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PRIVACY POLICY

Last Revised: April 20, 2020

This Privacy Policy: (i) identifies how we MM use the Personal Data (defined below) you provide us and (ii) informs you of what choices and rights you have with respect to our use of your Personal Data. Please contact us with any questions you have about this Privacy Policy at the e-mail address in the Contact Us section below. Capitalized terms not defined in this Privacy Policy have the meaning stated in the End User Service Agreement.

· 1.PERSONAL DATA WE COLLECT

· 2.HOW WE USE YOUR PERSONAL DATA

· 3.CATEGORIES AND PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

· 4.COOKIES

· 5.WHO WE SHARE YOUR DATA WITH

· 6.OUR COMMITMENT TO DATA SECURITY

· 7.YOUR CHOICES

· 8.LIMITATION OF LIABILITY

· 9.YOUR RIGHTS

· 10.ADDITIONAL INFORMATION ABOUT YOUR RIGHTS

· 11.DATA RETENTION

· 12.NOTICE TO CERTAIN INTERNATIONAL MEMBERS

· 13.CALIFORNIA PRIVACY RIGHTS

· 14.OTHER SITES LINKED TO SERVICES

· 15.QUESTIONS OR CONCERNS

· 16.UPDATES

· 17.DOWNLOAD A COPY OF OUR PRIVACY POLICY.

· 18.CONTACT US

1. PERSONAL DATA WE COLLECT

1.1 Personal Data. 'Personal Data' is information that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. We collect Personal Data from you when you register or create an Account; purchase merchandise; request information from us; sign up for e-mails or otherwise communicate with us or use the Services. We may also collect Personal Data you provide by interacting with us through social media or other forums[, from government entities that make information publicly available, and from other third-party services and organizations]. The categories of Personal Data we have collected during the past 12 months are described in the 'Categories and Purposes for Which We Will Use Your Personal Data' section below.

1.2 Aggregated Data. We also collect, use and share aggregated data such as statistical or demographic data for any purpose ('Aggregated Data'). Aggregated Data may be derived from your Personal Data but is not considered Personal Data by law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Service feature. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.

1.3 Special Categories. We collect Special Categories of Personal Data about you (which may include details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, and information about your health).

2. HOW WE USE YOUR PERSONAL DATA

We use Personal Data collected from or about you:

(a) To manage your Account;

(b) To provide you with our Services, including customer services;

(c) To maintain our Services (including security, troubleshooting, testing, system maintenance, support, reporting, hosting of data, and blocking users);

(d) To improve our Services, including your match experience such as mutual match, recommendations, reverse match, etc.;

(e) To contact you, including sending marketing, advertising, information and updates relating to our Services, responses to questions or requests and/or for the provision of customer services;

(f) To use data analytics to improve user relationships and experiences; and

(g) To monitor the use of our Services and prevent blocked users from accessing the Services or the information of other users.

3. CATEGORIES AND PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

3.1 Data Categories

(i) Account Data, including identifiers such as your phone number, username, and password.

(ii) Contact Data, including billing address, and identifiers such as email address and telephone numbers.

(iii) Payment Data, including payment card/account details, account verification data and commercial information such as transaction data.

(iv) Technical Data, including internet protocol (IP) address, and internet or other electronic network activity information such as your login data, device IDs, browser type and version, time zone setting and geolocation data, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Service.

(v) Profile Data, including identifiers such as your first name, last name, marital status, age, gender, other information and preferences you decide to add to your profile, including financial data and Special Categories of Personal Data, blog posts, audio, electronic, or visual information such as photos used in connection with your Account, education information, professional or employment-related information, government-issued identification, and any other information you provide in relation to specific Services you request, such as Certified Millionaires and photograph verification. Profile Data also includes inferences based on the information described above and other information described in this Privacy Policy.

3.2 Purpose for use.

We use your Personal Data for the following business purposes:

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

Please note that we may process your Personal Data without your knowledge or consent where this is required by law.

4. COOKIES

We may use a variety of technologies such as cookies, web beacons, embedded scripts, or other technologies to collect data about visits to and the users of our Service and interactions with our e-mails and online and mobile advertisements, to allow us to keep track of analytics and certain statistical information.

Some mobile and web browsers transmit 'do-not-track' signals. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. We currently do not take action in response to these signals.

5. WHO WE SHARE YOUR DATA WITH

We share the categories of Personal Data described above as follows:

(a) Service Providers. We may share your information with third-party service providers for business purposes, including those that provide business, professional, or technical support functions that make products and our Services available to you. We may also share information about you with your financial service provider in order to verify and make transactions and refunds and for fraud detection and prevention purposes.

(b) Third Parties. We do not share Personal Data with third-parties for their direct marketing purposes without your permission. If you access third-party services—such as social media services, third-party single-sign on tools, or mobile platforms for in-app purchases—through our Services, these third-party services may be able to collect information about you, including information about your activity on the Services, and they may notify your connections on the third-party services about your use of the Services, in accordance with their own privacy policies. Finally, our Services consist of making your profile data available to other users of our Services in order to find Matches at your direction.

(c) Legal Matters; Safety. We may access and disclose your information to respond to subpoenas, judicial processes, or government requests and investigations, or regarding an investigation on matters related to public safety, as permitted by law, or otherwise as required by law. We may disclose your information to protect the security of our Service including our servers, network systems, and databases. We also may disclose your information as necessary, if we believe that there has been a violation of our Agreement, any other legal document or contract related to our Service, or the rights of any third party.

(d) Transfer of Business or Assets. We may transfer assets in connection with a corporate transaction such as a merger or bankruptcy. If another entity acquires us or any of our assets, the information we have collected about you may be transferred to such entity. In addition, if any bankruptcy or reorganization proceeding is brought by or against us, such information may be considered an asset of ours and may be transferred to third parties.

(e) Marketing Statistics and Analytics. We may share Aggregate Data, anonymous, or de-identified data with third parties for their marketing or analytics uses.

(f) Our Affiliates. We may share information with our affiliated dating websites, subject to the limitations set forth in our Service Agreement or on those dating websites.

6. OUR COMMITMENT TO DATA SECURITY

To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect online. We regularly monitor our systems for possible attacks and vulnerabilities, but we can’t warrant the security of the data you send us even with the safeguards we have put in place.

We maintain (and requires our subcontractors and service providers to maintain) appropriate organizational and technical measures designed to protect the security and confidentiality of any information we process. However, no organizational or technical measures are 100% secure so you should take care when disclosing information online and act reasonably to protect yourself online.

7. YOUR CHOICES

You have the following choices regarding your Personal Data. To protect your privacy and security, we may take reasonable steps to verify your identity before any request for access or alteration of your Personal Data.

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(a) How You Can Access or Correct Your Information. You can access a variety of your Personal Data that we collect online and maintain it either online, or by contacting our customer service representatives via the e-mail address in the Contact Us section below. We use this procedure to better safeguard your information. You can correct factual errors in your Personal Data by sending us a request that credibly shows the error.

(b) How You Can Cancel Your Account. You can ask us to cancel your Account at any time using the 'cancel account' feature. When you ask us to cancel your account, we will remove it from our Service and it will no longer be viewable by other users or the public. Upon Account cancellation, you will be able to reactivate your account within two years, after which your Personal Data will be destroyed and/or anonymized.

(c) How You Can Request for Your Information To Be Deleted. You can ask us to delete your Personal Data at any time using the 'delete my account and data' feature (provided it is no longer necessary for legal purposes or to provide Services to you). You may also place a request by contacting our privacy team via e-mail at the e-mail address in the Contact Us section below. We will delete and/or anonymize all your Personal Data we are not legally required to maintain within 30 days. IF YOU REQUEST YOUR PERSONAL DATA BE DELETED, ANY OUTSTANDING ORDER OR TRANSACTION WILL BE IRREVOCABLY TERMINATED AND YOU WILL NOT BE ABLE TO RESTORE YOUR ACCOUNT OR RETRIEVE YOUR PERSONAL DATA UPON DELETION.

(d) Opting out

(i) E-mail. Any subscription to various marketing e-mails can be cancelled by clicking the 'unsubscribe' links in the e-mails, changing preferences in the 'Your Account' area online, or sending a request to the e-mail address in the Contact Us section below.

(ii) Geolocation data. You can disable our collection of geolocation data by changing the settings on your device.

(iii) Cookies. You may disable or delete cookies as explained in our cookie policy.

8. INTERNATIONAL TRANSFERS OF INFORMATION

For users in the European Economic Area ('EEA'), Personal Data collected in the EEA may be transferred, stored and processed by us and our service providers in the United States and other countries whose data protection laws may be different than the laws of your country. These transfers are required to provide our Services and to perform the agreement with you.

Please contact us at the e-mail address in the Contact Us section below if you want further information on the specific mechanism used by us when transferring your Personal Data out of the EEA.

9. YOUR RIGHTS

You have the following rights under data protection laws. To protect your privacy and security, we may take reasonable steps to verify your identity before any exercise of the following rights according to applicable law.

(a) Request access to your Personal Data (commonly known as a 'data subject access request'). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.

(b) Request correction of your Personal Data. Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

(c) Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

(d) Object to processing of your Personal Data. Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

(e) Request restriction of processing your Personal Data. Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (i) if you want us to establish the data’s accuracy; (ii) where our use of the data is unlawful but you do not want us to erase it; (iii) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

(f) Request transfer of your Personal Data. Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

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(g) Right to withdraw consent. Withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain features of our Services to you. We will advise you if this is the case at the time you withdraw your consent.

(h) Right to data portability. You may request us to transmit certain data we have about you (collected based on your consent or in order to provide you with our Service) to another data controller in a structured, commonly used and machine-readable format (so long as this is technically feasible).

If you wish to exercise any of the rights set out above, please contact us at the e-mail address in the Contact Us section below.

10. ADDITIONAL INFORMATION ABOUT YOUR RIGHTS

(a) No fee usually required. You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

(b) What we may need from you. We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

(c) Time limit to respond. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

11. DATA RETENTION

We will only retain your Personal Data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, audit, reporting and/or corporate compliance requirements.

To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

12. NOTICE TO CERTAIN INTERNATIONAL MEMBERS

If you are a citizen of Canada, Brazil or Mexico and have questions about the accuracy of information that we have collected about you, you can have access to that information in order to verify and update it, unless we are permitted or required under applicable laws to refuse your access to such information. You may write or email us the e-mail address in the Contact Us section below

13. CALIFORNIA PRIVACY RIGHTS

Section 1798.83 of the California Civil Code entitles residents of California to request a notice detailing the categories of Personal Data that we have shared with third parties for direct marketing purposes during the preceding calendar year, as well as the identity of those third parties. To request a copy of your Personal Data maintained by us, please contact us as at the e-mail address in the Contact Us section below.

California residents may also request access to, deletion, and portability of their Personal Data in accordance with applicable law by contacting us at the email address in the Contact Us section below. We will not discriminate against you for exercising your rights, although some of the functionality and features on the Services may change or no longer be available to you. Any differences in the Services are related to the value provided.

Once we receive your request, we may verify it by requesting information sufficient to confirm your identity. If you would like to use an authorized agent registered with the California Secretary of State to exercise your rights, we may request evidence that you have provided such agent with power of attorney or that the agent otherwise has valid written authority to exercise rights on your behalf.

We do not sell your Personal Data to third parties. We do disclose Personal Data for business purposes, including but not limited to services performed on our behalf, to provide advertising on our Service and elsewhere based on users’ online activities over time and across different sites, services, and devices (so-called 'interest-based advertising'), and to protect against fraud and malicious activity. In addition, your information may be accessible to third parties with whom you interact or direct us to share your information through our Services. The information practices of these third parties are not covered by this Privacy Policy.

14. OTHER SITES LINKED TO SERVICES

Our Service may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the privacy policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

15. QUESTIONS OR CONCERNS

For users in the EEA, any questions or concerns regarding the use or disclosure of Personal Data should first be directed to us via the email address provided in the Contact Us section below. We will promptly investigate and attempt to resolve all complaints regarding our use of Personal Data. In the event we are unable to mutually resolve a complaint; we will work with you and agree to refer your complaint to an independent dispute resolution mechanism. You may also work with the Data Protection Authority in your country http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm to assist with this process as well.

16. UPDATES

This Privacy Policy was last updated on the date identified above and we accordingly reserve the right to change or modify this policy at any time without prior notice, and we may apply any change in the Privacy Policy to information previously collected, as permitted by law. Please review our Privacy Policy before you provide any Personal Data and periodically on an ongoing basis. When we make material changes to this Privacy Policy, we will notify you by posting the updated Privacy Policy on our Service noting the 'Last Revised' date at the top of the Privacy Policy. Your continued use of our Service after any changes or revisions to this Privacy Policy become effective shall indicate your consent to the then-current Privacy Policy.

17. DOWNLOAD A COPY OF OUR PRIVACY POLICY.

You can download a PDF version of our Privacy Policy here: https://www.classydatingapp.com/privacy.html

18. CONTACT US

If there are any questions regarding this Privacy Policy, you may contact us via e-mail at [email protected].

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