We are committed to protecting and respecting your privacy.
This policy (together with our terms and conditions of use and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. By ticking the acceptance box when signing up to use our Services, and by your continued use of the Services, you agree to bound by this policy as updated from time to time.
This policy will tell you about:
- Who we are
- Your rights to access and/or amend data held and opt out of consenting to uses of your data
- What data we collect
- What we do with this data
- Where we store this data
- How long we store your data for
- Steps taken to keep data safe
- Our right to amend our policy
1. WHO WE ARE
Together Networks Limited is the data controller (for the purposes of the Data Protection Act 1998). We own and/or operate a large number of dating, adult entertainment sites (including mobile applications/apps) through our Group Companies and Partner Sites. We refer to our sites and apps as, collectively, the “Services” within this policy. Some of our terms will make reference to our Group Companies or Partner Sites and any reference in this policy to “us” or “we” or “our” will include our Group Companies and Partner Sites.
(a) ABOUT OUR GROUP COMPANIES
As a large organisation we have a number of subsidiary companies (“Group Companies”) that operate some of our sites on our behalf or provide services to us to enable us to provide the Services to you. For data protection purposes, these companies are called data processors and this includes Together Networks Limited, who operates this site. Our Group Companies are all wholly/majorly owned by us.
(b) ABOUT OUR PARTNER SITES
We want to offer you a full range of products and services and in order to do that we will share your details across our Partner Sites (See below Creation of duplicate profiles across our Partner Sites) and we will market our different products and services to you (See below Marketing). You authorise us to reproduce and broadcast the information contained in your profile including your name, photograph, 'chat up line', description etc. throughout all or part of our Partner Sites and our Group Companies for the purposes of delivering the Services to you.
2. YOUR RIGHTS TO ACCESS/AMEND THE DATA WE HOLD ON YOU & OPT OUT
(a) Accessing the data we hold on you
If you want to know what data we hold on you, you have a legal right to obtain this information from us. You can make a Subject Access Request at any time, in writing, by following this simple process. By law, we have up to 40 days to respond to you and reserve the right to make a small charge for this service.
To make a Subject Access Request please write to us enclosing a photocopy of a photographic ID (e.g. passport or driving licence) and utility bill (to provide proof of your address). This is to ensure we only send your data to you, or a third party that you expressly authorise in writing to deal with for you.
Our address for this purpose only is Vincenti Buildings, 28/19, (Suite No. 1374), Strait Street, VLT 1432, Valletta, Malta
(b) Amending/correcting the data we hold on you
If you want to amend the data we hold that’s also very easy to do. We want to make sure we have everything right so please simply contact us at Vincenti Buildings, 28/19, (Suite No. 1374), Strait Street, VLT 1432, Valletta, Malta to make any amendments to our records.
(c) Changing your consent and opting out
It’s ok to change your mind about what data you are allowing us to keep and what you don’t want us to keep. You can amend your settings through your account at any time, or contact our Support team.
We have to advise you however, that opting out of some data processing/storage will result in a loss of functionality of the sites and a reduced user experience.
3. WHAT INFORMATION WE COLLECT ABOUT YOU
We may collect and process different types of information about you. Some of this data is considered to be Personal Data (that means you can be identified by it including Sensitive Personal Data) and Anonymous Data (that is data that you cannot be identified from).
(a) Information we collect when you sign up to our Services
We will collect your personal details including but not limited to your real name, user name, address, telephone, email address, date of birth, race, religion, sexual orientation and any other information you submit when you create a profile and sign up to our Services
(b) Data we collect in respect of customer service and support
If you contact customer support we will keep any information you provide to us including records of correspondence.
If you provide feedback to us, or take part in any customer survey, or participate in competitions we, we will keep any information you provide.
(c) Data we collect/you upload from your activity across our Services:
When you use our Services to search for other users, explore our Services, or interact with other users, we will gather data related to these activities including:
- Any information you populate your profile with including photographs (see also – Important Notice about how we use your photos);
- Any messages that you send or receive through our sites;
- A record of your activity including winks, block lists and search histories for example is also stored by us;
- Details of any transactions that you carry out, including any information we require to provide the products or services that you sign up to;
- Data from your other social network accounts if they are linked to our sites (see more details below – Information we collect from other social networks you use);
- Your location according to the IP address assigned to your computer machine or mobile device by your Internet Service Provider, and mobile location data (see more details below – Information we collect about your location)
(d) Information we collect from other social networks that you use
Some of our Services have the ability to link your use of the Services to other social networks you might have access to. If you have an account with another social network e.g. Facebook, you can share the data you have on our site with that network. To enhance your experience and create a personalised service we may ask you to login to your Facebook account. By doing so you grant us access to your information stored on your Facebook profile including without limitation your personal information, photographs, videos, interests and locations. When you login to the other network or install our app, we will receive the basic information from you including but not limited to your name, photos, gender, networks, user ID, friends list and any other information you make public and your email address. If you have logged into other social networks and linked them to any of our profiles you grant permission for us to post updates, including location information, on your behalf therefore please exercise caution. You can turn off location data – see below.
(e) Information we collect about your location
We can collect location data from your computer and/or mobile device. When accessing the Services from a mobile device you will be given the option to allow location sharing with our application. If you do not wish to share your location data with us please turn off this feature by following your mobile device instructions to do so. We can track your IP address if you are using a computer to access the Services. If you are using a mobile device we use GPS with an accuracy range of 20 to 100 metres. Although location data is anonymous and can’t identify you, it can be shown to other users so please exercise caution if you do not wish to publicise your location. We also use your location data to research our own Services, develop new products and improve our Services, including using third parties to help us either provide the Services to you or develop new ones, and target advertising to suit your user experience. Your devices can give us lots of information about the device including the brand, model, version of operating system, installed app details, email accounts, mobile carrier and so on. We may also connect your account with location data from Foursquare and can show your Foursquare check ins on our map within some of our Services.
(f) Information we collect about your Contacts
Some features of the Services allow you to share your user experience with people you know (“your Contacts”), or to invite them to join the Services. When given the option to do so you can choose to upload your Contacts information; we will request their name and email address. If you give us your password to upload these Contacts through a web based email provider we shall not store your password after you have uploaded your Contacts’ addresses. You may also choose to invite friends through your connected social networks. You assume all responsibility for ensuring that when you select a friend to be invited by email, application or SMS that the person wants to receive that invite from you.
4. HOW WE USE YOUR INFORMATION
We process data we collect from you for the following core purposes:
- To administer your user account with us (including notifying you of any compatible matches, tips, announcements, updates, special offers or services, should you consent to this);
- To help us improve the structure, layout and usability of the Services;
- To allow you to participate in any interactive features of the Services (including the features that require the mobile phone number);
- To help personalise your repeat visits to and usage of the Services;
- To notify you of any compatible matches or any matches who are near your location;
- To provide you with information on products or services or news and offers that you request from us (see below under 'Marketing' for more information);
- To answer any questions you may raise or respond to any comments you may send to us;
- To notify you about changes to our service or the functionality of the Site;
- To carry out market analysis and research;
- To ensure that you are complying with the terms and conditions of use and to comply with our statutory and regulatory obligations;
(a) Creation of duplicate profiles across our Partner Sites
When you sign up to any one of our Services we will send you an email shortly afterwards advising that we have created a duplicate profile on our Partner Sites to enhance your chance of finding a suitable match. When we email you about this you will have the option to decline this service, which costs nothing extra.
(b) Important notice about how we use your photographs
As we explain in our terms and conditions of use, when you upload a photo to any of our Services you are allowing us to use that photo for advertising and other commercial purposes, royalty free. For full details please refer to our terms and conditions of use – Licence to My Content).
(c) How we use your information about your Contacts
If you choose to upload your Contact’s name and email address and/or mobile number you are allowing us to send an email or social network or mobile invitation on your behalf, inviting your Contact to join the Services. We will store your Contact’s name and email address solely for the purposes of inviting them to sign up to our Services and for associating your Contact with you and other people they may know. If your Contact does not want us to store their email address which you uploaded to our Services, they can ask us to remove it by contacting us at email@example.com. We will not store your Contacts information after invitations (up to a maximum of 3) have been sent. Your Contacts will then only receive future emails from us if they choose to accept the invitation and join our Services, or if you use any of our tools to share experiences with your Contacts and you input their email address for us to use again.
(d) When we disclose your information to third parties and why
We may be required by law e.g. through potential or actual litigation, court order, public or governmental authorities, or rules and regulations within or out with your country of residence to disclose all or part of your information to third parties. We may also deem it necessary to make such a disclosure in the event of an issue of national security, law enforcement or other such similar situations as we deem necessary including, for example, allegations of alleged infringement of copyright, trade marks or other third parties’ rights by users. We share your personal information with third party service providers in order to provide the Services to you including third parties who assist us with information processing, credit and payment processing, fulfilment of your subscription order, managing and hosting data, conducting consumer research or satisfaction surveys. These disclosures relate to providing our Services, improving our Services and delivering targeted advertising to you. We do not provide your contact details to third parties for direct marketing by them to you without your express consent, which will be obtained from you at sign up process if you elect to provide this consent. As we continue to develop our business, we might sell or buy assets. In such transactions, the information we have collected about you will generally be one of the transferred business assets. Also in the unlikely event that any of our Group Companies or our assets are purchased, your information will also be one of the transferred assets. We may share information about you with: Other companies in the same corporate group as us. A buyer or prospective buyer of our business. Our professional advisers, such as our lawyers, where it is necessary for them to advise us. Other persons if we are under a duty to disclose or share your information in order to comply with any legal obligation.
(a) When we market to you directly about our products and services
We may share your information with our Partner Sites and Group Companies to develop and deliver targeted advertising to you of our Partner Sites and Group Companies’ products and services, or to help us to prepare marketing reports. We may send you information about our Partner Sites and Group Companies’ products and services, news and offers, and selected third party products and services that we think may be of interest to you. We may do this by contacting you through your email address or mobile phone number that you have provided. Any communication received from us, as consented to by you, will clearly state that it is being sent by us. You have the option to opt-out of our marketing communications at any time (see below).
(b) When third parties market to you (Our “third party Partner Services”)
If you have consented to receive marketing communications from third parties during our sign up process, referred to as Partner Services, your data may be passed on to such third parties as we enter into data sharing agreements with, from time to time, for marketing and analytical reporting purposes. We cannot be held liable for the content of the third party’s communications or products/services they are promoting. If you have provided this consent, but change your mind, you can opt-out at any time (see below). Please be advised that you will also require to contact the individual third parties who have been marketing to you if you wish to stop receiving their communications directly.
(c) Opting Out of Marketing
If you change your mind about the marketing consent you have granted to us, you can amend your preferences under the “My Account” section of your chosen Site or emailing us at firstname.lastname@example.org
6. WHERE WE STORE YOUR DATA
7. HOW LONG WE KEEP YOUR DATA FOR
Generally speaking, we only store data for as long as it is necessary to provide products and Services to you and others, with information typically being held until you cancel your membership.
For data storage purposes however our users are considered as either being:
(a) Active Users; this means you regularly log on to our Services and use the Services in any way;
(b) Inactive Users: this means that you have not cancelled your account but you haven’t logged in for 4 months, or conducted any activity on our Services in that time;
(c) Cancelled: this means that you have followed our cancellation process and actively cancelled your membership.
(a) Active Users
If you are an Active User we will store your data until you cancel your account.
(b) Inactive Users
If you are an Inactive User, you should be aware that we will continue to store your data until you cancel you account, including continue to market to you if you have consented to marketing. Just because you haven’t logged on for a few months, we hope you will return to use the Services regularly and we want your information to be there for your convenience so you should be aware that you will still appear in our search results for other users, and your profile will remain visible. The responsibility to change your preferences or cancel your account lies with you.
(c) Cancelled Users
If you are a Cancelled User, we will delete all of your data 9 months after the date of cancellation. It is important that we retain your data for this short period after cancellation to ensure that we can answer any payment or other account related queries, or provide information to third parties in line with our disclosure provisions outlined in this policy e.g. assisting police investigations. Even after you remove information from your profile or delete your account, copies of that information may still be viewable and/or accessed on the Internet to the extent such information has been previously shared with others, or copied or stored by other users or to the extent such information has been shared with search engines. We cannot control this, nor do we accept any liability for this. If you have given third party applications or websites access to your personal information they may retain such information to the extent permitted under their terms of service or privacy policies.
(d) Storage of activity data
Whilst we retain your Personal Data, Sensitive Personal Data and Anonymous Data as outlined at (a) to (c) above, there are some features of our Services that we store data in respect of, for different periods of time. For example, messages are only stored for 30 days, winks and other similar activities are stored for 10 days. All other profile and activity information including photographs, blocked list, search histories etc. are stored until 9 months after your account is cancelled.
8. KEEPING YOUR DATA SECURE
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Site; any transmission is at your own risk. Once we have received your information, we will use procedures and security features to try to prevent unauthorised access. Where we have given you (or where you have chosen) a password or user ID code which enables you to access certain parts of the Site, you are responsible for keeping the password or user ID code confidential. We ask you not to share a password or user ID code with anyone.
- To estimate our audience size and usage pattern;
- To store information about your preferences, and so allow us to customise the Services according to your individual interests;
- To speed up your searches;
- To recognise you when you return to any website or application;
- To provide annoymised statistical information: Non-personal data may be gathered on our behalf using cookies, log file data, and code that is embedded on our websites by specific third party partners. We use this non-personal information to help improve the services we provides to you.
When you visit the publicly available sections of the Services, a session ID cookie is placed on your computer that only lasts while you’re visiting. We also place persistent cookies (also known as local storage devices) on members’ computers, so that we remember them to make your login in process faster and easier. You may set your browser to block cookies and local storage devices, but if you do so, you may not be able to access all of the features of the Services. This table shows fully the cookie functions and why they are used, although our uses may change over time and it is important that you revisit this page to understand these uses:
|Cookie Functions ||Cookie Purposes |
|Analytics and research ||We use the information collected by Google Analytics to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. |
|Authentication ||These cookies help us to identify our members so that when you’re logged in, you can enjoy all of the features without having to continually log in – our website “remembers” you and allows you full access without the need to keep entering your log in details. |
|Performance ||We need to use certain cookies and local storage devices to ensure our members have the best possible experience, such assisting with your navigation of our site, ensuring pages load up quickly and respond faster to your requests for our Services. |
For further information about cookies visit: www.aboutcookies.org
10. OUR RIGHTS TO AMEND THIS POLICY
11. LINKS TO OTHER THIRD PARTY WEBSITES
Our websites, apps, and promotional materials, may, from time to time, contain links to and from the websites of our third party networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
12. ADDITIONAL PRIVACY PROTECTIONS FOR CHILDREN USING THE INTERNET
We do not solicit or target persons younger than legal age for collection of information online. Our Site does not permit children under the age of 18 to become users and we do not accept any information from children. By submitting information to us you represent that you are over the age of 18. We encourage minors to seek the consent of their parents before providing any information about themselves or their households to anyone on the Internet. We encourage parents to take an active role to protect the privacy and security of their children and to prevent the inappropriate use of information about their children. We support the development of technologies that help parents to control the collection and use of personal information from children who use online services in their households.