We are committed to safeguarding the privacy of our service users.
This policy applies where we are acting as a data controller with respect to the personal data of our service users; in other words, where we determine the purposes and means of the processing of that personal data.
Your use of our service manifests your consent to transmission of personal data specified in this policy.
How we use your personal data
We may process data about your use of our service (“usage data”). The usage data may include your IP address, geographical location (limited to country and state), browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analyzing the use of our service. The legal basis for this processing is your consent in the form of use of our service as stated in Section 1, and our legitimate interests, namely monitoring and improving our service.
We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data”). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you.
We may process information relating to our customer relationships, including customer contact information (“customer relationship data”). The customer relationship data may include your name, your contact details, and information contained in communications between us and you. The source of the customer relationship data is you. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. We need this kind of data for the proper management of our customer relationships.
We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters.
We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our service may generate the metadata associated with communications made using the service contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. We need this kind of data for the proper administration of our service and communications with users.
We may process information about your client application (web browser or mobile application) and its environment (operating system and hardware) used to access our service (“client data”). The client data may include your IP address, browser type and version, browser capabilities, operating system type and version, hardware setup, imei/esn code, device manufacturer, serial number and model name. We need this kind of data for the proper administration of our service.
We may process information that you send in text messages through our service (“message data”). The message data may be processed for the purposes of enabling such transfer and administering our service. We need this kind of data for the proper administration of our service, monitoring and improving our service.
We may process information about your communication with other users in our service (“communication data”). The communication data may include client and usage data for both sides, the time and date of communication happened and it’s length. We need this kind of data for the proper administration of our service, monitoring and improving our service.
We may process information about your ban (“ban data”) in case you have been banned because of inappropriate behaviour. The ban data may include different elements of usage data and client data necessary to block the user from using our service for a determined period, but also an image of the video frame obtained from a user’s video source. This image can be collected along with a complaint from another user (interlocutor) or when inappropriate behavior is detected by our system based on behavioral factors (how often interlocutors break off the connection, average duration of chat sessions, dubious message patterns, etc.). We need this kind of data for the proper administration of our service.
We may process complaint information (“complaint data”) if another user of our service complains about you. The complaint data may inlude an image of the video frame obtained from your video source. We need this kind of data for the proper administration of our service.
We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our service (“transaction data”). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. We need this kind of data for the proper administration of our service.
Like many site operators, we may process information that your browser sends whenever you visit our site (“log data”). The log data may include your IP address, browser type and version, the pages of our site that you visit, the time and date of your visit, the time spent on those pages and other statistics. The log data collected does not include personally identifiable information. We need this kind of data for the proper administration of our service, statistical analysis and understanding of user behavior.
We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. We need this kind of data for the protection and assertion of our legal rights, your legal rights and the legal rights of others.
We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. We need this kind of data for the proper protection of our business against risks.
In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
Please do not supply any other person’s personal data to us, unless we prompt you to do so.
Providing your personal data to others
We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
Financial transactions relating to our service may be handled by our payment services providers, PayPal, Apple, Google, Interkassa, SecurionPay, SMSBILL, VK. We will share transaction data with our payment service providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.
In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
Our service may require a direct connection to be made between your computer and the other user’s computer. To do this, it is necessary to make your IP address available to the other user’s computer, although it is not shown to the other user by service’s interface. This is a necessary part of how any peer-to-peer system functions.
International transfers of your personal data
The hosting facilities for our service are situated in The UK.
Users of our service are located in multiple countries, including the European Economic Area. We have developed data practices designed to assure information is appropriately protected but we ask you to be aware of the privacy and data protection laws in the jurisdiction in which you reside. As otherwise stated in this policy, you acknowledge that, the ultimate responsibility for the information you choose to share is yours.
You acknowledge that personal data that you submit for publication through our service may be available, via the Internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
Retaining and deleting personal data
Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
We will retain your profile data as long as your account is active, and we have not been notified otherwise, or as long as we consider necessary for the purposes described in this policy.
We will not retain your complete message data (message log). We store none outgoing or incoming messages, and these data cannot be retrieved or restored. We will retain specific messages in ban data for bans related to inappropriate behavior in the text chat.
We will retain your ban data as long as it is necessary to maintain the ban technically for a determined period. We will not keep user image after ban expiration, but will retain a record about this specific ban.
We will not retain your communication data. We store none information related to with whom and when you communicated, and such information cannot be retrieved or restored.
Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
How we protect your personal data
We employ proper technical and physical measures to protect the personal data of our users from loss, destruction, change, unauthorized access, disclosure, or any other illegal forms of processing.
We employ a modern means of protection for the personal data of all users according to the current state of the industry. This includes, for example, firewalls, password protection and other access and authentication controls.
We use a secure server software (SSL) to encrypt user data before it is sent to us, and our database is hosted in a secure data center.
Only authorized personnel have access to user data.
However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We cannot ensure or warrant the security of any information you transmit to us or store on our service, and you do so at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. If you believe your personal data has been compromised, please contact us as provided below.
Children’s online privacy
Protecting the privacy of young children is especially important. Our service is not intended for children or minors under the age of 18 years. We do not knowingly collect data from children under 18 years of age and do not wish to do so.
By using our service, you represent that you are at least 18 years of age. If you are under 18 years of age, then please do not use or access our service at any time or in any manner. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate your profile and take reasonable measures to promptly delete such data from our records.
If you become aware of any data we have collected from children under age 18, please contact us as provided below.
A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
Cookies that we use
Cookies used by our service providers
Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version.
Blocking all cookies will have a negative impact upon the usability of many websites.
If you block cookies, you will not be able to use all the features on our website.
We reserve the right to place external links to websites and third party goods throughout our service.
We attempt to always provide links and URLs to respected websites, however, we do not accept responsibility for any contents, security, or actions taken on such websites.
Do Not Track mechanisms
Your browser may deliver a “Do-Not-Track (‘DNT’) signal,” or similar mechanism for exercising choices about the collection of information about your online activities. Because technology continues to change, we do not guarantee that we will honor DNT signals or similar mechanisms at this time.
We may update this policy from time to time by publishing a new version on our website.
You should check this page occasionally to ensure you are happy with any changes to this policy.
If you have any questions about this policy, please contact us by firstname.lastname@example.org.