Last Updated Date: Feb 04, 2019
This Privacy Policy is incorporated by reference into Kinkoo End User License Agreement and Terms of Use (the "EULA"). The term "KINKOO," "we," and "us" includes KINKY DATING APP LTD. and our affiliates and subsidiaries. The Privacy Policy applies to the processing of Personal Information we obtain through your use of the Service, and in connection with our customer, service provider and partner relationships. This Privacy Policy describes the types of Personal Information we collect, the purposes for which we collect that Personal Information, the other parties with whom we may share it and the measures we take to protect the security of the data. It also tells you about your rights and choices with respect to your Personal Information, and how you can reach us to update your contact information or get answers to questions you may have about our privacy practices. All other terms not defined herein will have the meanings set forth in the EULA.
1. PERSONAL INFORMATION WE MAY COLLECT
For the purpose of this Privacy Policy, "Personal Information" means any information relating to an identified or identifiable individual. We obtain Personal Information relating to you from various sources described below.
Where applicable, we indicate whether and why you must provide us with your Personal Information, as well as the consequences of failing to do so. If you do not provide Personal Information when requested, you may not be able to benefit from our Services if that information is necessary to provide you with the service or if we are legally required to collect it.
a. Personal Information Provided by You
Native Registration. We ask you to provide certain Personal Information when you register for an account through our websites or mobile application, such as your name, address, email address and phone number.
User Content. We collect information you post through the Service. For example, when you interact with other Users by sending them Messages, the Service will collect the information you provide in such submissions, to the extent permitted under applicable law.
Customer Support. We may collect information through your communications with our customer-support team or other communications that you may send us and their contents.
Making Payments. When you make payments through the Service, you may need to provide Personal Information to our third-party service providers, such as your credit card number.
Preferences. We ask you for information regarding dating preference categories available on the Service, which may include racial or ethnic origin, political opinions, religious or philosophical beliefs, sex life or sexual orientation.
b. Personal Information Obtained from Your Interactions with our Services
Cookies, Automatic Data Collection, and Related Technologies. When you use our Service, we may collect technical data and related information, including, but not limited to, device identifier and other technical information about your device, system and application software, and peripherals. The Service collects and stores information that is generated automatically as you use it, including your preferences and anonymous usage statistics.
When you visit the Service, we and our third-party service providers receive and record information on our server logs from your browser, including your IP address, and from cookies and similar technology. Cookies are small text files placed in visitors' computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Service may not work properly.
By using the Service, you are authorizing us to gather, parse, and retain data related to the provision of the Service.
Location Information from Your Mobile Device. We may collect and store your location information, including GPS coordinates, if you enable your mobile device to send it to us. Collection of this information may improve the provision of the Service.
Personal Information Obtained from Other Sources
Social Sign-On. We collect Personal Information about you when you log into the Services via a Social Network. For example, when you log in using your Facebook credentials, we collect the information that you have made publicly available in Facebook, such as your name, location, email address and profile picture. We will also collect other information you have authorized your Social Networks to share with us, such as your education, profession, hometown, gender, age, events, and public friends or connections lists.
2. HOW WE MAY USE YOUR PERSONAL INFORMATION
We may use the Personal Information we obtain about you to:
create and manage your account, provide our Service, process payments, and respond to your inquiries;
communicate with you to verify your account and for informational and operational purposes, such as account management, customer service, or system maintenance, including by periodically emailing you service-related announcements;
tailor our service (e.g., we may use cookies and similar technologies to remember your preferences).
provide online advertising on the Service and to facilitate transmittal of information that may be useful, relevant, valuable or otherwise of interest to you;
analyze your interactions with our Service and third parties' online services, including to provide tailored advertising;
aggregate your Personal Information for analytical purposes;
anonymize your Personal Information;
operate, evaluate and improve our business (including by developing new products and services; managing our communications; determining the effectiveness of our advertising; analyzing how the Service is being accessed and used; tracking performance of the Service; facilitating the use of our Service);
send you marketing communications about products, services, offers, programs and promotions of KINKOO, and affiliated companies;
ensure the security of our Service;
manage our service provider or partner relationships;
enforce our agreements related to our Service and our other legal rights;
comply with applicable legal requirements, industry standards and our policies; and
perform auditing, research and analysis in order to maintain, protect and improve our Service.
We may process your Personal Information for the above purposes when:
you have consented to the use of your Personal Information;
we need your Personal Information to provide you with services and products requested by you, or to respond to your inquiries;
we have a legal obligation to use your Personal Information; or
we or a third party, have a legitimate interest in using your Personal Information. In particular, we have a legitimate interest in using your Personal Information to ensure and improve the safety, security, and performance of our Service.
3. HOW WE SHARE YOUR PERSONAL INFORMATION
We do not sell or otherwise disclose Personal Information we collect about you, except as described in this Privacy Policy or otherwise disclosed to you at the time the data is collected.
Vendors and Service Providers. We may share any information we receive with vendors and service providers who perform services on our behalf and in relation to the purposes described in this Privacy Policy. Also, we use third-party content moderators to monitor activity on the site/apps and approve content generated by you including your profile information. For example, we may use third parties to help us provide customer support, assist with data storage, etc. We require these vendors and service providers by contract to only process Personal Information in accordance with our instructions and as necessary to perform services on our behalf or comply with legal requirements.
Displaying to Other Users. Your Profile will be displayed to other Users; provided, however, that we will use commercially reasonable efforts to not display your Profile to (1) Users with whom you are currently "friends" or "connected to" on Facebook, as applicable and (2) Users who have identified the same current employer as you on a Social Network. We are not responsible for privacy practices of the other Users who will view and use the posted information.
Inviting Friends. The Service may allow you to share information with social networking websites when you invite friends to use the Service. We do not share your information with them unless you direct the Service to share it. Their use of the information will be governed by their privacy policies, and you may be able to modify your privacy settings on their websites. You may also invite friends to use the Service by sending them a text message. We will not collect the phone numbers of any person you invite to use the Service through text message.
Marketing. We do not rent, sell, or share information about you with other people or non-affiliated companies for their direct marketing purposes, unless we have your permission. To the extent permitted under applicable law, we may allow third parties to access data that is automatically collected by the Service to enable the delivery of online advertising on this website, or otherwise facilitate transmittal of information that may be useful, relevant, valuable or otherwise of interest to you.
As Required By Law and Similar Disclosures. We may access, preserve, and disclose your Personal Information and/or other account information or content if we believe doing so is required or appropriate to: (i) comply with law enforcement requests and legal process, such as a court order or subpoena; (ii) enforce this Privacy Policy, our EULA, or other agreements; (iii) respond to your requests; or (iv) protect your, our or others' rights, property, or safety.
Affiliates and Business Partners. We may share the Personal Information we collect with our affiliated companies and business partners to whom it is reasonably necessary or desirable for us to disclose your Personal Information.
Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of assets, or transition of service to another provider, then your Personal Information may be sold or transferred as part of such a transaction as permitted by law and/or contract. The use of your Personal Information following any of the foregoing events will be governed by the provisions of the Privacy Policy in effect at the time Company collected such information.
With Your Consent. We may also otherwise disclose your Personal Information with your permission.
4. MATCHING
In order to match you more effectively, we may use your Personal Information and preferences to perform automated analyses, identify correlations, and make predictions about your interests. This may include the use of dating preference Personal Information and may affect your match results on the Service. For example, your preference for someone with the same kinks may match you with someone with the same political belief looking for someone with your education level. Similarly, you and others may be excluded as a match based on your profile.
5. YOUR RIGHTS AND CHOICES
Account Information. Through your account settings, you can update some of your Personal Information, such as your name, photo, and email address. You can also contact us at support@kinkoo.app to update your information.
Location Information. You can prevent us from collecting location information from your device by changing the settings on your device; however, if you do not provide us with location information you may not be able to fully use the Service.
Marketing Opt-out. You can unsubscribe from promotional emails from us via the unsubscribe link provided in the email. Even if you opt out from receiving promotional messages from us, you will continue to receive administrative messages from us.
Other Rights. In certain jurisdictions you have the right to request access and receive information about the Personal Information we maintain about you, to update and correct inaccuracies in your Personal Information, to restrict or object to the processing of your Personal Information, to have the information blocked, anonymized or deleted, as appropriate, or to exercise your right to data portability to easily transfer your Personal Information to another company. Those rights may be limited in some circumstances by local law requirements. In addition to the above-mentioned rights, you also have the right to lodge a complaint with a competent supervisory authority subject to applicable law.
Where required by law, we obtain your consent for the processing of certain Personal Information collected by cookies or similar technologies, or used to send you direct marketing communications, to collect your location information or when we carry out other processing activities for which consent may be required. If we rely on consent for the processing of your Personal Information, you have the right to withdraw it at any time and free of charge. When you do so, this will not affect the lawfulness of the processing before your consent withdrawal.
To update your preferences, ask us to remove your information from our mailing lists, delete your account or submit a request to exercise your rights under applicable law, please contact us as specified in the "Contact Us" section below.
6. HOW WE PROTECT YOUR PERSONAL INFORMATION
We take steps to ensure that your Personal Information is treated securely and in accordance with this Privacy Policy. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any Personal Information you provide to us, subject to requirements under applicable law to ensure or warrant information security. We maintain administrative, technical and physical safeguards that are intended to appropriately protect Personal Information against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the Personal Information in our possession. In particular, KINKOO uses security methods and procedures designed to safeguard Personal Information during transmission and storage.
We also take measures to delete your Personal Information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it in the context of the Service or when you request their deletion, unless we are required by law to keep the information for a longer period. We complete periodic reviews of our databases, and have established specific time limits for data deletion, taking into account the type of services provided in the context of the Services, the length of our relationship with you, mandatory retention periods and the statute of limitations.
7. DATA TRANSFERS & INTERNATIONAL USERS
KINKOO is based in the UK. Personal Information that we collect may be transferred to, and stored at, any of our affiliates, partners or service providers which may be inside or outside the European Economic Area ("EEA") and Switzerland, including the United States. By submitting your personal data, you agree to this transfer, storing or processing. Your Personal Information may be transferred to countries that do not have the same data protection laws as the country in which you initially provided the information. When we transfer or disclose your Personal Information to other countries, we will protect that information as described in this Privacy Policy.
8. DO NOT TRACK
Some web browsers incorporate a "Do Not Track" feature. Because there is not yet an accepted standard for how to respond to Do Not Track signals, our website does not currently respond to such signals. By using the Service or providing information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Service. If we learn of a security system's breach, we may attempt to notify you electronically by posting a notice on the Service or sending an email to you. You may have a legal right to receive this notice in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice), please notify us at support@kinkoo.app.
9. CHILDREN'S PRIVACY
We do not knowingly collect, maintain, or use Personal Information, as defined by the Federal Trade Commission's Children's Online Privacy Protection Act ("COPPA") Rule, from children under 13 years of age, and no part of the Service is directed to children under the age of 13. If you learn that your child has provided us with Personal Information without your consent, you may alert us at support@kinkoo.app. If we learn that we have collected any Personal Information from children under 13, then we will promptly take steps to delete such information and terminate the child's account.
10. UPDATES TO THIS PRIVACY POLICY
Posting of Revised Privacy Policy. We will post any adjustments to the Privacy Policy on this web page, and update the "Effective Date" above. If you are concerned about how your information is used, then bookmark this page and read this Privacy Policy periodically. Your continued use of the Service after changes to the Privacy Policy constitutes your acceptance of the new terms of the Privacy Policy.
New Uses of Information. From time-to-time, we may desire to use information for uses not previously disclosed in our Privacy Policy. If our practices change regarding previously collected information in a way that would be materially less restrictive than stated in the version of this Privacy Policy in effect at the time we collected the information, then we will make reasonable efforts to provide notice and obtain consent to any such uses as may be required by law.
11. HOW TO CONTACT US
If you have any questions or comments regarding this Privacy Policy, you may contact us by email at support@kinkoo.app.