PRIVACY POLICY

 

Welcome to SeniorMatchMe's Privacy Policy. Thank you for taking the time to read it.

We appreciate that you trust us with your information and we intend to always keep that trust. This starts with making sure you understand the information we collect, why we collect it, how it is used and your choices regarding your information. This Policy describes our privacy practices in plain language, keeping legal and technical jargon to a minimum.

What information does SeniorMatchMe process?

SeniorMatchMe is a meeting place for adults aged 45 or over, and we provide that service by operating a social network site offering users the opportunity to connect to our global community of users. By joining SeniorMatchMe, you enter a legal agreement with us and we process your data in order to provide your service under the terms of that agreement. You can only become a member of SeniorMatchMe or use its features if you’re aged 45 years or over.

To join the SeniorMatchMe network you will have to complete our online registration form, where we may ask you to provide us with information about you such as your name, your gender, your date of birth, your occupation, your location details and what you’re looking for on SeniorMatchMe. We will also ask you to provide 1 photo and to write something about yourself. You have the opportunity to provide other details about yourself, but these are optional. Because you control your user profile, these details are available to you at any time by accessing your “Profile” page, which gives you the chance to correct or update your information (other than your gender) at any time by just logging in to SeniorMatchMe. You can contact SeniorMatchMe’s Customer Support Team at Feedback Page to change the gender on your profile.

Please be careful about posting sensitive details about yourself on your Profile such as your religious denomination and health details. While you may voluntarily provide this information to us when you create your Profile, including your sexual preferences and ethnic background, there is no requirement to do so. Please remember that any photographs that you post on SeniorMatchMe may reveal these kinds of sensitive personal data. Where you do upload and choose to tell us sensitive data about yourself, you are explicitly consenting to our processing your information and making this public to other users.

For safety and security and to ensure you have the best possible user experience, we require users to verify their accounts and might ask for your Email address. We want to make sure you are not a robot! And we also want to avoid fake SeniorMatchMe accounts being created which can be used for malicious activities and cyber crime – they threaten the SeniorMatchMe network and spoil things for everyone.

If you decide to purchase any of our premium services, we will process your payment information and retain this securely for the prevention of fraud and for audit/tax purposes.

Finally, we want to keep in touch with you to make sure you know about any great promotions and offers we may have available. If you’ve told us it’s OK, we will use your email address to send you information on these. You can withdraw this consent at any time via Settings in the app.

What does SeniorMatchMe collect about me if I use the mobile App?

SeniorMatchMe offers you the opportunity to stay in touch with the friends and contacts you’ve made no matter where you are. You can do this by using your mobile phone or by downloading an application to your desktop that allows you to share your location with other users.

When you use your mobile or the desktop application, we will collect information about WiFi access points as well as other location information about your longitude and latitude. That information helps us identify your physical location so that we can display other members who are within a certain distance to you.

If you have enabled location services, but wish to turn it off, you can do so by the following methods:

  1.                            iPhone app — settings, privacy, location services, SeniorMatchMe
  2.                            Android — profile, privacy, off

What is the legal basis that allows SeniorMatchMe to use my data?

We are only permitted to use your data when we have a lawful basis to do so. The table below provides an overview of the legal bases that SeniorMatchMe relies on to use your data. Where the legal basis is consent, you can withdraw consent at any time. Where the legal basis is legitimate interests, you have a right to object to our use of your data. We explain in the relevant sections in this privacy notice how you can withdraw consent or opt-out of certain data uses (where applicable).

Purpose for which data is used

Data

Legal basis

To provide you with social networking service

Name, email address, date of birth, location

Contractual necessity

To facilitate networking opportunities on the site

Optional information that you choose to provide in your profile, which may include information about your sexual preferences, religion, ethnic background, photos etc.

Consent

To verify your identity and prevent fraud and to ensure the safety and security of users

Email address

Legitimate interests – it is in our legitimate interests to ensure that accounts are not set up fraudulently and to safeguard users of the site

To take payment for premium services

Payment card details

Contractual necessity and legitimate interests – we need card details to receive the payment due under our contract with you (where applicable) and we have a legitimate interest in using this data for fraud prevention purposes

To send you marketing information about our offers and services

Email address

Legitimate interests – it is in our legitimate interests to promote our products and services

To show “nearby” location information to you and other users of the site

Wifi access points and location data when you use the mobile app

Consent

 

How long will SeniorMatchMe keep my data?

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, audit, reporting and/or corporate compliance requirements.

 To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

What information does SeniorMatchMe collect about me if I’m under 18?

SeniorMatchMe does not knowingly collect any information about or market to children, minors or anyone under the age of majority, and it is only available to people aged 45 years or more. If we become aware that a child, minor or anyone under the age of 45 has registered with us and provided us with personal data, we will take steps to terminate that person’s registration and delete their Profile information from SeniorMatchMe. If we do delete a Profile because you violated our age restriction rules, we may retain your email and IP address to ensure that you do not try to get around our rules by creating a new Profile.

Who does SeniorMatchMe share information with?

We may share aggregated information that includes your personal data (but which doesn’t identify you directly), together with other information including log data with third parties for industry analysis and demographic profiling.

We share your data with the following categories of third-parties:

  1. Information technology companies (hardware and software) which provide services to support our products
  2. Fraud prevention and anti-spam providers to protect the service from criminal activity
  3. Moderators to monitor activity on the site/apps and approve content
  4. Law enforcement agencies, where we are required to by law or to protect the vital interests of a person
  5. Payment processing and telecommunications companies to facilitate payments for our premium services

We ensure these parties must adhere to strict data protection and confidentiality provisions that are consistent with this Policy. Measures are taken to ensure that the data shared is non-attributable to the greatest extent possible.

In the event that SeniorMatchMe or any of its affiliates undergoes a business transition or change of ownership, such as a merger, acquisition by another company, re-organisation, or sale of all or a portion of its assets, or in the event of insolvency or administration, we may be required to disclose your personal data.

Your rights

Under certain circumstances, you have the following rights under Data Protection laws. To protect your privacy and security, we may take reasonable steps to verify your identity before any exercise of the following rights according to applicable law.

(a)  Request access to your Personal Data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

(b)  Request correction of your Personal Data. Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

(c)  Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

(d)  Object to processing of your Personal Data. Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third-party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

(e)  Request restriction of processing your Personal Data. Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (i) if you want us to establish the data’s accuracy; (ii) where our use of the data is unlawful but you do not want us to erase it; (iii) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

 (f)  Request transfer of your Personal Data. Request the transfer of your Personal Data to you or to a third-party. We will provide to you, or a third-party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

 (g)  Right to withdraw consent. Withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain features of our Services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us at the e-mail address in the Contact us section below.

 

Additional information about your rights

(a)  No fee usually required. You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

(b)  What we may need from you. We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

(c)  Time limit to respond. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

How does SeniorMatchMe protect my personal data?

SeniorMatchMe has implemented appropriate security measures to protect and prevent the loss, misuse, and alteration of the information under our control, including your personal data. Our technical experts at SeniorMatchMe work hard to ensure your secure use of our site.

While we take reasonable precautions against possible security breaches of our website, member database and records, no website or internet transmission is completely secure and we cannot guarantee that unauthorised access, hacking, data loss, or other breaches will never occur. We urge you to take steps to keep your personal data safe (including your password) and to log out of your account after use. If you lose your password or give it out, or another service provider that you use suffers a data breach and you have used the same credentials with that service provider as you have with SeniorMatchMe, your personal data may be compromised. If that happens, please report it to Support via Feedback Page.

E.U. residents and E.U. U.S. privacy shield framework

We comply with the E.U. U.S. Privacy Shield Framework and are committed to ensuring that we adhere to the following principals: Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. We are subject to the enforcement of the Federal Trade Commission and shall remain liability for harm caused in connection with our onward transfer of your data. To learn more about the E.U. U.S. Privacy Shield Framework, please visit the U.S. Department of Commerce website located at the following link: https://www.privacyshield.gov/welcome. We are committed to working with you to address questions, concerns or complaints you may have about this Privacy Policy or your Personal Data. For the avoidance of doubt, in the event there is a conflict between the Privacy Policy and the E.U. U.S. Privacy Shield Framework the terms of the E.U. U.S. Privacy Shield Framework shall govern. Please contact us at the e-mail address in the Contact us section below. if you have any questions or have an issue that youd like to resolve.

Dispute resolution (E.U. residents)

(a)  General. If you reside in E.U. and have any questions or concerns regarding the use or disclosure of Personal Data, you should first contact us for assistance. We will promptly investigate and attempt to resolve all complaints regarding our use of Personal Data. In the event we are unable to mutually resolve a complaint; we will work with you and agree to refer your complaint to an independent dispute resolution mechanism. In the event we are unable to resolve your claim, you should contact our U.S. based third-party dispute resolution provider free of charge at JAMS in SF. In certain instances conditions, described on the Privacy Shield’s website https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

(b)  Questions and concerns. Any questions or concerns regarding the use or disclosure of Personal Data should first be directed us. We will promptly investigate and attempt to resolve all complaints regarding our use of Personal Data. In the event we are unable to mutually resolve a complaint; we will work with you and agree to refer your complaint to an independent dispute resolution mechanism. You may also work with the Data Protection Authority in your country http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm to assist with this process as well.

Notice to certain international members

If you are a citizen of Canada, Brazil or Mexico and have questions about the accuracy of information that we have collected about you, you can have access to that information in order to verify and update it, unless we are permitted or required under applicable laws to refuse your access to such information. You may write or email us the e-mail address in the "Contact us" section below

California privacy rights

Section 1798.83 of the California Civil Code entitles residents of California to request a notice detailing the categories of Personal Data that we have shared with third-parties for direct marketing purposes during the preceding calendar year, as well as the identity of those third-parties. To request a copy of your Personal Data maintained by us, please contact us as at the e-mail address in the ”Contact us” section below.

Contact us

If there are any questions regarding this privacy policy, you may contact us via e-mail at seniormatchgroup@gmail.com.