- What is Personal Data?
Personal Data is any information relating to personal or material circumstances that relates to an identified or identifiable individual. This includes, for example, your name, date of birth, e-mail address, postal address, or telephone number as well as online identifiers such as your IP address. In contrast, information of a general nature that cannot be used to determine your identity is not Personal Data. This includes, for example, the number of users of a website.
- What is Special Category Data?
Special category data is Personal Data that needs more protection because it is sensitive. This includes Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data. As well as, data concerning health, a person’s sex life; and a person’s sexual orientation. In order to lawfully process Special Category Data, it is necessary to consent to the processing.
- What is processing?
“Processing” means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means. The term is broad and covers virtually any handling of data.
- Who is responsible for data processing
Responsible for data processing is ITEERS IT Services trading as Ugdate of Gregorius Coolstraat 12, 5623BG Eindhoven, the Netherlands with KVK: 89173643 (“Ugdate”, “we”, “us”, or “our”). We act as the data controller and ask you to direct all questions about your Personal Data directly to us using firstname.lastname@example.org or write us to the above address.
- What law applies?
In principle, we will only use your personal data in accordance with the applicable data protection laws, in particular the Dutch GDPR Implementation Act (“UAVG”) and the General Data Protection Regulation (“GDPR”).
- What are the legal bases for processing Personal Data
In accordance with the above-mentioned laws, we have to have at least one of the following legal bases to process your Personal Data:
- you have given your consent,
- the data is necessary for the fulfilment of a contract / pre-contractual measures,
- the data is necessary for the fulfilment of a legal obligation or
- the data is necessary to protect our legitimate interests, provided that your interests are not overridden.
- Where is your data stored?
In the course of our business and Platform operations, we process data in our Netherlands based headquarters. All data collect is generally transferred to our server using Hostinger International Ltd. and our Google Firebase Database when you are using our APP. The legal basis for the data processing is our legitimate interest in providing our Platform.
- How long is your data stored?
We process and store your Personal Data only to achieve the respective processing purpose or for as long as a legal retention period exists (in particular the Netherland’s commercial and tax law for up to seven years). Once the purpose has been achieved or the retention period has expired, the corresponding data is routinely deleted.
Processing of Automatically Collected Data
- Collection of access data and log files
We collect data on every access to our website. The access data includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.
Log file information is stored for security reasons (e.g., for the clarification of abuse or fraud) for a maximum of 7 days and then deleted. Data whose further storage is necessary for evidentiary purposes is exempt from deletion until the respective incident is finally clarified. The legal basis for the data processing is our legitimate interest in providing an appealing website.
Cookies” are small files that are stored on your device. Different information can be stored within the cookies. We use so-called cookies on our website. Cookies are pieces of information that are transmitted from our web server or third-party web servers to your web browser and stored there for later retrieval.
- Downloading and Installing the APP
The APP can be downloaded from the “Google Playstore” a service offered by Google LLC, or the Apple App service “App Store” a service of Apple Inc. to install our APP. Downloading it may require prior registration with the respective App store and/or installation of the respective App store software.
As far as we are aware, Google collects and processes the following data: License check, network access, network connection, WLAN connections, and location information. However, it cannot be ruled out that Google also transmits the information to a server in a third country. We cannot influence which Personal Data Google processes with your registration and the provision of downloads in the respective App store and App store software. The responsible party in this respect is solely Google as the operator of the Google Play Store.
As far as we are aware, Apple collects and processes the following data: device identifiers, IP addresses, location information, it cannot be excluded that Apple also transmits the information to a server in a third country. This could in particular be Apple Inc. One Apple Park Way, Cupertino, California, USA, 95014. We cannot influence which Personal Data Apple processes with your registration and the provision of downloads in the respective app store and app store software. The responsible party in this respect is solely Apple as the operator of the Apple App Store.
- Device information collected by Google and Apple
Google and Apple may collect information from and about the device(s) you use to access the APP, including hardware and software information such as IP address, device ID and type, device-specific and APP settings and properties, APP crashes, advertising IDs (AAID), information about your wireless and mobile network connection such as your service provider and signal strength; information about device sensors such as accelerometer, gyroscope, and compass.
We use the Google Firebase developer Platform and related features and services provided by Google LLC and Google Ireland Limited. Google Firebase is a Platform for developers of apps for mobile devices. The Google Firebase Developer Platform offers a variety of features. A list of these features can be found at: https://firebase.google.com/terms/. Firebase’s key security and privacy information can be found here: https://firebase.google.com/support/privacy
- Authorizations and Access
We may request permission to store your APP data including your Internet Connection and Network, Location, Push Notifications, Camera, Gallery, Location, and file storage of your device. The legal basis for data processing is our legitimate interest and the provision of contractual or pre-contractual measures. You can deny access on your device via the Settings/Notifications/ options of your device; however, this means that our APP may not function as intended.
- Push messages
When you use the app, you will receive so-called push messages from us, even if you are not currently using the App. These are messages that we send you as part of the performance of the contract. You can adjust or stop receiving push messages at any time via the device settings of your device. Insofar as you consent to the use of push messages, consent is the legal basis for the processing.
Our App is build using the Freemium Model. As such, the APP uses third-party advertising networks service to display ads. In order to provide personalized advertisements to our users, Google uses device information that include personal and non-personal data, such as advertising (or ad) identifiers, IP address regarding the delivery of advertisements and your interaction with them and/or other tracking technologies to enable and optimize its advertising procedure. Advertisers and third parties also may collect information about your activity on our APP, on devices associated with you, and on third-party sites and applications using tracking technologies. Tracking data collected by these advertisers and third parties is used to decide which ads you see both on our APP and on third-party sites and applications.
The App uses the Google Admob service to display ads. Ads are personalized and based on the device you are using. You can disable this via the settings on your device. You can also opt out on the Digital Advertising Alliance (DAA) if you wish not to receive targeted advertising. In addition, you may also choose to control targeted advertising you receive within applications by using the settings and controls on your devices.
When you make In-app purchases, we (Google and Apple on our behalf) may collect the following data from you to process the purchase:
- Android or Apple user ID
- Email address
- Payment confirmation from the payment data collected by Apple or Google; and
- Device IP and device serial number to link the story history to the device.
Data processing when you use our services
It goes without saying that we cannot help you find a partner without knowing some data about you, such as basic profile data and the types of people you would like to meet. We also collect data that occurs while you are using our services, such as records of access, but also data from third parties, such as when you access our services through social networks. You can find more information about this below.
- Contacting us
If you contact us, we process the following data from you for the purpose of processing and handling your request: first name, last name, e-mail address, and, if applicable, other information if you have provided it, and your message. The legal basis for the data processing is our obligation to fulfil the contract and/or to fulfil our pre-contractual obligations and/or our overriding legitimate interest in processing your request.
- Account Registration
If you create a user account, we will collect your Full Name, Email Address, Date of Birth, Gender and who you are interested in. Within your profile you are able to delete your account at any time. Your data will be processed on the basis of your consent.
As a registered user, you have the opportunity to create a user profile with just a few clicks and details. If you make use of the option, the relevant profile data you provide will be transferred to your profile. Of course, you can change the information at any time via the settings in your profile.
When creating a profile, you can submit both Personal Data and Special Category Data. You have choices about the information on your profile. You don’t have to provide additional information on your profile; however, profile information helps you to get more from our Services. It’s your choice whether to include sensitive information on your profile and to make that sensitive information public. Please do not post or add Personal Data to your profile that you would not want to be available.
The legal basis for the processing of your Personal Data is the establishment and implementation of the user contract for the use of the service. We store the data until you delete your user account. Insofar as legal retention periods are to be observed, storage also takes place beyond the time of deletion of a user account.
- Profile Verification
You may verify your account by creating and uploading an Image of your Face. In doing so, we may derive facial-related information from you and use it solely for the purpose of verifying that it is you. We do not collect, use, or store any facial-related information for the purpose of recognizing faces outside of this limited purpose.
- When using our services
We process the data of our registered users in order to be able to provide our contractual services as well as to ensure the security of our services and to be able to develop it further.
Some of the Personal Data you provide may be considered “special” or “sensitive”. This includes Personal Data concerning for example your health, racial or ethnic origins, sexual orientation, and religious beliefs. By choosing to provide this data, you consent to our processing of that data.
You have choices about the Personal Data you upload and share. You don’t have to provide Personal Data; however, Personal Data helps you to get more from our Services. It’s your choice whether to include Special Category Data and to make that Special Category Data public. Please do not upload or add data that you would not want to be available.
The legal basis for the processing of your personal and Special Category Data is the establishment and implementation of the user contract for the use of the service as well as your consent. We store the data until you delete your user account. Insofar as legal retention periods are to be observed, storage also takes place beyond the time of deletion of a user account.
You may withdraw your consent and request us to stop using and/or disclosing your personal and Special Category Data by submitting your request to us.
The legal basis for the data processing is the fulfilment of our contractual obligations and, in individual cases, the fulfilment of our legal obligations as well as your consent.
- Contacting others
Of course, we also process your chats and communications with other users as well as the content you publish, as necessary for the operation of the services. In addition to the information, you may provide us directly, we receive information about you from others. Users may provide information about you as they use our services, for instance as they interact with you or if they submit a report involving you.
We also share some users’ information with service providers and partners who assist us in operating the services. You share information with other users when you voluntarily disclose information on the service (including your profile). Please be careful with your information and make sure that the content you share is stuff that you’re comfortable being visible. The legal basis for the data processing is the fulfillment of our contractual obligations and, in individual cases, the fulfillment of our legal obligations as well as your consent.
- Information that we receive from others
In addition to the information, you provide to us directly, we receive information about you from others, including other users who provide us with information about you when they use our Services. For example, we may receive information about you from other users when you contact them about us. We collect information about your activities on our Services, such as how you use them (e.g., the date and time you logged in, features you used, searches you performed, clicks and pages you were shown, ratings you clicked on) and how you interact with other users (e.g., users you connect and interact with, the time and date of your exchanges).
- Service Notifications
By using our services, you are giving your consent to receiving notifications and messages per email. Those typically include administrative information about your account and activity. The legal bases are to provide you with our services and your consent.
- Administration, financial accounting, office organization, contact management
We process data in the context of administrative tasks as well as organization of our operations, financial accounting and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The purpose and our interest in the processing lies in the administration, financial accounting, office organization, archiving of data, i.e., tasks that serve the maintenance of our business activities, performance of our tasks and provision of our services.
Insofar as you have also given us your consent to process your Personal Data for marketing and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to.
You may give us your consent in a number of ways including by selecting a box on a form where we seek your permission, or sometimes your consent is implied from your interactions or contractual relationship. Where your consent is implied, it is on the basis that you would have a reasonable expectation of receiving a marketing communication based on your interactions or contractual relationship with us.
Our Marketing generally takes the form of e-mail but may also include other less traditional or emerging channels. These forms of contact will be managed by us, or by our contracted service providers. Every directly addressed marketing sent by us or on our behalf will include a means by which you may unsubscribe or opt out.
- Obligation to provide Personal Data
You are not obliged to provide us with Personal Data. However, depending on the individual case as described above, the provision of certain Personal Data may be necessary for the provision of the services. If you do not provide us with this Personal Data, we may not be able to provide the requested service.
Persons under the age of 16 should not transmit any Personal Data to us without the consent of their parents or legal guardians. We do not request Personal Data from minors and children and do not knowingly collect such data or pass it on to third parties.
- Automated decision-making
Automated decision-making including profiling does not take place.
- Do Not Sell
We do not sell your Personal Data.
- Social Media
We are present on social media on the basis of our legitimate interest. If you contact us via social media Platforms, we and the relevant social media Platform and we are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. The legal basis for the use of the relevant social media Platform is our legitimate interest, your consent or, in the case of a (pre) contractual relationship with us, the initiation of a contractual service, if any.
We will not disclose or otherwise distribute your Personal Data to third parties unless this is a) necessary for the performance of our services, b) you have consented to the disclosure, c) or the disclosure of data is permitted by relevant legal provisions.
In addition, we may disclose your Personal Data: in connection with law enforcement, fraud prevention or other legal proceedings; as required by law or regulation; if Ugdate (or a part of Ugdate) is sold to or merged with another company; or if we have reason to believe that disclosure is necessary to protect Ugdate, its users or the public.
In all cases other than those described above, Personal Data will not be disclosed by us to third parties for their own marketing purposes without your consent.
- International Transfer
In the course of our business, we process data. This also includes disclosure by transmission to third parties and, where applicable, to so-called third countries outside the Netherlands or the EEA. Where we transfer data outside the Netherlands or the EEA, we ensure that processing of your Personal Data is governed by Processing Agreements that include Standard Contractual Clauses to ensure a high level of data protection.
- Data Security
Our data processing is subject to the principle that we only process the Personal Data that is necessary for the use of our services. In doing so, we take great care to ensure that your privacy and the confidentiality of all Personal Data are always guaranteed.
We also use technical and organizational security measures (TOMs) throughout the company to protect the data we manage from you against accidental or intentional manipulation, loss, destruction or against access by unauthorized persons.
Nonetheless, databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised, and the notice will be accompanied by a description of the action being taken to reconcile any damage as a result of the data breach. Notices will be provided as expeditiously as possible after which the breach was discovered.
Your Rights and Privileges
- Privacy rights
Under the UAVG and the GDPR, you can exercise the following rights:
- Right to information
- Right to rectification
- Right to object to processing
- Right to deletion
- Right to data portability
- Right of objection
- Right to withdraw consent
- Right to complain to a supervisory authority
- Right not to be subject to a decision based solely on automated processing.
If you wish to exercise any of your rights, please contact us.
- Updating your information
If you believe that the information, we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please do so by contacting us.
- Withdrawing your consent
You can revoke consents you have given at any time by contacting us. The legality of the data processing carried out until the revocation remains unaffected by the revocation.
- Access Request
In the event that you wish to make a Data Subject Access Request, you may inform us in writing of the same. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the respective legal regulations mentioned above).
- Complaint to a supervisory authority
You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection. The supervisory authority in the Netherlands is:
The Autoriteit Persoonsgegevens, PO Box 93374, 2509 AJ Den Haag, The Netherlands www.autoriteitpersoonsgegevens.nl
Controls For Do-Not-Track Features
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (‘DNT’) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
If you would like to contact us regarding our privacy practices for any reason, please do so using email@example.com or write us to the above address.