Certain words will have the following meanings:
- “We” and “we” and “our” means DateSmart Ltd
- “website” refers to this website https://getdatesmart.com/
- “Member(s)” is a person or persons who have registered an account on the website
- “Registered user” is a person or persons who have registered an account on the website
- “Profile” refers to a personal profile, which is publicly visible to any registered member of the website.
- “Personal information” is data that we collect on subscription/registration
- “The Service” refers to the website, events and any other services that we operate.
We respect your privacy and are determined to protect your personal data. The purpose of this privacy notice is to inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from). We’ll also tell you about your privacy rights and how the data protection law protects you.
1. WHO WE ARE AND IMPORTANT INFORMATION
What is the purpose of this privacy notice?
This privacy notice aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, purchase a product or service, use the dating site, take part in a survey or take part in a competition.
This website is not intended for anyone under the age of 18 years old.
You must read this privacy notice together with any other privacy notice.
DateSmart Ltd is the controller and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy notice). Our contact details are: DateSmart Ltd, 111 New Union Street, Coventry, CV1 2NT, email: email@example.com, 111 New Union Street, Coventry, CV1 2NT. For all data matters email our Data Representative at: firstname.lastname@example.org
DateSmart Ltd is the controller and responsible for this website.
This website may include links to third-party websites, plug-ins and applications. Using or clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.
When you use a third-party app or website or leave our website, we encourage you to read their privacy notice.
2. DATA PROTECTION AND THE PERSONAL DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. You can find out more about personal data from the Information Commissioners Office.
In addition, you have rights under the Data Protection Legislation. For an overview of your rights under these laws, please see the data protection section on the GOV.UK website.
We will collect personal information about you that is voluntarily given by you when you register on our website. This personal information include your name, email address, gender, age county, country, username and password.
When you create a profile, we will collect personal information about you that you put in your profile. This might include photos, your answers to questions and anything else you say about yourself on your profile.
If you send us a success story about yourself and a partner you have met through us or other testimonial comments, we will collect personal information about you that is included in any such submission.
Your profile photos will be displayed to anyone who views your profile page or sees you on a search results page. Your profile photos may be included in email communications to DateSmart members.
All photos uploaded needs to comply with our Terms and conditions.
Special category of data
When you complete your profile we ask you about your gender and whether you are looking to meet women or men. We only collect this information in order to provide you with the appropriate matches.
If you fail to provide personal data
Where we need to collect your personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. HOW WE COLLECT YOUR PERSONAL DATA
We use different methods to collect data from and about you including through:
- Directly. You may give us your identity, contact and financial data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- Apply for our products or services;
- create an account on our website;
- Subscribe to our service or publications;
- Request marketing to be sent to you.
4. HOW WE USE YOUR PERSONAL DATA
We use the personal data collected through our sites and app (where appropriate) for a number of purposes, most commonly:
- To provide the DateSmart services you sign up for, for example, dating site, sending service emails and related internal administrative purposes (and to make you aware of any changes to our services;
- Sending you marketing communications when we have your permission, or when permitted by law;
- To improve our marketing, we may use a similar technology to cookies to confirm whether you have opened a marketing email or clicked on a link in the email;
- From time to time we may request to use your personal data, as part of a promotional or advertising feature. We will only do this with your consent and you can change your mind at any time in your “Your account” preferences;
- Personalising our services for you (for example, so you can log in), remembering your settings, recognising you when you log into your account on different devices and tailoring your emails based on the information provided on your profile;
- For statistical purposes, such as analysing the performance of our site and apps and to understand how visitors use them;
- To respond to your queries and resolve complaints;
- For security and fraud prevention and to ensure that our site and apps are safe, secure and used in line with our terms and conditions. For example, we collect our members’ date of birth to ensure they are at least 18 years; and
- To comply with applicable laws and regulations.
We will use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Performance of Contract this means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
- Legitimate Interest this means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
- Comply with a legal or regulatory obligation this means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communication to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us by email: email@example.com
If you make contact with other DateSmart members or with us, we will collect and store this information.
You must enter the details on the welcome/landing page. If you do not opt out in the subscription process, we will use your details to send you promotional emails. You can opt out any time by unsubscribing in the email.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We have established the following personal data control mechanisms:
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company outside the DateSmart Ltd for marketing purposes.
We will never share your email address with another DateSmart member.
We do not share your personal data with other people or companies that are not directly linked to us except under the following circumstances:
- We use other service providers who provide elements of the DateSmart services on our behalf such as hosting the platform, dealing with online payments and other forms of payment processing credit card transactions and preventing fraud. When you access DateSmart through our apps and become a subscriber. We do not receive your full payment details from these third parties when they send us a confirmation that your payment has been made.
- We may reveal your personal data to any law enforcement agency, court, regulator, government authority or other organisation if we believe we need to do so to keep to a legal or regulatory obligation, or otherwise to protect our rights or the rights of anyone else.
You can ask us or third parties to stop sending you marketing messages at any time by unsubscribing via the email you receive.
We may use data about your behaviour and use of the site for the following reasons:
- to identify potential fraud by comparing genuine behaviour with known fraudulent behaviour;
- to help us plan targeted marketing and advertising campaigns, by looking at how particular groups of users are using the Service;
- to help us understand what behaviours are more likely to result in a successful experience (typically finding a partner), so that we can pass on advice to members, and we can improve the design of the Service to achieve a higher success rate by encouraging the kind of behaviour that is more likely to yield a success;
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please our Data Protection Officer or Data Representative at firstname.lastname@example.org
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. WHO WE SHARE YOUR PERSONAL DATA WITH
We may have to share your personal data with the parties set out below for the purposes set out in 4 above.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We may use various third-party providers to help provide the service to you. These third parties process your personal information on our behalf for the purposes of site administration, payments, development and back-up.
It is in our legitimate interest to share your personal information in such a way to ensure that we provide the very best service we can to you. Where we share your sensitive personal information (eg religious or political views, or health or sexuality information), we shall be relying on your consent to do so which you provide if you choose to submit such information.
In the event that we sell any of our business or assets, we will disclose your personal data to the prospective buyer of such business or assets. If our assets are acquired by a third party, any personal data held by it in relation to its customers (including you) will be one of the transferred assets.
6. INTERNATIONAL TRANSFERS
We currently do not share your personal data outside the UK.
7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting 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 unauthorised 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.
By law we have to keep basic information about our customers including contact, identity, financial and transaction data for 6 years after they cease being customers.
In some circumstances you can ask us to delete your data: see Your legal rights below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9.Changes to this notice and your duty to inform us of changes
Please keep us informed if your personal data changes during your relationship with us. It is important that the personal data we hold about you is accurate and current.
10. We reserve the right to not approve or refuse memberships. In these circumstances, any money paid will be refunded.
Queries, requests or concerns
To exercise all relevant rights, queries or complaints in relation to this policy or any other data protection matter between you and us, please in the first instance contact our [DATA PROTECTION OFFICER/OUR DATA REPRESENTATIVE] on email@example.com