Privacy Policy
PROMISE (hereinafter
“We” or “PROMISE”)
values the privacy of all of our users and has
established this Privacy Policy to show commitment to these rights and to safeguard
your privacy. If you use our application (“Application”) or services, then we
urge you to read this Privacy Policy and become fully informed about how it
affects to your personal privacy. Please refer to this Privacy Policy to find
out how to contact us if you have any questions about the contents herein. By
using our Application you consent to the contents of
this Privacy Policy.
Contents:
I.
Privacy Policy
II.
Types of personal data collected
III.
The use and share of the collected personal data
IV.
Age restriction
V.
The rights of access and opt-out
VI.
Mode and place of processing the personal data
VII.
Retention time and deletion of personal data
VIII.
Changes to this privacy policy
IX.
Data controller contact information
X.
Rights of EU users
XI.
Acceptance of this privacy policy
I. Privacy Policy
When
you visit any website or using an Application, you are providing a range of
personal information about your visit to the operators of the website or
Application, depending on the actions you take. This is also the case with PROMISE. You should
always understand the privacy policies on any website or Application when
supplying information during your use of the website or Application. You should
always ask for a copy of the privacy policy if the website does not make the
information available to you.
We
will only use the personal data you send to us during your visits for the
purposes of internal tracking. This includes the activities of making PROMISE and other our
websites more effective for you to use our Application’s features and services
and responding appropriately to your requests for information. Unless
specifically mentioned, we do not use your personal data for any other reason.
We will never sell your personal data to a third party, and we will never give
a third party access to your personal data, except as
may be provided in our Terms of Use Agreement or Privacy Policy or unless
required to do so by law.
II. Types of personal data
collected
Personal
data requests and user registration
When
you use or register on the PROMISE Application, we only collect personal data that you
provide of your own accord. By registering on our Application
you will provide and share your personal data with the public and with other
users. Something that is public can be seen by anyone. For example, the
personal data you provide in section “About Me”, your name, gender, username,
user ID, profile picture, photos and videos. This
personal data is made available to the public to help connect you with other
Application users. Please be advised that public personal data can show up when
someone does a search on PROMISE
Application. In some cases, people you share and communicate with may download
or copy the content you provided to them or make it public. Use caution about
the personal data you share with others.
Personal
data you provide us when you use our services or register for an account with
us:
· identifying personal data such as your gender, email and billing address when you
register for an account with us. It is your voluntary decision whether to
provide us with any such personal information, but if you refuse to provide
such information we may not be able to register you to
receive our services;
· other content that you generate, or that is
connected to your account (username, user ID, profile picture, photos and
videos, interests, favorites);
· you may also provide us other personal data through your participation in
user-to-user communications, chats, or when you otherwise communicate with us
regarding our services;
· additional personal data we are required or authorized by applicable laws to
collect and process in order to authenticate or identify you or to verify the
personal data we have collected.
Personal
data we collect automatically when you use our services or register for an account
with us:
· we
collect data about your interaction with our services and your communications
with us. This is personal data we receive from devices (including mobile
devices) you use when you access our services. This personal data could include
the following: device number, device ID or unique identifier, device type, and
unique device token, operating system and applications used, application
crash-data, IP address, User agent, platform, Software Development Kit version,
anonymous User ID, time stamp Developer Key, application version, device
identifiers such as: IDFA (Identifier For Advertisers), device model,
manufacture, OS version, in-app events, and network status (WiFi/3G),
Login source, application use, age, gender, if profile is linked to Facebook/Google,
number of photos in profile, interests, notification status, registration date,
credits bought, date of last payment and use of services;
·
location personal data, including location personal data from your mobile
device including specific geographic locations through IP, GPS, Bluetooth, or WiFi signals;
·
mobile phone or tablet and connection personal data such as statistics on your
page views, traffic to and from the websites, referral URL, ad data, your IP
address, your browsing history, and your web log personal data;
Personal
data we collect using cookies and similar technologies:
We
use cookie technology on PROMISE
as part of the statistical reporting on our website. It contains personal data
used by a website to personalize your experience (e.g.
rotating profiles) and to gather statistical data, such as which pages are
visited, what is downloaded during your experience, the domain name and country
of the internet provider that you have come from (e.g. ‘aol’,
or ‘umich.edu’), and addresses of those websites you have visited just before
and after PROMISE.
Nevertheless, we do not associate any of this personal data with you as an
individual. Only an aggregate measure is taken. Cookie personal data allows us
to follow your «click stream» activity (i.e., how visitors navigate our website
as they move from page to page). It is important to note that cookies never
capture your individual email address or any of your private personal data.
We
also operate standard server log files to assist in counting visitor numbers
and analyzing our website’s technical capability. This personal data is used to
establish how many people using PROMISE Application, enable us to organize the pages for the best
usability, make the Application suitable for your OS version, and ensure that
our pages are working at their full potential. Although we collect personal
data on web traffic we do not record personal data on
particular users of our Application, which means that no personal data about
you as an individual is retained or used.
Personal
data we collect from other social media:
We
allow you to create your account with the respective social media site (e.g. Facebook, Google or other). Those social media sites
may give us automatic access to certain personal data retained by them about
you. You control the personal data you share with us through the respective
social media you used for registering account with us privacy settings on the
applicable social media site and the permissions you give us when you grant us
access to the personal data retained by the respective social media site about
you. By associating an account managed by a social media site with your account
on our Application and authorizing us to have access to your personal data, you
agree that we can collect, use and retain the personal
data provided by these social media sites in accordance with this Privacy
Policy and privacy policy of respective social media site in part of personal
data transfer to us.
Third-party
Cookies:
We
use analytics packages from trusted third parties in order to
constantly improve your browsing experience on our websites. Our trusted
partners help us serve advertising and analytics and may place cookies on your
device. You can find their privacy policies in the list below. Please read
their privacy policies to ensure that you are comfortable with the manner in which they use cookies.
· Use
of Google Analytics, Google DoubleClick are subject to Google Privacy Policy;
· Use
of Facebook Pixel is subject to Facebook Privacy Policy;
· Use
of Adroll is subject to Adroll
Privacy Notice;
· Use
of Criteo is subject to Criteo Privacy Policy;
· Use
of Yahoo is subject to Yahoo Privacy Policy;
· Use
of Microsoft Bing Ads is subject to Microsoft Privacy Statement;
· Use
of MGID is subject to MGID Privacy Policy.
While
we do our best to keep this list updated, please note that third parties who
place cookies on your device may change from time to time, and there may be a
slight delay updating the list.
Also,
you can generally activate or later deactivate the use of cookies through a
functionality built into your web browser or mobile device.
To
learn more about how to control cookie settings through your browser:
· Firefox
· Chrome
For
other browsers, please consult the documentation that your browser manufacturer
provides. You can opt out of interest-based targeting provided by participating
ad servers through the Digital Advertising Alliance (http://youradchoices.com
).
III. The use and share of
the collected personal data
We
use your personal data to fulfill the provisions of PROMISE Application Terms of Use Agreement
with you and provide you with our services, to comply with our legal
obligations and to protect your vital interest. This includes:
· management
of your account and preferences, operate, measure and improve our services,
keep our services safe, secure and operational, and customize website content
that includes services that you may like in response to actions that you take;
· provision
of customer support, to contact you regarding your account, to resolve any
dispute and answer your questions and enquires;
· provision
of marketing information and special offers, different kind of notifications
about our services (you have the right to withdraw, opt-out, your consent at
any time;
· provision
of analytics, improve services, monitor and develop the personal data security
of our website and mobile applications, measure the performance of our
marketing and advertising campaigns;
· detection
and protection against fraudulent transactions and other suspicious activities;
· to
create Agregated data for internal use or for
improving services/websites and creating new features. Agregated
data is anonymous and is not linked to any personal data. Aggregate Information
helps understand trends and customer needs so that new products and services
can be considered and so existing products and
services can be tailored to customer desires. We may share such aggregated data
with our partners, without restriction, on commercial terms that we can
determine in our sole discretion.
Following
links to other websites
If
you click on a link that takes you away from PROMISE to another website, you should
remember that the Terms of Use Agreement and Privacy Policy of Application no
longer apply to the new website you visit. All your activity on any other
website, including any website with a link on Application, is subject to the
rules and regulations of that website. Therefore, we recommend that you read
all the policies of new websites you visit to fully understand their rules and
regulations for collecting, using, and sharing your personal data.
We
may share your personal data you provide to us with specially selected service
providers service providers who assist us in delivering the products and
services we offer for the sole purpose of providing the services or when we
consider their services or products to be of interest to you. These service
providers must adhere to strict confidentiality obligations in a way that is
consistent with this Privacy Policy and the agreements we enter
into with them. We may cooperate with external service providers to:
· oversee
a customer personal data database;
· help
us in sending out emails;
· help us with direct marketing;
· assist
us with storage and data analysis;
· prevent
from fraudulent activities;
· help
us in maintaining, developing and improving our systems/websites/applications/services;
We
may transfer or share a copy of your personal data in cases where PROMISE or one of its
properties, affiliates, or subsidiaries is part of a business transition, such
as a merger, being acquired by another company, or selling part of its assets.
The
Personal data may be used for legal purposes by us or the Data controller and
any of its affiliates, subsidiaries, directors and etc.,
in court or to protect against the contravention or unauthorized use of our
website, to defend or protect our rights.
We
may share personal data internally within our family of companies or with third
parties for purposes described in this Privacy Policy. Personal data collected
within the European Economic Area (“EEA”) may, for example, be transferred to
countries outside of the EEA for the purposes as described in this Privacy
Policy. We utilize standard contract clauses approved by the European
Commission, adopt other means under European Union law, and obtain your consent
to legitimize data transfers from the EEA to the United States and other
countries.
By
posting any content, messages, photos and/or videos to any public area of the
Application You automatically grant, represent and warrant that You have the
right to grant to us an irrevocable, perpetual, non-exclusive, fully paid,
worldwide license to use, copy, perform, display, and distribute such personal
data and content and to prepare derivative works of, or incorporate into other
works, such personal data and content, and to grant and authorize sublicenses
of the foregoing.
For
content that is covered by intellectual property rights, like photos and videos
(IP content), you specifically give us the following permission, subject to
your privacy and application settings: you grant us a non-exclusive,
transferable, sub-licensable, royalty-free, worldwide license to use any IP
content that you post on or in connection with Website / application (IP License).
This IP License ends when you terminate your membership with the Application
and we according this Privacy Policy and Terms and
Conditions delete your IP content unless your content has been shared with
others, and they have not deleted it.
The member
hereby agrees that we may at our own discretion use any available channels of
communication (including, but not limited to Email, phone, sms,
push notifications, Whatsapp, Facebook, Wechat, QQ and any other messengers) for customer support
and/or marketing purposes if You have provided us such. You may at any time
cancel Your consent on such communication by contacting our Customer Support
team.
You
can contact us using the contact information provided below with questions or
concerns. We also may resolve disputes you have with us in connection with our
Privacy Policy.
IV. Age restriction
Children
under 18 years of age are not allowed to use our website and our services are
not targeted at children under the age of 18. In accordance with the Children’s
Online Privacy Protection Act, any personal data we receive from users we
believe to be aged 18 or under will be removed from our database.
V.
The rights of access and opt-out
You
have the right, at any time, to change or delete your Personal data, please
carry out these instructions:
· Log
into your account;
· Click
the profile thumbnail at the top right hand corner of
the PROMISE main
page;
· Select
My Profile;
· Click
the pencil thumbnail in section You would like to edit;
· Edit your personal data;
· Click
Save.
You
may also send a request to our Support Team and they will guide you through the
process.
You
can decide which correspondence to receive from us in accordance with our
policy on freedom of choice and opting out. To stop receiving correspondence
you can click the unsubscribe link found at the bottom of each email you
receive or by emailing your request to us at unsubscribe@promisedating.com or
by changing the settings in your profile.
VI. Mode and place of processing
the personal data
The
Data controller processes the personal data of users of PROMISE in a proper manner and shall
take appropriate security measures to prevent unauthorized access, disclosure, modification or unauthorized destruction of the personal
data.
The
personal data processing is carried out using computers and/or IT enabled
tools, following organizational procedures and modes strictly related to the
purposes indicated. In addition to the Data controller, in some cases, the
personal data may be accessible to certain types of persons in charge, involved
with the operation of the website (administration, sales, marketing, legal,
system administration) or external parties (such as third
party technical service providers, mail carriers, hosting providers, IT
companies, communication agencies) appointed, if necessary, as Data Processors
by the Data controller.
The
Personal data is processed at the Data controller’s operating offices and in
any other place where the parties involved with the processing are located.
VII. Retention time and
deletion of personal data
The
Personal data is kept for the time necessary to provide the services to you and
you can always request that the Data controller suspend or delete your personal
data. If You wish to delete personal data we have collected during your use of
Application, You should send a request to our Support
Team. Processing of your request will take some time to take effect. Thank you
for your patience. Please note that changing or deleting your personal data
will only change or delete the data in our database for purposes of future
activities and for managing future communications. These changes and deletions
will not change or delete emails or personal data Application may have already
forwarded to other users or credit card companies or any other third parties,
all as provided above in this Privacy Policy. Further, if you delete your
personal data from the Application, but continue to use other our
Application/services, you may receive emails from us regarding those
Applications/services. However, we may elect to keep your personal data,
subject to the requirements of the law and legitimate interests of the Data
controller. In case of your request to delete all your personal data, you agree
that your email will be stored in our database to avoid creation of duplicate
accounts and for identification purposes. The email will not be used in
marketing activities, nor forwarded to any partner websites or Third parties.
Please
note that, even after termination of membership and deletion of any personal
data, termination of any license granted hereunder, some content may continue
to exist because of cached internet pages beyond the control of PROMISE.
VIII. Changes to this
privacy policy
PROMISE
reserves the right to replace, modify or amend this Privacy Policy at its own
discretion. It is your responsibility to review this page and check for any
Privacy Policy updates. Please note the latest modification date at the bottom
of the Privacy Policy.
IX.
Data controller contact information
If
You live in the USA, Canada:
Data
controller of the website is «DMM Solutions, Inc.», located at: 300 Park
Avenue, 12th floor,
New
York, NY, 10022.
If
You live in the European Union or anywhere else:
Data
controller of the website is «SOL Networks Limited», located at: 71, Tower
Road, SLM 1609, Sliema, Malta.
X. Rights of EU users
In
addition to rights set out in the section V of this Privacy Policy, if you are located in the European Union, as a data subject (a
person whose personal information is collected, stored and processed) you have
several rights under GDPR:
· You
have the right to obtain confirmation if your personal information is being
processed by us. If that is the case, you can access your personal information
and the following information: (a) the purposes of the processing; (b) the
categories of personal information; (c) to whom the personal information have been or will be disclosed; (d) the envisaged period for
which the personal information will be stored, or the criteria used to
determine that period.
If
you would like to have a copy of your personal information from us, we will
provide it based on (1) you will prove your identity, (2) it will not adversely
affect the rights and freedoms of others.
· You
have the right to demand that we erase your personal information, and we shall
erase it without undue delay where one of the following grounds applies: (a)
this personal information is no longer necessary in relation to the purposes
for which they were processed; (b) you withdraw consent if the processing was
based on your consent, and where there is no other legal ground for the
processing; (c) you object to the processing and there are no overriding
legitimate grounds; (d) your personal information have been unlawfully
processed; (e) your personal information have to be erased for compliance with
a legal obligation.
· You
have the right to receive your personal information which you provided us in a
structured, commonly used and machine-readable format
and have the right to transmit those data to another company, where: (a) the
processing is based on your consent or on a contract; and (b) the processing is
carried out by automated means.
· You
have the right to withdraw you consent for processing of your personal
information at any time. The withdrawal of consent shall not affect the
lawfulness of processing based on consent before its withdrawal.
· You
have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual
residence, place of work or place of the alleged infringement if you consider
that the processing of your personal information infringes GDPR.
XI. Acceptance of this
privacy policy
Our
website and your use of it, including any issue concerning privacy, is subject
to this Privacy Policy and the related Terms & Conditions. When you use our
website, you accept the conditions set out in this Privacy Policy and the
related Terms of Use Agreement. You signify and guarantee that you will never
generate any databases, websites, software, legal entities
and services that compete with PROMISE. Such behaviour will be fully
investigated, and necessary legal action will be carried out, including,
without limitation, civil, criminal, and injunctive redress.
The
acceptance of this Privacy Policy and applicable Terms of Use Agreement are
considered as a pre-condition for the use of our Application and our services.
Last updated February 2021.