Privacy Policy

At Safer Date Ltd, your privacy is a top priority. We work hard to keep your data secure. This privacy policy explains what personal data Safer Date Ltd collects, how we use this data and what rights you have as a Safer Date Ltd user in relation to your personal data. The controller of your personal data is Safer Date Ltd, John Buddle Work Village, Buddle Road, Newcastle Upon Tyne, NE4 8AW (hereafter “Safer Date Ltd”, “us”, “our”, “we”).Unless otherwise stated in this privacy policy, the controller of your personal data is Safer Date Ltd.If you have any questions or suggestions about how we use your personal data, please contact us or our data protection officer.Our contact details are as follows:Safer Date Ltd, John Buddle Work Village, Buddle Road, Newcastle Upon Tyne, NE4 8AWYou can reach our data protection officer at:[email protected] (e-mail)

Collection, processing and use of personal data

Personal data is any information relating to an identified or identifiable natural person (e.g., name, address, phone number, date of birth or e-mail address).When we say that we process personal data, this means that we collect, store, use, transfer to others or delete such data.Safer Date collects and processes your personal data exclusively in the following cases:
  • If you visit us on our website without being a member.
  • If you contact us directly.
  • If you subscribe to a Safer Date membership and then use Safer Date.
Once you have signed up for a Safer Date account and have passed our verification procedures, we will provide you with access to an online database over which you will be able to get know other Safer Date-registered customers (also known as members). In order to provide you with the Safer Date service as described in the General Terms and Conditions (the “Safer Date Service” or “Service”), we need to use your personal data. If you do not want us to use your personal data, we will not be able to provide you with the Service. You will also need to provide us with special categories of personal data (i.e. sensitive personal data), such as information about your sexual orientation). Please see below for further information about the types of personal data Safer Date collects when you use our Service.In order to register for the Safer Date Service, you will need to provide us with the personal data described below. In addition, in order to provide you with our Services (as more fully described in the General Terms and Conditions), we need to process this personal data.

Registration process

In order to register for the Safer Date service, you will need to provide us with personal data without which the registration cannot be completed. This data includes:
  • Full Name
  • Address
  • Email address
  • Password
  • Passport/Driving License

Data required in connection with a Safer Date Membership

Our Service works by providing your profile information (“profile”) and your compatibility scores to other Safer Date users. In order to get the full benefit of our Service and to set up your Safer Date profile, we will ask you to provide us with personal data about you. This may include information about your personal values and preferences, your appearance, and any other characteristics that are relevant for us to personality profile and to recommend potential partners (“matches”) to you. When designing your profile, you will also need to provide us with information about yourself, including text and photos.When we ask you to provide us with information about you during the registration process, we make it clear when such information will be kept private and will not be made available to other users. Additionally, the information you voluntarily provide for hobbies and interests will be visible to your matches in your profile, but you may update or delete this information at any time. All other information you provide us with for or as part of your Safer Date profile will be publicly visible to other members on our website, such as information that you voluntarily choose to include in your profile, especially place of residence /postal code, and your interests.We will not be able to suggest matches for you if you do not provide us with the requested information relating to your sexual preferences (i.e. both preferred sex and gender). If you do not want to provide us with this information, you will not be able to use our Service.Generally, the types of data that we will collect during the registration are as follows:
  • Residence/postal code
  • Country of residence
  • Date of birth
  • Full name
  • Height
  • Number of children
  • Marital status
  • Education level
  • Occupation
  • Income
In addition, you may choose to provide us with sensitive information such as:
  • Religion
  • Ethnicity
  • Political view
By giving us this information, you agree that we store and use this information for matching purposes. This information allows us to further refine the match preferences and search criteria available to you when searching for a partner on our platform. This information will be disclosed in your profile, and therefore, visible to matches who visit your profile. However, please note that you do not have to provide us with all of this information in order to use the Safer Date Service, and you may change your answers at any time in your profile.You may also upload photos of yourself in your profile, whereby other members may see, next to your first name, your photos clearly (i.e. unblurred version) in your profile or in a blurred version via email. Please note that you do not have to upload any photos in order to use the Safer Date Service. You may upload photos to your profile at any time, even after you completed your registration or already used the Service for a period of time.You do not have to provide us with your mobile phone number in order to use the Safer Date Service. However, if you want to, you can provide it to us for an additional security measure (known as “SMS verification”). This functionality is available to all our members but only after logging in to our Safer Date Service. This will allow us to carry out a further identification check to make sure that you are the right person to be using your profile – please see more on this below.When you sign up for a Safer Date membership, we will collect your payment data during your order. However, please note that your credit card data is not stored by us, but is instead stored by a third-party payment provider.

Communication with the members, communication with our customer care and communication via video chat

If you correspond with other Safer Date members through the Safer Date platform, or with Safer Date customer care, we will collect and store this information.If you contact our customer care, please note the following: if you communicate with our customer care:
  1. using the online contact form
  2. via email: this information will only be protected in transit via TLS transfer encryption if your email provider supports TLS transport encryption.
If you would prefer not to contact our customer care by email (for example, because you are concerned that your email provider does not support TLS encryption or the content of our email is not encrypted), please contact Safer Date by post instead.

Promotional emails – Messages

When you subscribe for our membership, you must enter your email address on the welcome page. Unless you opt out in the registration process, we will use this email address to send you promotional emails about Safer Date’s products and special offers.In your profile under “Notification options,” you can also choose to receive personalised matches and guidance during your Safer Date membership, to help you to get the most out of the Safer Date Service.As long as your email provider supports “Transport Layer Security” (TLS) transport encryption, these promotional emails (including our personalised guidance) are protected in transit via TLS transfer encryption.You can object to our use of your email address for promotional purposes or personal advices, upon registration and or later at any time, either by: (i) clicking on the link in our emails to adjust your email notification settings, (ii) adjusting your settings in your profile under “Notification options”, or (iii) contacting us using the information in the Contact section. You may re-subscribe to receive such promotional emails in your profile under “Notification options” at any time.

What information does Safer Date collect when using the Safer Date platform?

Every time you access the Safer Date website or app, we will collect your usage data. This means that, even if you have not signed up to be a Safer Date member, we will collect and use this information about you. This data is sent to us by your Internet browser and is stored in log files. This data includes:
  • Information about your browser type and your internet service provider, as well as your operating system (for example Windows 7, Apple OS, etc.)
  • The IP address (Internet Protocol address) of the device you use to access our website or Service (for example, your computer, tablet or smartphone). We will also compare your IP address against a geo-database to collect information about your location, such as your country, state and city.
  • Information about the page that you have accessed
  • The date and time that you used the website
  • The referrer URL (origin URL) from which you came to the page that you have accessed
  • Statistics about the amount of data transmitted during your use of the website
  • Status message as to whether you were successfully able to access the website
  • Session identifier
  • Session participant´s pseudonym
  • Screen resolution used on your device

Login data

We also collect the following usage data each time a Safer Date member logs in to our network (“login records”):
  • Date and time of login
  • User identifier on the Safer Date platform (your e-mail address)
  • IP address (Internet Protocol Address)
  • Device ID (e.g. UDID) to identify your device for a secured authentication.

GPS data

When a Safer Date Member turns on the “radius search” option, we also collect location data about their device (such as GPS, possibly WLAN information, and device ID) to determine their location. This information will be used to allow the Member to set a suitable search radius to look for other members.

What information does Safer Date process when using the Safer Date platform?

Part of our Service is providing you with potential partners (“matches”). These matches are presented to you in your profile and via notifications (e.g. emails), with information including: first name, age, place of residence or postal code, a photo, compatibility score and a link to their profile. Please note that we may present you at any time as a match to other members. As such, your first name, age, place of residence or postal code, photo, compatibility score and a link to your profile will be provided to these members.In your profile, under “Notification options”, you may choose to receive notifications from us (e.g., emails or push messages) to alert you when there has been activity in your account (e.g. you have received a new message or we have new matches for you). Please note that if you do not choose this notification option, your matches who have requested notifications may still receive notifications related to you (e.g., when you send them a new message or we send your profile as a suggested new match). As such, and as mentioned above, your first name, place of residence or postal code, photo, age, compatibility score and a link to your profile may appear in such notifications.You may also request to be informed about: (1) which matches visited your profile (“visitors of my profile”) and/or (2) if your matches are currently online (green circle if they are online, or grey circle if they are not). Please note that if you do so, the same information regarding your activity will be available to your matches who have also selected these notification options. As such, and subject to a match’s notification settings, (1) a match whose profile you visited may be informed of your visit, and (2) your matches may be notified when you are online or offline.In addition, you are able to see the last time a match was online (“last time online”), and your matches are also able to see when you last logged in. This feature is set up automatically and, for technical reasons cannot be deactivated.

Processing Purposes

Safer Date processes the personal data of its users for the following purposes:
  • To provide our services as described in our General Terms and Conditions. (The legal basis for our use of this information is contractual necessity, i.e. to provide you with the services you have asked for from Safer Date. The legal basis four our use of sensitive data is your consent)
  • For the prevention of and defence against abuse. Safer Date automatically collects, processes and uses personal data and geo data we collected during your registration and the completion of your Safer Date profile, to check for any evidence of the misuse of our Service. This information is stored in a database and compared against empirical values and information. If our automated processing activities suggest that our Service has been misused, a Safer Date employee will review the relevant rating and underlying clues, as well as the information in your profile (including any wording and photos you have provided) to confirm whether this is the case. In addition, customer care representatives perform profile check to check members’ profiles that have been reported by other members through the website or as having breached our General Terms and Conditions. Furthermore, as mentioned above, if you have provided your mobile phone number, Safer Date may use this information to carry out an identity check (SMS verification) (i.e. to check that you are who you say you are). (The legal basis for these activities is the legitimate interests of Safer Date and our Safer Date members, to ensure that the Safer Date Service is not used in a way that is in breach of our General Terms and Conditions and/or the law.) In doing so, we also comply with our legal obligation regarding data security to guarantee system security and to detection and trace unauthorised access attempts or accesses).
  • For automated price determination reasons. (The legal basis for these activities is contractual necessity.)
  • To ensure that you comply with your obligations under your subscription and our General Terms and Conditions, including your payment obligation (which concerns only Premium members). If you do not pay outstanding invoices / instalments despite repeated reminders, we will transfer the data that are required for the execution of a debt collection procedure to a debt collection service provider for the purpose of fiduciary debt collection. (The legal basis for these activities is contractual necessity, but it is also within the legitimate interests of Safer Date to ensure that (as applicable) you provide the agreed payment for our Service in accordance with your subscription.)
  • For the protection and defence of our rights and the fulfilment of legal obligations. (The legal basis for these activities is the fulfilment of our legal obligations and our legitimate interest in asserting and defending our rights.)
  • For the purposes of sending advertising relating to our own products through promotional emails and personalised guidance. (The legal basis is our legitimate interests in relation to sending direct marketing about our own products. The legal basis in some instances is also your consent.)

Transfer of data to third parties; service provider

We may share your personal information within our group of companies and other entities within our group may also store and/or process your information in accordance with this privacy policy.In addition, we may disclose your personal data to third parties where we are obliged to do so by law, a regulator or a court order.

Transfers to service providers

Safer Date may use service providers when collecting or processing your personal data. Safer Date will ensure that any service provider only receives that portion of your personal data that the service provider needs for their specific activity.In particular, Safer Date will transfer your personal data to IYE Global Ltd to carry out background checks and to Credas to carry out identity checks for the purpose of providing the services in accordance with our General Terms and Conditions (as set out in “Processing Purposes” above).In addition to those already expressly mentioned in this privacy policy (e.g. under Cookies & Tracking), Safer Date uses, amongst others, service providers to send promotional emails and push messages to members. In addition, Safer Date uses service providers to provide our servers. If you subscribed to your Membership over the website, we also use external payment services and service providers to help us with the settlement of payments and debt collection. Depending on the particular payment method you choose when purchasing your Membership over our website, Safer Date will send your payment information to the bank or to the particular payment service provider that we have appointed. Please be aware that such payment service providers will be responsible for their use of your personal data for their own purposes (i.e. to process your payment). As such, the privacy policy of the respective payment service provider will also apply.Generally, the service providers that we appoint are engaged as our processor and may only use the personal data of our members in accordance with our instructions.

How do we protect your personal data?

Safer Date uses a variety of security measures to protect the security, integrity and availability of our customers’ and users’ personal data. In particular, these measures include the following:
  • Core software updates to keep the systems up to date
  • WordPress login protection to protect against brute force attacks where attackers can repeatedly guess usernames & passwords
  • SQL Injection protection
  • Malware Detection: We use security tools such as the Wordfence plugin, which regularly and automatically performs a scan of the website to detect potential security vulnerabilities.
  • Website traffic to each is fully encrypted with 256-bit SSL encryption

Cloudflare

In order to secure this website and optimize loading times (e.g. bot detection, account takeover, SSL certificate) we use a “Content Delivery Network” (CDN). This CDN is a service of Cloudflare, Inc, 101 Townsend St, San Francisco, CA 94107, USA. Therefore, registration and login requests are routed through the Cloudflare server and consolidated into statistics that cannot be deactivated.The Cloudflare web application firewall (WAF) acts as a shield between the website and the internet, protecting a site from exposure by having traffic pass through the WAF before reaching the server, and filtering out threats. The Cloudflare WAF is continuously updated to recognise and protect against the newest threats. Cloudflare’s WAF protects sites with 148 rules, providing an additional level of protection against vulnerabilities including Distributed Denial of Service (DDoS) attacks, SQL Injection, Cross-site scripting (XSS) and malicious file upload.

Duration of storage; retention obligations

We store your data for as long as is necessary for the provision of our Service and any associated services or where we have a legitimate interest which permits the further storage of that information. In all other cases, we will erase your personal information once it is no longer necessary, except for any information we need to retain in order to comply with any contractual or statutory (e.g. tax or commercial) retention periods (e.g. invoices).You can choose to remove the data in your profile at any time. You can also erase your profile data yourself by logging in to the Safer Date website and starting the deletion process.We will erase your data following your request as long as there is no legal storage obligation that applies to that information. If your data is subject to a mandatory storage period, we will ensure that this information is isolated and stored until the expiry of the retention period. Once your Membership is over, if you do not ask us to erase your data before your subscription comes to an end, your Membership will be put on hold.Log files are stored by Safer Date for 30 days and then deleted. Log files whose further retention is required for evidentiary purposes are exempt from deletion until the incident is finally resolved and may be forwarded to investigative authorities as appropriate in individual cases.Please note that if the deletion of your data is prevented due to a mandatory retention period, your data will be blocked and stored for no other purposes, until we can delete it.Safer Date will also store any personal data which is required to demonstrate that Safer Date has lawfully complied with a valid data subject rights request within the required period.

Rights of the data subject at a glance

You have the right to access, and -under certain conditions- to rectify, erase, restrict or object to the processing of your personal data, as well as the right to data portability.You can also object at any time to the processing of your personal data for advertising purposes (“object advertising “). Please take into account that for organisational reasons there may be a time lapse between when you submit your request and when we are able to remove your data from an ongoing campaign. Please also note that your objection will not affect the lawfulness of any processing that occurred prior to the date on which you objected to this activity.By using our Service, you will have provided us with information about your sexual orientation (such as your gender and your sexual preferences). You can withdraw your consent to our use of this information at any time. However, please note that any withdrawal of your consent will not affect the lawfulness of our processing of such data prior to the date on which you withdrew your consent. In addition, once you have withdrawn your consent, we will no longer be able to provide you with matches or our Service.By using our Service, you may have provided us with sensitive information about your religion, ethnicity and/or political view. You can withdraw your consent to our use of this information at any time. To do so, you should change your answers in your profile. However, please note that any withdrawal of your consent will not affect the lawfulness of our processing of such data prior to the date on which you withdrew your consent.If you would like to exercise any of your rights, please use the information under Contact. Please also ensure that when you do so, we will be able to clearly identify you.Alternatively, you may use the setting options in your Safer Date profile to rectify certain information that you provided during your registration or to object to advertising. You can also delete your data from a Safer Date Membership yourself in your profile. Lastly, please note that if we cannot delete your data due to a mandatory retention period, we will block (restrict) your data until it can be deleted.

Right to lodge a complaint with a supervisory authority

You have the right to file a complaint with a data protection authority. You can contact your local data protection authority or our appointed data protection authority. This is:The Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, Telephone Number: + 44 (0) 303 123 1113, Email: [email protected].

Social Media

In general, if social media plugins are used, the providers of such plugins will store cookies. However, the social media buttons that we use on our website contains only text links to the respective social media pages, they are not properly a social media plugin. Therefore, Safer Date will not transfer any data to the respective social media providers. The operator of the social media page is responsible for compliance with data protection law. You can get more information about their data protection practices in their respective privacy policies.

Cookies & tracking technologies when using the Safer Date website

Cookies & Tracking

Our website uses cookies and other web tracking mechanisms.A cookie is a small text file that is sent to your device when you access a website and is stored in your browser. If you then access the same webpage again, your browser will check its cookies and will recognize you as a returning user. Some cookies are automatically erased after the end of the browser session (these are “session cookies”), whereas other cookies are stored for a predetermined amount of time or permanently in your browser, before they erase themselves (these are “temporary” or “permanent” cookies).While a cookie may distinguish your device, it will not name you. Almost every website uses cookie technology.

What cookies and other web tracking mechanisms does Safer Date use?

Safer Date classifies cookies into different categories depending on their function and purpose.

“Essential” cookies

We use certain cookies to make sure that our website and our Service is easy, secure and safe to use. Without these cookies, services that you have asked for (such as a secure website and Service), would not be possible. This category of cookies includes:
  • Cookies that identify or authenticate our users to ensure that our Service is secure;
  • Cookies that ensure the security of Safer Date’s information system;
  • Cookies that control abuse;
  • Cookies that temporarily store certain user entries;
  • Cookies that store certain user preferences (such as your language choices).
A consent is not required to use “necessary” cookies. They cannot be deactivated.

“Functional” cookies

We use “functional” cookies to record usage data about our users (e.g. which users have visited which of our subpages, etc.) and to evaluate this information statistically. We use this statistical information about your use of our website to improve its performance, to tailor our platform to the users’ needs, to make it more user-friendly, to understand our market share and to conduct other market research.

“Marketing” Cookies

We also use cookies for advertising purposes (“marketing” cookies) to collect and evaluate usage behaviour for the purposes of sending our members interest-based advertising about our products.We also allow third parties to collect our users’ data through “marketing” cookies or pixels placed on our website. These cookies allow us and other third parties to provide you with interest-based advertising that is based on an analysis of your usage behaviour (e.g., which banner ads you have clicked on, which subpages you have visited, etc.) on the internet and our website.You can manage (able/disable and erase) cookies on our website by using the functions mentioned above, and also via your browser settings. Most browsers allow you to manage your cookies by either accepting or rejecting all cookies or by agreeing to only certain types of cookies. To learn how to manage and erase cookies, please refer to the help function of your browser.Please note, however, that if you choose to disable or remove cookies and other web tracking mechanisms, doing so may prevent certain features on our website from working properly and therefore affect your experience on our website. In addition, you may not be able to use all the features of our Service if you disable or remove cookies and other web tracking mechanisms.

What specific tracking technologies does Safer Date use?

Google Analytics

We use Google Analytics tools for analytics purposes. Google Analytics is provided by Google Ireland Ltd, with registered address: Gordon House, Barrow Street, Dublin 4, Ireland (“Google”). We have chosen to use Google Analytics with an additional feature provided by Google that ensures the anonymization of all user IP addresses. Specifically, Google will shorten the IP address of any user within the EU (and, in exceptional cases, within the US) and will only store the shortened IP addresses in the US. Google provides us with analytics services on our behalf; and evaluates our user’s use of our app in order to compile reports on app activity and to provide us with other services related to the app activity and our users’ use of internet, such as Google Analytics demographics and interest reports.We do not use the Google Analytics Advertising Features.To the extent that Google uses this personal data for our and/or its own purposes, this is described here (https://policies.google.com/privacy?hl=en).You may object at any time to the collection, transfer and/or use of your data for analysis purposes by this tracking provider by unchecking the box at the bottom of this page under the section “Allow tracking”. Once this checkbox is unchecked, your data will not be transmitted or used by this tracking provider.

Google Ads

We use an online advertising program, “Google Ads” which is an analytics service provided by Google Ireland Ltd (with registered address: Gordon House, Barrow Street, Dublin 4, Ireland) („Google“). Within Google Ads, we use the following features:
  • Google Ads Conversion-Tracking. With this tool, we can determine whether you have clicked on an Safer Date ad placed by Google. We use this information to generate conversion statistics to see how effective our advertising is. This information allows us to see if you have purchased our product or downloaded our app.
  • Google Ads Remarketing. This feature enables us to target Safer Date app visitors by displaying personalised, interest-based ads to these visitors when they visit other web pages or apps in Google Display Network, or use Google’s or a partner’s search engine.
  • Google Ads Similar Audience. Through this feature, we can extend our advertisements´ audience appeal by sending targeted ads to other individuals who have similar interests to our members. Our aim is to reach individuals who are not directly looking for our products or services, but who may find them interesting because of their similar interests.
For more information about Google Ads and Google’s privacy policy, please visit here (https://policies.google.com/technologies/ads?hl=en).You may object at any time to the collection, transfer and/or use of your data for analysis purposes by this tracking provider by unchecking the box at the bottom of this page under the section “Allow tracking”. Once this checkbox is unchecked, your data will not be transmitted or used by this tracking provider.

Facebook

We want to present “interest based advertising” on Facebook, while limiting the frequency that certain advertisements are displayed to individuals. To achieve this, we use the “Custom Audiences” tool operated by Facebook Ireland Ltd, whose registered office is: Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”).Facebook uses a hashed, user-specific Facebook ID to assign Facebook users to a “Custom Audience” according to specific rules determined by us. Our ads will be then displayed on Facebook towards this “Custom Audience”. However, ads are only displayed to a “Custom Audience” which contains more than 20 different users – therefore no inference can be drawn about the individual user’s characteristics based solely on the ad placement. A Facebook user will only be assigned to a certain “Custom audience” for a maximum of 180 days. After this time, you will only be re-added to a “Custom audience” when you revisit our app (at which point the same rules will apply).You can find further information about how Facebook complies with its data protection obligations here (https://www.facebook.com/privacy/explanation).You may object at any time to the collection, transfer and/or use of your data for analysis purposes by this tracking provider by unchecking the box at the bottom of this page under the section “Allow tracking”. Once this checkbox is unchecked, your data will not be transmitted or used by this tracking provider.

Disclaimer

Safer Date Ltd do not claim that the software, websites or servers we host or maintain are unbreakable or impenetrable, nor are we security consultants. While we strive to ensure our website and maintenance methods follow best practice and industry standards as described above to mitigate against possible threats, attacks, and data breaches, and minimise any risks, no guarantee is offered. Safer Date Ltd will not be liable to any party for damages, including lost profits, lost savings or other incidental, consequential or special damages in any event.EFFECTIVE DATE: 8th July 2020

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