PRIVACY POLICY
CONTENTS
2. What
Personal Data do we collect?
3. How do
we use your Personal Data?
4. What
legal basis do we rely on when processing your Personal Data?
5. Online tracking and analysis
7. Data
Transfers to Third Countries
8. With
which third parties do we share Personal Data?
9. What
Personal Data do we share with third parties?
10. What
Personal Data do we receive from third parties?
11. How
long do we retain your Personal Data?
12. How do
we secure your Personal Data?
15. Changes
to this Privacy Policy
This privacy policy (“Privacy Policy”) applies to the use of the website
https://partnerapp.dating/ in its entirety, including
all of our subpages, associated sites or pages (“Website”), and the PARTNER/TWINK
mobile and web app, which is accessible through browser on your mobile phone,
tablet computer and personal computer (“App”) (collectively, “PARTNER/TWINK”).
We are responsible for all information relating to an identified or
identifiable natural and, where applicable, legal person (“Personal Data”) that
we collect, process, and use during your use of PARTNER/TWINK.
This Privacy Policy outlines how we process your Personal Data both in
connection with PARTNER/TWINK and otherwise. The Website includes links to
third-party websites, such as social networks. Clicking on those links or
enabling those connections may allow the third party to collect or share data
about you. We do not control these third-party websites, and we encourage you
to read the privacy policy of those third-party websites.
We are committed to protecting your privacy and handling your Personal
Data in accordance with applicable laws and regulations. To achieve this, we
adhere to the principles of data minimization and purpose limitation. We will
only collect and process personal information that is necessary for the
specific purposes stated in this policy. Your data will not be used for any
purpose other than those disclosed and we will only retain it for as long as
required to fulfill these purposes or requests under applicable law.
We also prioritize transparency and respect for your privacy choices.
You have the right to access, correct, or delete your personal data held by us.
Your privacy is important to us, and we are committed to maintaining the
highest standards of data protection and user control in order to make PARTNER/TWINK
a service that people love and trust.
Some of the personal data we collect is mandatory for the provision and
functioning of PARTNER/TWINK, while other personal data is considered optional,
designed to enhance your user experience. Please be aware that without
providing the mandatory personal data, we won't be able to grant you access to PARTNER/TWINK.
a.
When visiting the Website and/or App
When you visit the Website or App, we can process the following
categories of Personal Data from you:
·
Technical Data: IP address, operating system, date and
time of access, country from which PARTNER/TWINK is accessed, browser type,
referrer URL, log-in data, and device type;
·
Tracking Data: See Article 5 below.
b.
When creating
an account
When you create your PARTNER/TWINK account, you voluntarily provide us
with certain information. In this way, we can process the following categories
of your Personal Data, which are either mandatory or optional for creating
account and using PARTNER/TWINK:
MANDATORY:
·
IDENTITY DATA, DETAILS ABOUT YOU ADD (nickname, AGE);
·
Survey DATA (Goal in app, preffered Age preferences,
preffered body type)
· Account data, including User
ID.
Optional:
·
Sexual and other preferences (position, tribes);
·
Identity data, details about you add (Relationship
status, hiv status);
·
Photo.
c.
WHEN USING PARTNER/TWINK
WHEN YOU USE PARTNER/TWINK, YOU VOLUNTARILY PROVIDE US WITH CERTAIN
INFORMATION. WHEN YOU ADD INFORMATION TO YOUR USER PROFILE, INTERACT WITH US OR
OTHER USERS, YOU MAKE THE CHOICE TO SHARE YOUR CERTAIN PERSONAL INFORMATION
WITH US. IN THIS MANNER, WE CAN PROCESS THE FOLLOWING CATEGORIES OF YOUR
PERSONAL DATA, SOME OF WHICH ARE OPTIONAL, WHILE OTHERS ARE MANDATORY TO ENABLE
YOU TO USE PARTNER/TWINK TO ITS FULLEST POTENTIAL AND ENHANCE YOUR OVERALL
EXPERIENCE:
OPTIONAL:
·
LOCATION DATA, INCLUDING GEOGRAPHICAL POSITION, TIME IDENTIFIER;
PARTNER/TWINK IS DESIGNED TO
HELP YOU ENGAGE WITH OTHER USERS LOCATED NEARBY TO YOU. WE USE YOUR LOCATION
DATA (E.G., BY USING THE GPS ON YOUR MOBILE DEVICE) TO ENABLE THE INTENDED
FUNCTIONALITY OF PARTNER/TWINK. THIS WILL BE ENABLED ONLY IF YOU EXPLICITLY
GIVE US PERMISSION TO ACCESS YOUR LOCATION. YOU CAN DISABLE THIS AT ANY GIVEN
TIME BY CHANGING THE LOCATION PERMISSIONS ON YOUR DEVICE OR IN THE BROWSER.
PLEASE KEEP IN MIND THAT WHEN YOU USE PARTNER/TWINK, OTHER USERS CAN VIEW YOUR
LOCATION DATA AND THEY MAY USE IT FOR PURPOSES YOU DID NOT INTEND, OR DISCLOSE
IT TO INDIVIDUALS OR ENTITIES OUTSIDE OF OUR CONTROL AND WITHOUT OUR AND YOUR
KNOWLEDGE. THE INFORMATION YOU PROVIDE MAY BE SUBJECT TO ABUSE, MISUSE, AND
MONITORING BY OTHERS, AND YOU SHARE THIS INFORMATION AT YOUR OWN RISK.
·
Transactional data, including information about the
application process, contract content, contract management and execution;
·
Financial data, including billing and payment
information;
·
Pictures, videos, audio and text messages sent when
communicating with others (i.e. users content and material that have been
submitted in the chat conversations, collectively “User Submissions”)
are processed in order to secure and operate services and keep our user
community safe. To safeguard user safety, we use automated systems to monitor
and review pictures in chat conversations between users. This approach is in
strict compliance with data protection regulations and is undertaken to meet
the legal requirements imposed by specific countries concerning the transmission
of explicit content. For this PURPOSE, pictures will be anonymized and stripped
of personal information to protect your privacy, thereby ensuring data
protection against unauthorized access or disclosure. For more details about
this, please see our Terms and Conditions;
·
Pictures and videos that you upload, publish or
provide in any other way. In order to add this kind of content, you first have
to give us permission to access your photo album/gallery and/or your camera;
·
Usage data, including activity data, online
interactions with us and with other users;
·
SEXUAL IDENTITY DATA (SEXUAL ORIENTATION DO YOU HIDE
YOUR ORIENTATION);
·
IDENTITY DATA, DETAILS ABOUT YOU ADD (HEIGHT, BODY
TYPE, ETHNICITY, TATTOOS);
·
Your insights into our products and services,
responses and testimonials you provide us when you participate in surveys,
market studies or answering questions;
·
Information that is used for participation in
different contests, events and promotions we provide;
·
If you contact our customer support team, we collect
the information you give us during the interaction, and
·
Photographic image of you and your form of
identification that can confirm the date of your birth when appealing our decision
to revoke your license, authorization to access and/or use PARTNER/TWINK and
terminate your account for failure to comply with our rules on minimum required
age (see more here).
We receive most of your Personal Data directly from you. To the extent
permitted by applicable law, we can also obtain your Personal Data from
publicly available sources or from public authorities and other third parties
(e.g., service partners, internet analysis services). Personal data we share
with third parties is regulated by Article 7 of this Agreement.
We use your Personal Data to provide you products, offer you services,
communicate with you, or to conduct other business operations, such as using
data to improve and personalize your experience. Examples of how we may use the
personal data we collect include:
·
Business relationships: We utilize transactional data,
financial data, User Submissions and others for establishing, administrating,
and processing contractual relationships, including the creation and management
of a user account to enable you to fully utilize PARTNER/TWINK.
·
Ensuring the core functionality of the business and PARTNER/TWINK:
We use location data, including geographical position, time identifier,
identity data, sexual identity data, including sexual orientation, sexual
preferences and others to ensure the core functionality of the business and PARTNER/TWINK,
which encompasses maintenance, provision, improvement, monitoring, and
geographically locating you relative to other users on PARTNER/TWINK.
·
Security and access control: Location data, including
geographical position, time identifier, usage data, activity data, account data
and others are used for monitoring, analyzing, and testing of networks and IT
infrastructures, system and error checks, documentation, security copies, and
communication of security updates;
·
Market and opinion research: We use usage data,
activity data, your insights, responses, testimonials, interactions and others
for monitoring and analyzing your use of PARTNER/TWINK, using statistical data
for scientific and analysis purposes, further developing the offers we provide
on PARTNER/TWINK, administering focus groups, determining user demographics,
and conducting market studies and surveys;
·
For the purpose of Advertising and marketing,
including promotional offers, events, and contests, we mainly utilize your
insights and information used for participation in different contests, events,
and promotions we provide;
·
Compliance with laws and regulatory recommendations
and directives: Know your customer (KYC) clarifications, fulfillment of
disclosure, information and reporting obligations, fulfillment of archiving
obligations, and the prevention, detection, and clarification of criminal acts;
·
Safeguarding legal claims: Assertion, enforcement, and
defense of legal claims, and
·
Other: For any other purpose with your consent.
We process your Personal Data based on the following legal bases:
·
Performance of contractual obligations: It is
necessary for us to process your Personal Data to provide PARTNER/TWINK to
users and thus carry out our obligations under the terms and conditions of PARTNER/TWINK
(e.g., create user account, receive payments);
·
Legitimate interests: It is necessary to process your
Personal Data to pursue our legitimate business interests, provided that your
rights and freedoms do not override these legitimate interests, which include
but are not limited to the protection of PARTNER/TWINK and enhancing the
functionality and efficiency of PARTNER/TWINK;
·
Compliance with applicable laws and regulations: It is
necessary to process your Personal Data to comply with our legal obligations
(e.g., accounting, tax, and other statutory data retention obligations); and
·
Your consent: If you choose to provide us with
Personal Data that may be considered sensitive in certain jurisdictions, such
as your sexual identity data, you are giving us consent to process that
Personal Data in accordance with this Privacy Policy. We will explicitly ask
for your consent to collect specific Personal Data such as your precise
geolocation, to transfer your Personal Data to countries without an adequate
level of data protection (for more information please see Article 7 of the
Agreement), or to use your Personal Data for certain specific reasons (e.g.
direct marketing). You may withdraw your consent at any given time by
contacting us as stated in this Privacy Policy. You can exercise this right at
any time and doing so won't affect the legality of processing your data that
occurred before the withdrawal, as long as you were informed before giving your
consent.
a.
COOKIES
WE USE AND MAY ALLOW OTHERS TO USE COOKIES AND SIMILAR TECHNOLOGIES ON PARTNER/TWINK
TO RECOGNIZE YOU AND/OR YOUR DEVICE(S). IF YOU WOULD LIKE TO GET MORE
INFORMATION RELATED TO THIS MATTER, PLEASE CONTACT US BY EMAIL AT SUPPORT@PARTNERAPP.DATING.
b.
ANALYTICS
WE USE ANALYTICS AND RESEARCH TECHNOLOGIES ON PARTNER/TWINK TO COLLECT
INFORMATION ABOUT HOW VISITORS USE PARTNER/TWINK. IF YOU WOULD LIKE TO GET MORE
INFORMATION RELATED TO THIS MATTER, PLEASE CONTACT US BY EMAIL AT SUPPORT@PARTNERAPP.DATING.
c.
LOG FILES
WHEN USING PARTNER/TWINK, GENERAL ACCESS DATA IS STORED IN A LOG FILE
FOR THE CREATION OF STATISTICS. WE USE THIS DATA FOR STATISTICAL AND TECHNICAL
EVALUATIONS IN ANONYMIZED FORM, FOR EXAMPLE TO OPTIMIZE THE SERVER
INFRASTRUCTURE, TO DETERMINE ON WHICH DAYS THERE ARE PARTICULARLY MANY
ACCESSES, OR TO DRAW CONCLUSIONS ABOUT POSSIBLE IMPROVEMENTS TO THE USER
INTERFACE AND FUNCTIONALITIES. A PERSONAL EVALUATION OF THIS DATA DOES NOT TAKE
PLACE.
There are links on our Website to our profiles on the following social
networks:
·
Meta Platforms Inc., 1601 Willow Road, Menlo Park, CA
94025, USA please find more information about data protection here.
·
Twitter Inc., 1355 Market Street, Suite 900, San
Francisco, CA 94103, USA, please find more information about data protection here.
·
TikTok Inc., 5800 Bristol Parkway Culver City, Los
Angeles, CA 90230, USA, please find more information about data protection here.
If you click on the social network icons, you will automatically be
redirected to our profile on the corresponding social network.
When you open a link to one of our profiles, a direct connection is
established between your browser and the server of the relevant social network.
This provides the network with the information that you have visited PARTNER/TWINK
with your IP address and accessed the link. If you access a link to a network
while logged into your user account on the network in question, the content of PARTNER/TWINK
may be linked to your user account on the network, i.e., the network may link
your visit originating from PARTNER/TWINK directly to your user account on the
social network. If you want to prevent this, you should log out from your
account before clicking on the corresponding links. In any case, an association
takes place when you log in to the relevant network after clicking on the link.
We may transfer your Personal Data abroad to our business partners
located in third countries, specializing in Analytics, Data Processing,
Business Operations and Data Integration, Content Moderation, Marketing, and
App Tracking.
To safeguard your data privacy rights when transferring your personal
data to third countries, including those where adequate data protection might
not be guaranteed, we use tools such as Standard Contractual Clauses (SCCs) -
approved by relevant data protection authorities, Binding Corporate Rules (BCR)
and other appropriate mechanism that ensure the personal data transfer complies
with applicable laws and regulations. These mechanisms are designed to provide
a legal framework for the protection of your personal data during international
transfers and demonstrate our commitment to maintaining the highest standards
of data protection.
IN ADDITION, WE ENSURE THAT THE PERSONAL DATA TRANSFER COMPLIES WITH
APPLICABLE LAW. FURTHERMORE, WE TAKE INTO CONSIDERATION SPECIFIC SAFEGUARDS,
INCLUDING BINDING CORPORATE RULES AND STANDARD CONTRACTUAL CLAUSES.
WHEN REQUIRED, WE MAY RELY ON YOUR EXPLICIT CONSENT FOR DATA TRANSFERS,
AS STIPULATED BY APPLICABLE REGULATIONS. WE CONDUCT A COMPREHENSIVE ASSESSMENT
TO SAFEGUARD YOUR PERSONAL DATA WHEN TRANSFERRED TO THIRD COUNTRIES. THIS
REFLECTS OUR UNWAVERING COMMITMENT TO PROTECT YOUR DATA DURING INTERNATIONAL
TRANSFERS AND MITIGATE POTENTIAL PRIVACY RISKS. WE TAKE YOUR PRIVACY SERIOUSLY
AND ENSURE THAT SUCH TRANSFERS COMPLY WITH THE REQUIREMENTS OF THESE DATA
PROTECTION LAWS AND REGULATIONS.
In alignment with data protection regulations, we prioritize
transparency when it comes to the transfer of your personal data to third
parties. This section provides you with essential details regarding such
transfers. We may transfer your personal data to carefully selected third
parties situated within or outside CYPRUS when we have a business reason to
engage these organizations.
Once again, we would like to emphasize that we consistently ensure
compliance with legal requirements by using up-to-date necessary and recognised
mechanisms, guaranteeing the confidentiality and integrity of your personal
data's privacy and security throughout its processing and transmission to these
third parties.
As we operate on a global scale, the recipient of shared Personal Data
and the location data of processing may vary depending on your geographical
location and other events. Third parties are located and may process shared data
in countries within the European Economic Area (EEA) and the European Union
(EU) (including but not limited to Ireland, Belgium, Netherlands, Denmark,
France, Germany, Cyprus, and Finland). Additionally, data may be shared to
other countries in Europe (including but not limited to the United Kingdom and
Russia), as well as to Asia (including but not limited to Israel, India,
Vietnam, Japan, Singapore and Hong Kong). Furthermore, data processing and
sharing extends to third parties in North and South America (including but not
limited to the United States of America, Canada, Mexico, and Brazil) and
Australia.
In particular, we may disclose your Personal Data to the following
categories of recipients:
·
Service providers: We work with trusted service
providers that process your Personal Data on our behalf or under joint
responsibility (e.g., providers of telecommunications systems, email, database,
hosting, outsourcing, payment, user verification, advertising, marketing,
analytics, anti-spam, anti-fraud services). These service providers may also
use your Personal Data for their own purposes. Service providers provide
information about their independent data processing in their own privacy statements.
·
Buyers or merger partners: In connection with an
actual or potential restructuring of part or all of our business or our assets
or any rights or interests therein, we may disclose your Personal Data to
potential buyers or merger partners or sellers and their advisors.
·
Government agencies: We may disclose your Personal
Data to governmental agencies, courts, and other authorities, both domestic and
foreign, if we are legally obligated or entitled to do so or if we deem it
necessary to do so in order to protect our interests.
This disclosure aligns with our commitment to transparency, in
accordance with relevant data protection laws and regulations. Please refer to
the Article 7 of Privacy Policy for detailed information on data sharing and protection
practices.
By signing in PARTNER/TWINK using your Facebook account you give
permission to Facebook to share your email address, name and your profile
picture with PARTNER/TWINK. You have an option to manually opt-out of
permission to allow Facebook sharing your email address with PARTNER/TWINK,
however this is only possible when an email is associated with your Facebook
account.
By signing in to PARTNER/TWINK using your Apple ID you give permission
to Apple to share your Apple login, your name and your email with PARTNER/TWINK.
Apple is offering an option to hide your email, so you can keep your email
address private but still receive messages from the App. To enable this, Apple
will create a random email address, link it to your account on PARTNER/TWINK
and allow your personal email to stay private.
By signing in to PARTNER/TWINK using your HUAWEI ID you give permission
to HUAWEI to share with PARTNER/TWINK your profile picture, your nickname or
anonymised phone number/email address if no nickname is set, to link your
HUAWEI ID and to share your email address. HUAWEI allows you to manually
opt-out of sharing the email address.
By signing in PARTNER/TWINK with your Google Account you give permission
to Google to share your name, email address, language preference AND WITH PARTNER/TWINK.
Compiled data will be used in order to form your account on PARTNER/TWINK.
You can always manually withdraw your permission to access the data above by
removing the PARTNER/TWINK app from the Facebook settings, your Google account
or from your Apple ID or by canceling authorization for HUAWEI ID. Data
provided at the set up of the account using any of these THIRD-PARTY services
will still be accessible to PARTNER/TWINK, even after you withdraw permission
on these THIRD-PARTY services. In order to remove our access to this data you
will have to delete your PARTNER/TWINK account. Your rights regarding, and
setting options for protecting your privacy, can be found in the privacy
notices of the providers:
·
Apple Inc., One Apple Park Way, Cupertino, CA 95014,
USA; please find more information about data protection here.
·
Google LLC, 1600 Amphitheatre Parkway, Mountain View,
CA 94043, USA; please find more information about data protection here.
·
Meta Platforms Inc., 1601 Willow Road, Menlo Park, CA
94025, USA please find more information about data protection here.
·
Huawei Device Co. Ltd., 9 Canton Road, Tsim Sha Tsui,
Kwloon, Hong Kong; please find more information about data protection here.
We only retain your Personal Data for as long as it is needed for the
purpose for which it was originally collected or as we are required to retain
it under applicable laws and regulations or contractual agreements. If you
would like to get more information related to this MATTER, please contact us by
email at SUPPORT@PARTNERAPP.DATING.
We use appropriate technical and organizational security measures to
protect Personal Data from loss, misuse, or alteration. Our employees and the
service providers commissioned by us are contractually obliged to maintain
confidentiality and to comply with the provisions of data protection law.
However, it is not possible for us to guarantee the absolute security of
Personal Data. In this context, please note that data transmitted over an open
network such as the Internet or an email service is openly accessible. We
cannot guarantee the confidentiality of messages or content shared over these
networks. Thus, Personal Data sent to us via open networks will not be subject
to the same security measures as Personal Data contained within PARTNER/TWINK.
You have the following rights:
·
Access: You have the right to access your Personal
Data. This gives you the opportunity to check what Personal Data we process
about you and that we process it in accordance with the applicable data
protection regulations.
·
Rectification: You have the right to have inaccurate
or incomplete Personal Data rectified and to be informed of the rectification.
In this case, we will inform the recipients of the data concerned of the
adjustments made, unless this is impossible or involves disproportionate
effort.
·
Deletion: You have the right to have your Personal
Data deleted under certain circumstances.
·
Restrict processing: You have the right, under certain
conditions, to request that the processing of your Personal Data be restricted.
·
Data portability: You have the right, under certain
circumstances, to obtain from us, free of charge, the Personal Data you have
provided to us in a readable format.
·
Lodge a complaint with a supervisory authority: You
have the right to lodge a complaint with a competent supervisory authority
about the way in which your Personal Data is processed.
·
Withdrawal: You have the right to withdraw your
consent to the processing of your Personal Data at any time, free of charge,
and without giving any reason by contacting us at the address provided in this
Privacy Policy. Processing activities conducted with your consent in the past,
prior to you revoking consent, do not become unlawful as a result of your
revocation.
Please note that the above-mentioned rights are not absolute. These
rights are subject to exceptions and their applicability is largely dependent
on the legal basis we rely on in each case and the various circumstances of
each specific request.
If you would like to exercise any of your rights ABOVE, please contact
us by email at SUPPORT@PARTNERAPP.DATING.
If you are a California resident, California law may provide you with
additional rights regarding the Company’s use of your personal information.
California Civil Code Section 1798.83 permits you to request information
regarding the disclosure of your personal data by us to third parties for the
third parties’ direct marketing purposes. Further, if you are a California
resident and would like to opt out from the disclosure of your personal data to
any third party for their direct marketing purposes, please send an email to
the email contact listed below. However, please know we do not currently
disclose your personal data to any third party for their direct marketing
purposes. If you opt out from permitting your personal data to be shared, you
may still receive selected offers directly from us in accordance with
California law.
Users who are not at least 18 years old or older when explicitly
required by applicable state laws (referred to as “minor/s” hereafter) are not
permitted to use PARTNER/TWINK. We do not knowingly collect Personal Data from
minors.
We encourage parents and legal guardians to monitor their children's
Internet usage and to help enforce our Privacy Policy by instructing their
children not to use PARTNER/TWINK and thus not to provide Personal Data on PARTNER/TWINK.
If you have reason to believe that a minor has provided Personal Data to us,
please contact us immediately and we will endeavor to delete that data from our
databases.
We may change this Privacy Policy to address changes in the legislation
or on PARTNER/TWINK. Changes to this Privacy Policy will take effect
automatically after they are first posted on the Website or App.
If you would like to exercise any of your rights or if you have
feedback, comments, or questions about data protection or this Privacy Policy
please contact us by email at SUPPORT@PARTNERAPP.DATING.
This Privacy Policy was last updated on 29 NOVEMBER 2023.