Last Updated: November 11th, 2016
The Service provides an online marketplace and platform (including the mobile applications and related technology, the “Platform”) for end user customers (“Users”) to browse, be connected with and hire the services of matchmakers, dating services consultants, therapists and related service providers (collectively, “Service Providers”) for the purpose of meeting romantic matches and receiving content, advice and counseling relating to dating, romance and related topics.
The Platform will offer messaging and video chat functionality to allow Users to (i) directly interact with Service Providers and potentially, hire them (each hire an “Engagement”) and (ii) in the case of Users who have hired Matchmakers, to connect with other persons (each a “Match”) for the purpose of dating (such introduction, a “Onadate.”)
2. Collection of Information.
The Types of Information We Collect
We may collect personally identifiable information (“Personal Information”) and non-personally identifiable information (“Non-Personal Information”) from you.
This policy is primarily concerned with Personal Information. Personal Information is information that can be used to identify or locate a particular person or entity. This includes, but is not limited to: name, address, telephone number, email, date of birth and, if applicable, billing information.
Non-Personal Information cannot, by itself, be used to identify a particular person or entity and includes any aggregate information and/or usage information relating to the Service or Site that we have gathered, as long as Personal Information has been removed from it. This policy does not restrict our use of Non-Personal Information and you agree that we may use or transfer any Non-Personal Information that we collect from you or based on your usage, at our discretion.
However, if we combine your Non-Personal Information with Personal Information that we collect about you, we will treat the combined information as your Personal Information.
Information You Provide To Us
- Service Registration. At registration, we require you to provide, your email address, date of birth and gender categorization. If you have registered with us via a social media platform such as LinkedIn or Facebook, you must consent to have the applicable platform share that information with us. If we partner with other social networks or sites for integrated registration, similar sharing may occur.
- User Profile. Your registration information will be used to create your service user profile (“User Profile”). After you register, we will request that you review your User Profile, to confirm any pre-populated information shared with us and to edit and supplement it, with your personal information and dating preferences that we think are relevant to your Service usage experience. We will also encourage you to upload photo and potentially video content of yourself, for Service usage purposes. Over time, we may change or supplement the information that we ask or require to provide.
- Commerce. When you book any Engagements (and/or make any other Service purchases from us, if we add additional commerce functionality), we may request that you provide additional billing-related information (“Billing Information”). We may also provide purchase links directly to properties that are operated by third parties which will be governed by their own privacy policies.
- Sharing and Community Features. We may offer features within the Service or Site that allow you to further communicate with us or with Service Providers and/or other Users, including by uploading files.
- Promotions, Surveys, Contests. We may conduct promotions, offer voluntary surveys and host contests, as part of which we may request additional information from you.
We are not responsible for verifying the accuracy of any information that you provide or post.
Information We Automatically Collect
As you use our Service or Site (or access emails or other messages we send to you) we may use technologies that automatically collect information about your usage, including but not limited to: data about your mobile device (such as your device-type, software and language preference) or desktop interface and IP address, your channel viewing information and interests, and your movement through our properties and on to external links, as well as your location. Collectively, this information is referred to as “Analytics Information.” We may create a unique device or user ID for you so we can recognize you.
Some tools that we may use to collect Analytics Information include:
· Cookies. Cookies are small pieces of data that are stored on your computer or mobile device.
· Tags/Pixels/Beacons. These terms are generally used to describe small blocks of code on webpages that do things like allow another server to measure viewing of a webpage.
· Location: We can normally automatically detect your location data via your phone. However, your operating system may require you to grant us permission to access your GPS. If you do not permit this access, you may not be able to use the Service.
· Other. We may use technology available on your device, technology similar to cookies and pixels and technology that is later developed, all for similar purposes.
Information We May Automatically Collect via Third Parties.
We sometimes use third party services to help us track activity and user flows within our properties, using similar tools to the ones we described (see Information We Automatically Collect). Such tracking would track an individual user’s movements but the data would not be tracked in a personally identifiable way and would be treated as Analytics Information (below).
We may work with advertisers and others whose products are promoted on our properties that may also use similar technologies. In those cases, we advise you to check their privacy policies. To learn more about behavioral advertising or to opt-out of some types of behavioral advertising for participating ad networks, you can visit the Network Advertising Initiative (http://www.networkadvertising.org/choices/) or the Digital Advertising Alliance (http://www.aboutads.info/choices/).
Information We Receive From Third Parties.
There are instances where we may receive information from third parties.
- As highlighted earlier, if you register via Facebook, LinkedIn or another social network or other future promotional partner, we will receive registration information from them.
- You may click through certain links or promotions via the Service or Site that will enable you to purchase products or use services provided by promotional partners or other sites or commerce providers. Some of those entities may share with us certain information that you provide to them. You agree to allow us to receive and use any information that you may provide to such entities, under the same terms as if you provided it to us directly.
3. Use of Information. We use the information we collect in the following ways:
Registration, User Profile and Service Usage Information
- to maintain our customer lists
- for Service improvement,
- to provide updates and announcements and to address issues like malicious use of the Service.
- for limited marketing purposes, namely, to contact you regarding your interest in the Service, to send you information about us or our partners and to personalize advertising or promotions for you.
- For internal purposes, we may retain logs of all comments that you post via any facilities that we provide, though we will not be obligated to do so.
All information you send or post to areas of our properties (if any) that are public or semi-public (such as message boards) becomes public information that will not be treated as Personal Information. So please be careful about posting any Personal Information to such areas.
Unless you have blocked the functionality on your mobile device, our Platform collects GPS location information from your mobile device, for the purpose of tailoring your Service experience based on your current location, including by sharing the same with Service Providers so that they can do the same, and for our internal analytics and other business purposes.
If we offer premium products, we will use your Billing Information solely to check the financial qualifications of prospective customers and to collect payment for Engagements and any addition premium services or products that we may offer from time to time.
Criminal Background Check
Per our Service user terms and conditions, in order to utilize certain parts of the Service, you agree that we may conduct a criminal background check on you. The results of those checks will be retained by us for use as part of the provision of Services; specifically to confirm or deny your eligibility for some all or of the Service. Certain Service Providers may also have access to background check results, also to be used by them for the purpose of determining eligibility for certain aspects of the Services.
Quizzes and Surveys
Unless we state otherwise at the time, your responses to any quizzes and surveys posted through the Service will become part of User Profile. We may use that to improve the Service, for analytics and for our business purposes and Service Providers will be able to view and access it as well, as part of their ability to view your User Profile as part of their involvement in the Platform for the potential provision of Services.
Contests and Sweepstakes
Any Personal Information will be used only by us unless we specify otherwise when we ask you to participate. However, we may share aggregate survey or contest result information with others. We will use the information you provide to conduct the contests or sweepstakes and for any other purposes to which you consent. If we offer contests or sweepstakes with our partners, we may notify you that we will share the information we obtain from you with them and will give you the opportunity to choose whether or not to participate.
We may use your Analytics Information in conjunction with an analytics service such as Google Analytics to monitor and analyze use of the Service or Site, for technical administration, to improve functionality and security to personalize the Service and improve your experience, and for internal analysis or for shared analysis with our partners.
Information We Receive From Third Parties
5. Exceptions. The following are the ONLY exceptions, with respect to whom we may share your information with:
- any of our affiliated companies;
- companies acting as our agents in hosting, building, developing or otherwise supporting the Service or Site, including but not limited to any component thereof (e.g. customer/support services, email providers, billing processing) to you, all of which agree to use it only for that purpose and to keep the information secure and confidential;
- Service Providers, in the context of their participation in the Service and any Engagements that they may provide, all of which agree to use it only for that purpose and to keep it secure and confidential.
- any entity with whom we are required to do so by law, for example, in response to a court order or a subpoena or other legal obligation, in response to a law enforcement agency's request, or in special cases when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property.
You should also be aware that courts of equity, such as U.S. Bankruptcy Courts, may have the authority under certain circumstances to permit your information to be shared or transferred to third parties without your permission.
6. Security. The security of your Personal Information is very important to us. We use commercially reasonable efforts to store and maintain your Personal Information in a secure environment. We take technical, contractual, administrative, and physical security steps designed to protect Personal Information that you provide to us. We have implemented procedures designed to limit the dissemination of your Personal Information to only such designated staff as are reasonably necessary to carry out the stated purposes we have communicated to you.
You are also responsible for helping to protect the security of your Personal Information. For instance, protect your devices and never give out your password.
8. Third Party Widgets and Links. We may display links to other sites and we may provide tools and widgets from other sites and services. We are not responsible for those other sites and services, their privacy policies or how they treat information about their users. We advise you to check their privacy policies to find out how they are treating your personal information.
11. Access. You have the right to access the Personal Information we hold about you in order to verify the Personal Information we have collected in respect to you and to have a general account of our uses of that information. Upon receipt of your written request, we will provide you with a copy of your Personal Information although in certain limited circumstances, we may not be able to make all relevant information available to you such as where that information also pertains to another user. In such circumstances we will provide reasons for the denial to you upon request. We will endeavor to deal with all requests for access and modifications in a timely manner.
12. Your California Privacy Rights. If you are a California resident and you decide that you do not want us to share your personal information with third party companies for their marketing and promotional purposes, please send an email to email@example.com. In this e-mail, state that you do not want Tunity to share your personal information with third parties for their marketing purposes. Your request will be processed within thirty (30) days of the date of which we receive it.
13. No Access to Children Under 13. If you are under the age of 13 you may not use our apps or websites in any way. We don't knowingly collect data from anyone under the age of 13 and we do not direct any of our products or services at this age group. If we become aware that we have inadvertently captured any personal data about a person who is under 13 years of age, then we will take the appropriate steps to shut down the account of that person.
14. Contact Us. You can help by keeping us informed of any changes such as a change of email address or telephone number. If you would like to access your information, if you have any questions, comments or suggestions of if you find any errors in our information about you, please contact us by emailing firstname.lastname@example.org or by writing to us at:
Attn: Privacy Officer
118 West 22nd St., 3rd Floor,
NY NY 10011
If you have a complaint concerning our compliance with applicable privacy laws, we will investigate your complaint and if it is justified, we will take appropriate measures.