Welcome to Dgay Privacy and Cookie Policy. This Policy explains how Dgay LLC (Dgay or “we” or “us”) processes and puts you in control of your Personal Data. When we talk about processing Personal Data, we mean how we collect, use, share, and retain Personal Data. This policy covers these activities across all of our services (“Services” or “Grindr Services”). We have included [LEARN MORE] page links where we describe additional details you may find helpful.
PERSONAL DATA WE COLLECT - WHERE, WHEN, AND HOW
When you use the Dgay Services, we collect Personal Data about you. At Dgay, “Personal Data” means any information that allows someone to identify you directly. You choose to provide the majority of this data. We may collect data about your interactions, use, and experiences with our services and receive information from third parties. [LEARN MORE]
Personal Data You Are Required to Provide. When you set up an account, we require that you provide limited Personal Data such as email or phone number and date of birth.
Personal Data You Have the Option to Provide. You have a choice when providing your community profile information. For example, you may share location (failing to provide location may impact the functionality available in Dgay Services), HIV status, photos and videos.
Personal Data We Automatically Receive From Your Device When You Use Dgay Services. To keep the services running and to improve services, we collect user activity, hardware and software information, sensor activity and cookies, and leverage other tracking technologies such as web beacons, SDKs, local storage, and log files. [LEARN MORE]
Personal Data We Automatically Receive From Third Parties. Dgay collects limited information from third parties. For example, we may collect Personal Data from payment processors, ad partners, app usage and website tracking information, authentication partners, etc.
Permissible Age. The Dgay Services are intended only for users who are legal adults, generally eighteen (18) years of age and older. If you are aware that a child or minor has submitted Personal Data on the Dgay Services, please contact us using the information provided below, or using the in-app reporting tool, so that we can take appropriate action.
WHAT WE DO WITH YOUR PERSONAL DATA
We generally use your Personal Data to enable the Dgay Services, such as the following purposes:
Provide you with services and products associated with Dgay accounts to maintain, improve, and develop Services.
Provide safety and security features.
Communicate with you to provide updates, service-related notifications, and promotions.
Respond to user inquiries, complaints, and to provide customer service.
Process your purchases and transactions.
Conduct partner promotions.
Comply with valid legal requests and address legal issues and disputes.
Investigate and respond to suspected illegal activities or fraud.
Access your camera, photo roll and microphone to allow you share with other users.
Create and administer surveys and conduct research.
For Automated Decision Making - for example, to detect and remove spammers, detect and remove non-compliant images, etc. through artificial intelligence.
For users subject to the data privacy laws of the EEA and the U.K. we created a table to provide an overview of the legal bases on which we rely to process your Personal Data. [LEARN MORE]
HOW WE SHARE YOUR PERSONAL DATA WITH THIRD PARTIES
Dgay may share information we have about you for the purposes described in this Privacy Policy to assist us in providing the services you have requested. The majority of the sharing occurs between you and other users, but we also share with third parties such as Service Providers who work on Dgay behalf, Ad Partners, and when required, by law. Our Third Party Disclosure document provides more details. [LEARN MORE]
Other Users. Dgay provides a safe space where you can discover, navigate, and interact with others in the Dgay Community. Your profile data and distance information is also shared with the Dgay Community.
Third-Party Advertising Companies. In the past 12 months Dgay shared the following categories of Personal Data with our ad partners who provide payment for ad placement: cookie or device IDs (such as advertising ID), connection information (such as type, carrier, speed), opt-out status, and technographics (such as device model, brand, OS version).
Service Providers. Partners who assist Dgay with providing our services such as with crash reporting, payment and business transaction systems, website and app tracking and reporting tools, internal support tools (bug reporting, customer support systems, app ratings reporting, etc.).
Your Consent. Where you’ve given your consent for other disclosures, features, or services provided by Dgay.
Partner Promotions. We may promote programs and events with partners to offer discounts, early access, or other information or incentives to our users.
Legal Obligations . We may access, preserve and disclose information to investigate, prevent, or take action in connection with: (i) legal process and legal requests; (ii) enforcement of the Dgay Terms of Service ; (iii) claims that any content violates the rights of third-parties; (iv) requests for customer service; (v) technical issues; (vi) protecting the rights, property or personal safety of Dgay, its users or the public; (vii) establishing or exercising our legal rights or defending against legal claims; or (viii) as otherwise required by law.
HOW LONG WE KEEP YOUR PERSONAL DATA
We retain your Personal Data for no longer than is necessary to fulfill the purposes for which the information was collected or as otherwise permitted or required by applicable law or pursuant to Dgay Terms of Service or Dgay Community Guidelines. Personal Data may be retained for longer periods of time if required for legal or security purposes. For example, Dgay may retain some account information, a Dgay-generated device identifier, and limited log information for accounts that have been banned or that violate the Dgay Terms of Service and/or Community Guidelines . In some circumstances, Dgay may also retain chat messages used for reporting violative behavior resulting in an account’s ban. [LEARN MORE]
YOUR CHOICES AND RIGHTS
You can make the following choices and exercise your rights regarding your Personal Data held by Dgay:
Correct Profile Information. By creating an account, you are providing us Personal Data about yourself in your public Dgay Community Profile. You can review and change your Community Profile Information at any time by accessing the “Edit Profile” section of the App.
Delete Account and Related Information. You may delete your account and related information at any time. There are some scenarios where some or all of your information may be held after your request (such as for tax and accounting purposes, moderation review, dispute resolution, and other legal matters).
Promotional Emails. You may choose during the registration process to allow us to use your email address to send free newsletters, surveys, offers, and other promotional materials related to Dgay and/or the Dgay Services, as well as targeted offers from third parties. You can stop receiving promotional emails by following the unsubscribe instructions in emails that you receive. If you unsubscribe from receiving such promotional emails, we may still send you service-related communications, and our applications will continue to deliver you in-app messages.
Behavioral Advertising On Websites and the Dgay App. You can opt-out of the sharing of your Personal Data (“Sale”) with our Ad Partners. Please note that opting-out of behavioral advertising does not mean that you will not receive advertising while using the free version of Dgay Services. It will, however, exclude you from interest-based advertising conducted through participating networks, as provided by the applicable choice mechanisms. [LEARN MORE]
Third-Party Tracking. You may opt-out of Google Analytics' collection and use of your Personal Data by following the instructions here to download an opt-out browser add-on.
Access & Portability . You may request that we provide you with information about our processing of your Personal Data and provide you with a machine-readable copy. We may not be able to provide some elements of information if making the information available to you would also reveal Personal Data about another person or if we are legally prevented from disclosing such information.
Restrict Processing . Under certain circumstances, you may limit the way we process your Personal Data.
Withdraw Consent . You may withdraw consent that you have previously given us at any time. Revocation of your consent will only apply to future processing activities and will not apply retroactively. Dgay relies on your consent for live location sharing; your use of the Dgay Web Chat service; when you provide HIV status and last tested date; to access your camera and photo roll; sharing your Personal Data with advertising partners; for surveys; sharing Personal Data with analytics partners; and to facilitate messages between users.
Object to Processing . Where your jurisdiction’s law allows, you may object to us relying on our legitimate interests as the reason for why we process your Personal Data.
To make a request outside of your Dgay account please click here. Statistics pertaining to Dgay processing of access, erasure and opt-out requests can be found here. Dgay does not discriminate against users who exercise their rights as detailed in this section of the Privacy Policy.
HOW WE PROTECT YOUR PERSONAL DATA
At Dgay, we take the privacy and security of your Personal Data seriously. We have a dedicated data security team that actively works to monitor the integrity and safety of the Dgay Services. We have policies and protocols in place to help protect Personal Data. We consistently strive to improve our defenses in the ongoing battle against bad actors. That said, no method of transmission over the Internet, or method of electronic storage, is fully secure, and Dgay cannot guarantee the security of your Personal Data. In the event that we are required by law to inform you of any unauthorized access to your Personal Data, we may notify you electronically or in writing in accordance with applicable law.
HOW TO CONTACT US OR FILE COMPLAINTS
Contact Information. Dgay welcomes your comments, questions, or complaints regarding this Privacy and Cookie Policy, our use of your Personal Data, or our response to your requests regarding your Personal Data. Please contact us by email at privacy@Dgay.com or by postal mail at:
Contacting our DPO and EEA Representative. Individuals in the European Economic Area (EEA) also have the right to lodge a complaint with a supervisory authority in the EEA Country where they reside or work, or where the alleged infringement of the General Data Protection Regulation (EU) 2016/679 (“GDPR”) took place. You can find information about your data protection regulator here. Individuals in Switzerland also have the right to lodge a complaint with the Swiss Federal Data Protection and Information Commissioner. For complaints from Individuals in the EEA or Switzerland that cannot be resolved with Dgay directly, Dgay will cooperate with EEA and Swiss authorities and will implement the advice they provide with respect to such unresolved complaints.
If you are based in the EEA or have GDPR-related inquiries, you may contact our EEA Representative by submitting your request or inquiry to the postal address listed here for your country of residence.
You can also contact Dgay Data Protection Officer (DPO) by submitting a request through our website here.
Where necessary, we may request specific information from you to verify your identity prior