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PRIVACY POLICY

Welcome to the Friends Privacy Policy (“Policy”). This explains how we collect, store, protect, and share your information, and with whom we share it. While you’re using the Friends mobile application (“App”), we are collecting some information about you. In addition, you may choose to use the App to share information with other users, including your friends and contacts (“Users”). We may also need to share your information sometimes. The App is operated by the “Friends” (also referred to in this policy as “we” or “us”) which includes Choice Marriage LLC which is controller of personal information collected and processed through the Friends App.

 

1. COLLECTION OF INFORMATION.

Registration Information

When you download the App and create an account (“Account”), we may collect certain information (“Registration Information”) about you, such as:

  • Name;

  • Username;

  • Email address;

  • Mobile number;

  • Gender identity;

  • Date of birth;

  • Sexual preference;

  • Photographs;

  • Location;

Once you register, you will be able to review and change this information at any time just by logging in to Friends (other than your date of birth and location (which, if you have given Friends App access to your location in your device settings, is automatically updated based on the location of your device). It is your responsibility to ensure that your account details are kept up to date. If your phone number changes, please ensure that you update this in your account. The information we collect helps to enhance the App and verify our Users (robots are not welcome!). Registration Information such as your sexual preference, name and username may be visible to other Users who view your profile page.

 

Profile Information

We recommend and encourage you (and all our members) to think carefully about the information you disclose about yourself. We also do not recommend that you put email addresses, URLs, instant messaging details, phone numbers, full names or addresses, credit card details, national identity numbers, drivers’ license details and other sensitive information which is open to abuse and misuse on your profile.

When you post information about yourself or use the messaging function to communicate with other Users, the amount of personal information you share is at your own risk.

Profile Verification Information (Including Biometric Information)

For safety and security and to ensure you have the best possible user experience, we require Users to verify their accounts and might ask for your phone number and, in some instances, we might also ask that you carry out photo verification. We want to make sure you are not a robot! And we also want to avoid fake accounts being created which can be used for malicious activities and cybercrime – they threaten the network and spoil things for everyone. This verification might be required by us for the prevention of fraud. You can also verify your photo on a voluntary basis (to add the blue ‘verified’ badge to your profile).

If you choose to verify your profile photo, we will scan each photo that you submit. The scan may include the use of facial recognition technology so that we can compare the photo you submit to your profile photo, to help ensure that you are who you say you are. We do not add the verification photos to your profile. We retain the scans so that we can verify you in the future and for our record-keeping purposes until we no longer need them for such purposes or for three years after your last interaction with us, whichever occurs first. After the applicable retention period expires, we take commercially reasonable steps to permanently and securely delete the scans from our systems.

 

Purchases Information

If you decide to purchase any of our premium services, we will process your payment information and retain this securely for the prevention of fraud and for audit/tax purposes.

Friends uses automated decisions to prevent fraudulent payment transactions being processed as part of its anti-fraud procedures. In order to do this, our systems check payment transactions for behavior that indicates breaches of our Terms and Conditions of Use. If a transaction meets certain criteria that demonstrate that the Terms and Conditions of Use are likely to have been breached and the transaction is likely to be fraudulent, the relevant transaction may automatically be blocked. Where a transaction is blocked, the user will be notified that their transaction cannot be processed and affected Users can contact Friends to contest the decision.

 

Geolocation Information

If you have given Friends access to your location in App we will collect information about WiFi access points as well as other location information about your longitude and latitude and may save your device’s coordinates to offer certain features to you. This information helps us identify your physical location and we use it to personalize the App and make it easier for you to interact with other Users, by enabling the general locality information to be displayed to Users seeing your profile and showing you the profiles of other Users who are near you.

If you have given Friends access to your location, but wish to turn this off, you can do so by the following methods:

  1. iPhone app — settings, privacy, location services

  2. Android — settings, location, permissions, location

 

Device Information

We may collect information about your device when you use the App including the unique device identifier, device model, and operating system, for a number of purposes, as set out in this policy. In addition, if you permit us to do so, the App may access your device’s address book solely in order to add someone to your contacts.

 

2. USE OF YOUR INFORMATION.

When you use our services, we collect technical information about which features you used, how you used them, and which devices you used to access our services. More on this below:

  • Usage data. When you use the services, data is recorded about your use of our services: how you use them (date and time you logged in, features you use, activities, information shown to you, addresses of pages you came from, advertisements clicked) and how you communicate with other users (for example, the users you contact and interact with, the time and date of the contact, the number of messages you receive and send).

  • Device Information. We collect information about the devices you use to access our services, including hardware and software information such as IP address, device ID and type, application settings and characteristics, application crashes, advertising identifiers (randomly generated numbers that you can reset in your device settings), identifiers associated with cookies or other technologies that can uniquely identify a device or browser.

  • Other information provided with your consent. With your permission, we may determine your exact location (latitude and longitude). Location data collection may occur in the background even when you are not using the services, if you have given us permission to collect this information. If you do not give us permission to collect information about your exact location, we will not collect this information. With your consent, we may also collect your photos and videos (for example, after you post a photo, video or live stream on one of our services).

 

3. HOW WE USE YOUR INFORMATION

The primary reason we use your information is to provide and improve our services. In addition, we use your information for security purposes and to serve ads that may be of interest to you. In the following, we will detail the reasons why we use your information, as well as provide examples.

1) To manage your account and provide our services

  • Create and manage your account

  • Provide you with customer support and respond to your inquiries

  • Conduct your transactions

  • Communicate with you about your use of the Services

2) To show your profile to other users

  • Recommend you to other users

  • Show user profiles to each other

3)To manage advertising and marketing campaigns

  • Organize sweepstakes and contests, provide discounts or other offers

  • Run and measure the effectiveness of advertising campaigns on our

  • Tell you about products or services that we think you might be interested in

4) To improve our services and develop new

  • Manage focus groups, market research and surveys

  • Study interaction with the help desk to improve the quality of service

  • Analyze user behavior in the services to improve them

  • Develop new features and services

5) To prevent, detect and combat fraud and other illegal or unauthorized activities

  • Detect or respond to current or suspected violations of our Terms of Use through complaints investigation and user communication

  • Learn more and develop measures to counter violations of our Terms of Use

  • Store data related to violations of our Terms of Use to prevent recurrence

  • Report the results to users who have filed complaints

6) To ensure legal compliance

  • Comply with legal requirements

  • Help law enforcement

 

Sharing your personal data with Marketing Services Providers

We can use your data in App and measure the effectiveness of our advertising campaigns. For example:

  • to exclude you from advertising campaigns aimed at finding new users, if you already have a Friends account;

  • to show Friends adverts to users who have visited the Friends App but haven’t yet created a Friends account;

  • to create an audience for our advertisements of other potential users who have similar characteristics to you based on the information the Marketing Service Providers holds about you (also known as a Lookalike Audience);

  • to include you in a ‘custom audience’ that will receive Friends advertising content (a custom audience is essentially a list of people who we think are most likely to be interested in a particular advertisement).

We share a limited amount of your personal data with these Marketing Services Providers, such as:

  • the advertising identifier associated with your device (this is a random number assigned by your mobile device manufacturer (for example Apple or Google) to your device to help advertisers (including the manufacturer) know when an ad has been viewed or clicked in an App, and when an ad causes a ‘conversion’ (downloading the App advertised to you)

  • your estimated location (based on your IP address)

  • age and gender

  • data about your visit to our App and action taken on those (for example if you downloaded our App or created an account with our App)

Some platforms require user consent before Friends App is permitted to use data gained through the platform for advertising purposes and where this is the case, Friends will only use this data where the necessary consent has been obtained. Through your device’s privacy settings, you also have the option to prevent or limit device identifiers being shared with third party advertisers and what use is made of the device identifiers.

 

In some cases, the App will also use the data that it collects for its own purposes, for example it may aggregate your data with other data it holds and uses this to inform advertising related services provided to other clients.

 

4. WHAT OTHERS MAY SEE ABOUT YOU.

We think our Users are wonderful, and we want you to share how wonderful you are with the world, so we have built certain features to enable this. Our App is designed to make it easier for you to connect with other Users.

When using the Friends App, you should assume that anything you post or submit on the App may be publicly-viewable and accessible, both by Users and non-users of the App. We want our Users to be careful about posting information that may eventually be made public.

Please be careful about posting sensitive details about yourself on your profile such as your religious denomination and health details. While you may voluntarily provide this information to us when you create your profile, including your sexual preferences, there is no requirement to do so. Please remember that photographs that you post on Friends may reveal information about yourself as well. Where you do upload and choose to tell us sensitive information about yourself, including through the addition of badges to your profile, you are explicitly consenting to our processing of this information and making it public to other Users.

Your Friends profile and other information you make available via the App, including certain information added to your profile through third party accounts (such as Facebook, Instagram or Spotify) may be viewed and shared by Users with individuals who may or may not be users of the App. For example, a User may recommend you as a match to his or her Facebook friend(s) by taking a screenshot of your profile picture and sharing it, regardless of whether such friend(s) is also a User of the App.

If you log in to or access the App through your Google account or another third-party account on a device which you share with others, remember to log out of the App and the relevant third-party account when you leave the device in order to prevent other users from accessing your Friends account.

 

5. OUR POLICY TOWARDS AGE

 We do not allow people under the age of 21 to use our platform.

 

6. SECURITY.

Friends takes all appropriate security measures to help protect your information against loss, misuse and unauthorised access, or disclosure. We use reasonable security measures to safeguard the confidentiality of your personal information such as secured servers using firewalls.

Unfortunately, no App is ever completely 100% secure and even we cannot guarantee that unauthorised access, hacking, data loss or other breaches will never occur, but here are some handy tips to help keep your data secure:

  1. Please make sure you log out of your Account after use as you never know who may stumble onto your Account.

  2. Please don’t share the password you use to access your Friends Account with anyone else.

  3. Change your password periodically.

 

7. YOUR RIGHTS.

Privacy laws applicable in your country may give you the following rights:

  1. Right to be informed: what personal data an organization is processing and why (we provide this information to you in this Privacy Policy).

  2. Right of access: you can request a copy of your data.

  3. Right of rectification: if the data held is inaccurate, you have the right to have it corrected.

  4. Right to erasure: you have the right to have your data deleted in certain circumstances.

  5. Right to restrict processing: in limited circumstances, you have the right to request that processing is stopped but the data retained.

  6. Right to data portability: you can request a copy of certain data in a machine-readable form that can be transferred to another provider.

  7. Right to object: in certain circumstances (including where data is processed on the basis of legitimate interests or for the purposes of marketing) you may object to that processing.

  8. Rights related to automated decision-making including profiling: there are several rights in this area where processing carried out on a solely automated basis results in a decision which has legal or significant effects for the individual. In these circumstances your rights include the right to ensure that there is human intervention in the decision-making process.

The particular rights which are applicable to you (which might include other rights not listed above) may vary depending on your country. You should make yourself aware of the rights you have under applicable privacy laws in your country.

If you have a concern about how we have processed your request or your personal data, you should contact us.

 

8. DATA RETENTION AND DELETION.

When you delete your Account, or it is deactivated by us, we make sure it is no longer viewable in the App. For up to 28 days, it is still possible to restore your Account if it was accidentally deleted or wrongfully deactivated. After 28 days, we begin the process of deleting your personal information from our systems, unless:

  1. We must keep it to comply with applicable law ( if you make purchases within the App, some personal data may be kept for tax and accounting purposes);

  2. We must keep it to evidence our compliance with applicable law (for example, if an account is blocked, we keep some account information and a record of the behaviour that led to the block - this information is retained for evidential purposes in case of queries or legal claims concerning the block);

  3. there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved;

  4. The information must be kept for our legitimate business interests, such as fraud prevention and enhancing Users’ safety and security (for example, information may need to be kept to prevent a user who was banned for unsafe behaviour or security incidents from opening a new account).

Warning: Even after you remove information from your profile or delete your Account, copies of that information may still be viewable and/or accessed to the extent such information has been previously shared with others, or copied or stored by others. 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.

5. Changes to the privacy policy

We are always looking for new and innovative ways to help you learn about and provide up-to-date information about our approach to data processing, so this policy may change over time. We will alert you before any major changes go into effect so you have time to review them.

 

If you have any questions, please contact us

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