to time. When we update the Privacy Policy, we will notify you by updating the “Last Updated” date at the top of this policy and posting the new Privacy Policy and providing any other notice required by applicable law. We recommend that you review the Privacy Policy each time you visit the Platform to stay informed of our privacy practices.

Contact

Questions, comments and requests regarding this policy should be addressed to:

• Mailing Address: Dating App, Inc. Attn: Dating App Legal Department Manchester Road 123-78B, Silic town 7854MD, USA

• Contact us: info@comunication.org

SUMMARY

What information do we collect about you?

We collect and process information you give us when you create an account and use the Platform. This includes technical and behavioral information about your use of the Platform. We also collect information about you if you download the app and use the Platform without creating an account.

How will we use the information about you?

We use your information to provide the Platform to you and to improve and administer it. In order to provide an effective and dynamic Platform, and where we have determined it is in our legitimate interests, we use your information to improve and develop the Platform, prevent crime and ensure users’ safety. Where we have your consent, we will also use your personal data to serve you targeted advertising and promote the Platform.

Who do we share your information with?

We share your data with third party service providers who help us to deliver the Platform including cloud storage providers. We also share your information with business partners, other companies in the same group as Communications (including Communications Inc in the US which provides certain services for us in connection with the Platform), content moderation services, measurement providers, advertisers and analytics providers. We may share your information with law enforcement agencies, public authorities or with other third parties only where we are legally required to do so or if such use is reasonably necessary (for instance, to ensure your or someone else’s safety).

Your Rights

We offer you settings to control and manage the personal data we have about you. You also have the following rights: you can ask us to delete your data; to change or correct your data; to provide a copy of your data and to stop using some or all of your data. You can also contact us using the contact information below, and we will review your request in accordance with applicable laws.

How long do we keep hold of your information?

We retain your information for as long as it is necessary to provide you with the service so that we can fulfil our contractual obligations and exercise our rights in relation to the information involved. Where we do not need your information in order to provide the service to you, we retain it only as long as we have a legitimate business purpose in keeping such data or where we are subject to a legal obligation to retain the data. We will also retain your data if necessary for legal claims.

How will we notify you of any changes to this Privacy Policy?

We will notify all users of any material changes to this policy through a notice on our Platform or by other means. We update the “Last Updated” date at the top of this policy, which reflects the effective date of the policy. By accessing or using the Platform, you acknowledge that you have read this policy and that you understand your rights in relation to your personal data and how we will collect, use and process it.

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1. The types of personal data we use

We collect and use the following information about you:

Your Profile Information

You give us information when you register on the Platform, including your username, date of birth, email address and/or telephone number, information you disclose in your user profile and your photograph.

User Content and Behavioral Information

We process the content you generate and view on the Platform, including preferences you set, photographs you upload, comments you make (“User Content”). We collect information through surveys, challenges and competitions in which you participate. We also collect information regarding your use of the Platform, e.g. how you engage with the Platform, including how often you use the Platform and how you interact with content we show you.

We infer your interests, gender and age for the purpose of personalizing content. We also infer the interests of our users to better optimize advertising across our Platform. If you have consented, we will use this information for the purpose of serving personalized advertising. 

We review User Content for content moderation purposes to enforce our community guidelines, comply with legal obligations, and prevent and respond to abuse, fraud, illegal activity and other potentially harmful content on the Platform. 

We also process information about your followers, the likes you receive and responses to content you upload, for the purposes of personalizing your "For You" Feed, promoting your content to other users and exploring whether your profile presents opportunities for collaboration. 

We do this to prevent and block spam, prevent and detect crime, safeguard children (where this is in the substantial public interest) or to protect the interests of our users and other people. 

Please also be aware that messages sent to other users of the Platform will be accessible by those users and that we are not responsible for how those users use or disclose them.

Information from Third Parties

You may choose to share certain data with us from third parties or, through your use of the Platform.

Business Partners

If you choose to register to use the Platform using your social media account details (e.g. Google), you will provide us or allow your social network to provide us with your username and public profile. We will likewise share certain information with the relevant social network such as your app ID, access token and the referring URL. For further information on sharing your Google accoubnt info with us.

Advertisers and Measurement Partners

Where you have consented to personalized advertising, we will match your information e.g. your mobile advertising ID, where it is provided to us by advertisers and other partners, with your Dating App profile to serve you ads. We may also serve you ads based on the information we infer from the data these partners provide. You can opt out of this activity at any time via your app settings by going to 'Privacy and safety' and then to 'Personalization and data' and opting out of ‘Ads based on data received from partners’.

We use information provided by our measurement partners, to understand how you’ve interacted with our ad partners’ websites and better assess the effectiveness of the advertising on our Platform. 

Technical Information we collect about you

We collect certain information from you when you use the Platform including when you are using the app without an account. Such information includes your IP address, instance IDs (which allow us to determine which devices to deliver messages to), time zone settings, identifier for advertising purposes and the version of the app you are using. We will also collect information regarding the device you are using to access the Platform such as the model of your device, the device system, network type, device ID, your screen resolution and operating system, Where you log-in from multiple devices, we will be able to use your profile information to identify your activity across devices.

Location

When you use the Platform on a mobile device, we will collect information about your location in order to customise your experience. We infer your approximate location based on your IP address. In certain jurisdictions, we may also collect Global Positioning System data.

We use your personal data to find matches based on your contact information and your address book. However, your contact information and your address book is private and will not be disclosed. We use a technical system to find matches without sending your own information or your address book to us in plain text. 

We also collect information you provide to us in correspondence.  

2. How we use your personal data

We will use the information we collect about you based on the legal grounds described below.

In accordance with, and to perform our contract with you, we will use your information to:

• provide the Platform and associated services;

• notify you about changes to our service;

• provide you with user support;

• enforce our terms, conditions and policies;

• administer the Platform including troubleshooting;

• personalize the content you receive and provide you with tailored content that will be of interest to you;

• enable you to share User Content and interact with other users;

• enable our messenger service to function if you choose to use it and are 16 or above;

• enable you to participate in the virtual items program; and

• communicate with you.

In order to comply with our legal obligations and as necessary to perform tasks in the public interest or to protect the vital interests of our users and other people, we use your data to help us prevent and respond to abuse, fraud, illegal activity and other potentially harmful content on the Platform.

In accordance with our legitimate interests to provide an effective and dynamic Platform, we may use your information to:

• ensure your safety and security, including reviewing User Content, messages and associated metadata for breaches of our Community Guidelines and our Terms of Service;

• ensure content is presented in the most effective manner for you and your device;

• understand how people use the Platform so that we can improve, promote and develop it;  

• promote popular topics, hashtags and campaigns on the Platform;

• carry out data analysis and test the Platform to ensure its stability and security;

• provide non-personalized advertising, which keeps many of our services free; 

• infer your interests for optimizing our advertising offerings, which, where you’ve consented to personalized advertising, may be based on the information our advertising partners provide to us;

• measure the effectiveness of the advertising you see on our Platform;

• inform our algorithms so we can deliver the most relevant content to you and to prevent crime and misuse of the Platform;

• carry out surveys regarding our services, products and features; 

• allow you to participate in interactive features of the Platform; and

• enable you to socialize on the Platform. For example, we may allow other users to identify you via the "Find Friends" function or through their phone contacts or connect you with other users by tracking who you share links with.

Where we process your information to fulfill our legitimate interests, we conduct a balancing test to check that using personal data is really necessary for us to achieve our business purpose. When we carry out this balancing test we also take into account the privacy rights of our users and put in place appropriate safeguards to protect their personal data.

3. How we share your personal data

We share your data with the following selected third parties:

Business Partners

• If you choose to register to use the Platform using your social network account details (e.g. Google), you provide us or allow your social network to provide us with your username and public profile. We will likewise share certain information with the relevant social network such as your app ID, access token and the referring URL.

Service Providers

• We provide information and content to service providers who support our business, such as cloud service providers and providers of content moderation services to ensure that the Platform is a safe and enjoyable place.

Analytics and measurement providers

• We use analytics and measurement providers to help us improve the Platform including by assisting us with content measurement and following your activity on our Platform across your devices. 

• Our third party analytics and measurement providers also help us measure advertising on our Platform and help our advertisers determine whether their advert has been shown on our Platform and how it performed. We share your mobile advertising ID and other device data with measurement companies so that they can link your activity on the Platform with your activity on our advertisers’ websites.

Advertisers

• We only share aggregated user information with advertisers. Aggregated information is information that is grouped together and is not specific to an individual user. This is done to help measure the effectiveness of an advertising campaign by showing advertisers how many users of the Platform have viewed or clicked on an advertisement. 

Our Corporate Group

• We may share your information with other members, subsidiaries, or affiliates of our corporate group where it is necessary to provide the Platform in accordance with the Terms of Service. 

• We share information to improve and optimize the Platform, including to prevent illegal use and to support users.

Law Enforcement / Legal Obligation

• We may share your information with law enforcement agencies, public authorities or other third parties if we consider that we are legally required to do so or if such use is reasonably necessary to:

• comply with a legal process or request;

• enforce our Terms of Service and other agreements, policies, and standards, including investigation of any potential violation;

• detect, prevent or otherwise address abuse, fraud, illegal activity or security or technical issues; or

• protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction).

Public Profiles

• If your profile is public, your content will be visible to anyone on the Platform and may also be accessed or shared by your friends and followers as well as third parties such as search engines, content aggregators and news sites. You can change who can see a video each time you upload a video. You can also change your profile to private by changing your settings to 'Private account' in 'Privacy and safety' settings. If your profile is public, other users can use your content to produce and upload further content, for example, by creating a duet with your video.

Sale or Merger

• We disclose your information to third parties:

• in the event that we sell or buy any business or assets (for example, as a result of liquidation, bankruptcy or otherwise). In such transactions, we will disclose your data to the prospective seller or buyer of such business or assets; or

• if we sell, buy, merge, are acquired by, or partner with other companies or businesses, or sell some or all of our assets. In such transactions, user information may be among the transferred assets.

4. Where we store your personal data

The personal data that we collect from you will be transferred to, and stored at, a destination outside of the European Economic Area ("EEA").

Where we transfer your personal data to countries outside the EEA, we do so under the European Commission’s model contracts for the transfer of personal data to third countries (i.e. standard contractual clauses) pursuant to Commission Decision 2004/915/EC or 2010/87/EU (as appropriate) or in line with any replacement mechanism approved under EU law. For a copy of these Standard Contractual Clauses, contact us at: info@datingapp.world

5. Your Rights

We offer you settings to control and manage the personal data we have about you. 

You have the following rights:

• Access Your Data: You can ask us, free of charge, to confirm we process your personal data and for a copy of your personal data.

• Delete Your Data: You can ask us to delete all or some of your personal data. 

• Change or Correct Data: You can ask us to change or fix your data. You can also make changes using the in-app controls and settings.  

• Portability: You can ask for a copy of personal data you provided in a machine readable form.

• Object or Restrict Use of Data and Withdraw Consent: You can ask us to stop using some or all of your data, e.g. if we have no legal right to keep using it. You can ask us to stop processing your personal data for direct marketing purposes; withdraw your consent or ask us to stop making any automatic individual decisions, including profiling. If you object to such processing, we ask you to share the reason for your objection in order for us to examine the processing of your personal data and to balance our legitimate interest in processing and your objection to this processing.

Before we can respond to a request to exercise one or more of the rights listed above, you may be required to verify your identity or your account details.

For information about how to make these requests, you can contact us using the contact information below, and we will review your request while considering applicable laws. Dating App Ireland will be responsible for responding to your request within the relevant periods provided by law. If necessary to resolve your request, Dating App Ireland will liaise with Dating App USA.

6. The security of your personal data

We take steps to ensure that your information is treated securely and in accordance with this policy. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, for example, by encryption, we cannot guarantee the security of your information transmitted via the Platform, which means any transmission is at your own risk. 

We have appropriate technical and organizational measures to ensure a level of security appropriate to the risk that may be posed to you and other users. We maintain these technical and organizational measures and will amend them from time to time to improve the overall security of our systems.

We will, from time to time, include links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any information to these websites. 

7. How long we keep your personal data

We retain your information for as long as it is necessary to provide you with the service so that we can fulfil our contractual obligations and exercise our rights in relation to the information involved. Where we do not need your information in order to provide the service to you, we retain it only for so long as we have a legitimate business purpose in keeping such data. 

If you ask us to delete your account it will first be placed into a deactivated state for 30 days (to allow you to request it to be reinstated), followed by the deletion of the account. We will also delete personal data that relates to the in-app messaging function within 30 days of you cancelling your user account. Please note that messages sent to other users of our service are stored on their devices and cannot be deleted by us. 

In each case, there are also occasions where we may need to keep your data for longer in accordance with our legal obligations or where it is necessary for legal claims.

8. Information relating to children

Dating App is not directed at children under the age of 17. If you believe that we have personal data about or collected from a child under the relevant age, contact us at: info@communication.org

9. Changes

We will notify you of any material changes to this policy through a notice provided via the Platform or by other means. The “Last Updated” date at the top of this policy reflects the effective date of such policy changes. 

10. Who we are and how to contact us

Dating App Ireland and Dating App USA provide the Platform and associated services, and together process personal data in the manner described in this policy and in our Terms of Service. For users of the Platform in the EEA and Switzerland, Dating App Ireland is the service provider in accordance with our Terms of Service and if you are in the USA, the provider of the Platform is Dating App USA. Dating App Ireland and Dating App USA share information as joint controllers of your data where it is necessary to do so to operate the Platform efficiently and in line with applicable laws.

If you have questions or complaints regarding this policy, or if you wish to reach the Dating App's Data Protection Officer, contact us at: info@comunication.org.

Verifying your identity: For your safety and to allow us to make sure that we do not disclose any of your personal data to unauthorized third parties, in order to verify your identity and guarantee the adequate exercise of your rights, we may request specific information and/or documents from you before we can properly respond to a request received concerning your data. All data and documents received from you in the process of responding to your requests will be used for the strict purposes of analyzing your request, authenticating your identity, and finally responding to your request.

Limitations to your rights: In certain situations, we may have legitimate reasons not to comply with some of your requests. For instance, we may choose not to disclose certain information to you when a disclosure could adversely impact our business whenever there is a risk of violation to our trade secrets or intellectual property rights. In addition, we may refrain from complying with a request for erasure when the maintenance of your data is required for complying with legal or regulatory obligations or when such maintenance is required to protect our rights and interests in case a dispute arises. Whenever this is the case and we are unable to comply with a request you make, we will let you know the reasons why we cannot fulfill your request.

Contact: In case of doubt about your privacy, your rights or how to exercise them, please contact us through the form "Contact". If you have any questions about the processing of your personal data, we would like to clarify them.

Access Logs. We keep your application access logs, under confidentiality, in a controlled and safe environment, for, at least, 6 months, in order to comply with legal obligations.

Language. The Policy may have been prepared in the English language.