Table of Contents
- Who we are
- Information we collect
- What do we use your information?
- Legal basis
- Personal data protection
- Disclosure of information to third-party
- Third-party links
- Where do we store the information
- Access, data portability, migration, and transfer back assistance
- Request for rectification, restriction or erasure of the personal data
- Data retention
- Terms of service
- Your consent
A. Who we are
SAOC SA, c/o Python & Peter, Avenue de la Gare 28, 1950 Sion, Switzerland
Phone: +1 (661) 451-1077
Company registration number: CHE-443.630.418.
- Our customers may submit inquiries regarding personal data protection, privacy and security matters to email@example.com.
B. Information we collect
- You may visit our site anonymously.
- If you choose to register on our website, these are the categories of data to and on behalf of you will be processed:
- Personal Data, such as name, date of birth, mobile number, email address, postal address, gender, account details and credentials and device information, such as IP.
- Financial information, such as billing information and Credit Card Details. Financial institutions or payment processors may provide us with updates regarding your payment information or payment methods related to your paid account or paid subscription and services.
- Additional information is provided when you complete your profile, such as, dating matches, age preferences, star sign, geographical location, photographs, personal interests, physical characteristics.
- Usage information: we may collect information about your activity on our services, e.g., date and time you logged in, clicks and advertising that you click on, and how you interact with other users.
- Sensitive personal data such as sexual orientation and religious beliefs.
- Some information is automatically collected when you visit or use our website, such as your IP address and browser user- agent. We may also install cookies and analytic tools. For more information on cookies, please read our cookies policy here.
- Some information is collected when you contact our customer support team.
- We will inform you about relevant changes concerning the Service, such as the implementation of additional functions, by posting it on this website and by e-mail.
C. What do we use your information?
- Any of the information we collect from you may be used for one or more of the following purposes:
- To provide our services and to help you connect with other users;
- To communicate with you and administrate your profile such as create and manage your account, provide you with costumer support and complete your transactions;
- To personalize your experience, to target your interests using targeted banners or promotions;
- To improve our website, to improve our marketing efforts, to statistically analyse site usage;
- To send periodic e-mails;
- To prevent, detect and fight fraud or other illegal or unauthorized activities;
- To comply with legal requirements.
- If at any time you would like to unsubscribe from receiving future e-mails, you can cancel your account after login by clicking on "Remove account".
D. Legal basis
- EU General Data Protection Regulation (GDPR). The processing of your data is either based on your consent or in case the processing is necessary for the performance of a contract to which you are a party, or in order to take steps at your request prior to entering into a contract.
- If the processing is based on your consent, you may at any time withdraw your consent by contacting us using the contact information in section A.1.
- In order to become a member, you must provide us with the required personal data. If you do not to provide us with all the required information, it will not be possible to deliver the Service.
- Children’s Online Privacy Protection Act Compliance. We will not intentionally collect any information from anyone under thirteen (13) years of age. Our website, products and services are all directed at people who are at least eighteen (18) years old or older.
E. Personal data protection
- We implement the following technical, physical and organizational measures to maintain the safety of your personal data against accidental or unlawful destruction or accidental loss, alteration, unauthorized use, unauthorized modification, disclosure or access and against all other unlawful forms of processing.
- We regularly monitor our systems for possible vulnerabilities and attacks and review your information, storage and processing practices to update our technical, physical and organizational measures.
- In order to ensure that our systems and your information are protected the following measures are involved: storage of confidential data such as credentials and credit cards details in encrypted form.
- Confidentiality. All personnel are subject to full confidentiality and any subcontractors and subprocessors are required to sign a confidentiality agreement if not full confidentiality is part of the main agreement between the parties.
- Transparency. We will at all times keep you informed about changes to the processes to protect data privacy and security, including practices and policies. You may at any time request information on where and how data is stored, secured and used. We will also provide the summaries of any independent audits of the Service.
- The ability to intervene. We enable your rights of access, rectification, erasure, blocking and objection by offering you the option to send instructions to the following e-mail address firstname.lastname@example.org.
- Monitoring. We uses security reports to monitor access patterns and to proactively identify and mitigate potential threats. Administrative operations, including system access, are logged to provide an audit trail if unauthorized or accidental changes are made.
System performance and availability is monitored from both internal and external monitoring services.
- Personal Data breach notification. In the event that your data is compromised, we will notify you and competent Supervisory Authority(ies) within seventy two (72) hours by e-mail with information about the extent of the breach, affected data, any impact on the Service, as well as our action plan for measures to secure the data and limit any possible detrimental effect on the data subjects.
"Personal data breach", means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed in connection with the provision of the Service.
F. Disclosure of information to third-party
- We do not sell, trade or otherwise transfer to outside parties any personally identifiable information.
- This does not include trusted third parties or subcontractors who assist us in operating our website, conducting our business, or servicing you. Such trusted parties may have access to personally identifiable information on a need-to-know basis and will be contractually obliged to keep your information confidential.
- We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect our or others’ rights, property, or safety.
- We will monitor subcontractors’ and sub-processor’s’ maintenance of these standards and audits to ensure that data protection requirements are fulfilled.
- Legally required disclosure. We will not disclose the customer’s data to law enforcement except when instructed by you or where it is required by law. When governments make a lawful demand for customer data from us, we strives to limit the disclosure. We will only release specific data mandated by the relevant legal demand.
- If compelled to disclose your data, we will promptly notify you and provide a copy of the demand unless legally prohibited from doing so.
- Disclosure of data to non-EEA countries. We may share personal data with third parties or processors based in non-EEA countries other than United Kingdom or Switzerland. In this case, we ensure that the recipient either has an adequate level of data protection according to the adequacy decision by the European Commission for the respective country, by self-certification of the recipient for the EU/ Swiss – US Privacy Shield or there is consent from our users.
- Residents of California. If you are California resident, you can request a notice disclosing the categories of personal information about your that we have shared with third parties for their direct marketing purposes during the preceding calendar year.
G. Third-party links
Occasionally, at our discretion, we may include or offer third party products or services on our website. These third party sites have separate independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked websites. Nonetheless, we seek to protect the integrity of our website and welcome any feedback about these websites.
H. Where do we store the information
Personal data location. All data are stored in databases and file repositories hosted in United Kingdom.
I. Access, data portability, migration, and transfer back assistance
- You may at any time obtain confirmation from us as to whether or not personal data concerning you are being processed.
- You may at any time order a complete data copy, which you may transmit to another controller of the data. Your data will be delivered by us within 30 working days, and free of charges.
J. Request for rectification, restriction or erasure of the personal data
- Rectification. You may at any time obtain without undue delay rectification of inaccurate personal data concerning you, cf. section E.6.
- Restriction of processing personal data. You may at any time request us to restrict the processing of personal data when one of the following applies:
- if you contest the accuracy of the personal data, for a period enabling us to verify the accuracy of the personal data;
- if the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead; or
- if we no longer needs the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims.
- Erasure. You may without undue delay request the erasure of personal data concerning you, and we shall erase the personal data without undue delay when one of the following applies:
- if the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
- if you withdraw your consent on which the processing is based, and where there is no other legal ground for the processing;
- if you object to the processing in case the processing is for direct marketing purposes;
- if the personal data have been unlawfully processed; or
- if the personal data have to be erased for compliance with a legal obligation in EU or national law.
K. Data retention
- Data retention policy. We store your data as long as is necessary to provide our services or we have a legitimate interest in further storage. We will keep data that we must keep in order to meet contractual or statutory retention periods (tax, penal, commercial, and invoices). Because of that, your data will due to tax regulations be retained for up to ten (10) full fiscal years from the cancellation of your Service account.
- In the event you cancel your Service account, your account information will be retained although your Service account will not be visible on our Website anymore.
- Data retention for compliance with legal requirements. You cannot require us to change any of the default retention periods, except for the reasons for erasure pursuant to section J.3.
- Data restitution and/or deletion. When we have no ongoing legitimate interest, we anonymize your information, unless we must keep it to evidence our compliance with applicable law. For instance:
- We will keep your data in the event of an outstanding issue, claim, or dispute requiring us to keep the relevant information until it is resolved; or
- The information must be kept for our legitimate business interests, such as fraud prevention, and enhancing users’ safety and security.
- You may request a data copy before termination. You must not cancel the Service account until the data copy has been delivered, as we otherwise will not be able to deliver the data copy.
We will cooperate with you in order to ensure compliance with applicable data protection provisions, e.g. to enable you to effectively guarantee the exercise of data subjects’ rights (right of access, rectification, erasure, blocking, opposition), to manage incidents including forensic analysis in case of security breach.
M. Terms of service
N. Your consent
You may at any time lodge a complaint with a supervisory authority regarding our collection and processing of your personal data.