REVEAL DATING LTD. PRIVACY POLICY

Last Updated: 06 August 2018

OUR COMMITMENT TO YOU

At Reveal, your privacy is a top priority. Your privacy is at the centre of the way we design and build the services and products you know and love, so that you can fully trust them and focus on building meaningful connections.

We appreciate that you put your trust in us when you provide us with your information and we do not take this lightly.

This Privacy Policy will inform you as to how we look after your personal data (for ease we will call this data) when you visit our website and when you use our services or products. This Privacy Policy also applies when you use any of our applications, attend any events and other services operated by Reveal.

To make it extra clear, we’ve added links to this Privacy Policy on all applicable services.

On some occasions certain services we provide will have their own unique privacy policy. On those occasions, that privacy policy will override this Privacy Policy. We will always notify you when this happens or when we use another privacy policy in place of this Privacy Policy.

This Privacy Policy is provided in a layered format so you can click through to the specific areas set out below. Alternatively, you can download a pdf version of the policy here:

GLOSSARY

LAWFUL BASIS

Legitimate interests, means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Our contractual obligations, means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation, means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

HOW WE KEEP YOUR DATA SECURE.

We have teams dedicated to keeping your data safe and secure. We constantly update our security practices and invest in our security efforts to enhance the safety of your personal data. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

THE TYPES OF DATA WE COLLECT

When you use our services, including navigating our website or app, we will collect personal data about you. Personal data means information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). It goes without saying; we can’t help you develop meaningful connections without some data about you, such as basic profile details and the types of people you’d like to meet. We also collect data generated as you use our services, for example access logs, as well as data from third parties, like when you access our services through a social media account. If you want additional info, we go into more detail below.

The type of data we will use
You choose to give us certain data when using our services. This includes:

  • Identity Data: When you create an account, you provide us with at least your login credentials, as well as some basic details necessary for the service to work, such as your title, name, gender and date of birth.
  • Contact Data: includes your billing address, mailing address and email address.
  • Special Category Data: When you complete your profile, you can share with us additional data, such as details on your personality, lifestyle, interests and other details about you, as well as content such as photos. To add certain content, like pictures, you may allow us to access your camera or photo album. Some of the data you choose to provide us may be considered “special” or “sensitive”, for example your racial or ethnic origins, sexual orientation, sexual interests and religious beliefs. Where we collect such sensitive data from you we will always ask your permission first. Financial Data: When you subscribe to a paid service or make a purchase directly from us (rather than through a platform such as iOS or Android), you provide us or our payment service provider with data, such as your debit or credit card number or other financial data.
  • Survey Data: When you choose to participate in surveys or focus groups, you give us your insights into our products and services, responses to our questions and testimonials. Giving us survey data is entirely discretionary and is not required in order to receive the services.
  • Promotional Data: When you choose to participate in our promotions, events or contests, we collect the data that you use to register or enter.
  • Service Data: This is data we collect about you in order to allow us to provide the services to you and includes situations where:
    • You contact our customer care team, we collect the data you give us during the interaction. Sometimes, we monitor or record these interactions for training purposes and to ensure a high quality of service.
    • You ask us to communicate with or otherwise process data of other people (for example, if you ask us to send an email on your behalf to one of your friends), we collect the data about others that you give us in order to complete your request.
    • Of course, we also process your chats with other users as well as the content you publish, as part of the operation of the services.

Data we receive from others
In addition to the data you provide us directly, we receive data about you from others, including:

OTHER USERS

Other users may provide data about you as they use our services. For instance, we may collect data about you from other users if they contact us about you. We receive and process this data as it is necessary in order to provide the services to you under our contractual obligations.

SOCIAL MEDIA

You may be able to use your social media login (such as Facebook Login) to create and log into your Reveal account. This saves you from having to remember yet another user name and password and allows you to share some data from your social media account with us. This option will be entirely discretionary and you will always be able to access the services by logging on directly to your account via the app.

OTHER PARTNERS

We may receive your data from our partners, for instance where Reveal ads are published on a partner’s websites and platforms (in which case they may pass along details on a campaign’s success). However this will only be received where we know that partner has complied with data protection laws in sharing your data with us.

Data collected when you use our services When you use our services, we collect data about which features you’ve used, how you’ve used them and the devices you use to access our services. See below for more details:

USAGE DATA

We collect data about your activity on our services, for instance how you use them (e.g., date and time you logged in, features you’ve been using, searches, clicks and pages which have been shown to you, referring webpage address, advertising that you click on) and how you interact with other users (e.g., users you connect and interact with, time and date of your exchanges, number of messages you send and receive).

DEVICE DATA

We collect data from and about the device(s) you use to access our services, including:

  • hardware and software data such as IP address, device ID and type, device-specific and apps settings and characteristics, app crashes, advertising IDs (such as Google’s AAID and Apple's IDFA, both of which are randomly generated numbers that you can reset by going into your device’ settings), browser type, version and language, operating system, time zones, identifiers associated with cookies or other technologies that may uniquely identify your device or browser (e.g., IMEI/UDID and MAC address);
  • data on your wireless and mobile network connection, like your service provider and signal strength;
  • data on device sensors such as accelerometers, gyroscopes and compasses.

OTHER DATA WITH YOUR CONSENT

If you give us permission, we can collect your precise geolocation (latitude and longitude) through various means, depending on the service and device you’re using, including GPS, Bluetooth or Wi-Fi connections. The collection of your geolocation may occur in the background even when you aren’t using the services if the permission you gave us expressly permits such collection. If you decline permission for us to collect your geolocation, we will not collect it.

COOKIES AND OTHER SIMILAR DATA COLLECTION TECHNOLOGIES

We use and may allow others to use cookies and similar technologies (e.g., web beacons, pixels) to recognize you and/or your device(s). You may read our Cookie Policy for more information on why we use them (such as authenticating you, remembering your preferences and settings, analysing site traffic and trends, delivering and measuring the effectiveness of advertising campaigns, allowing you to use social features) and how you can better control their use, through your browser settings and other tools.

Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) have a “Do Not Track” (DNT) feature that tells a website that a user does not want to have his or her online activity tracked. If a website that responds to a DNT signal receives a DNT signal, the browser can block that website from collecting certain information about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many businesses, including Reveal, do not currently respond to DNT signals.

HOW WE COLLECT YOUR DATA

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you :

  • apply for our products or services;
  • create an account on our website;
  • subscribe to our services or publications;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey with us; or
  • give us feedback or contact us.

Automated technologies or interactions.

As you interact with our website or our apps, we will automatically collect Usage Data and Device Data about your equipment, browsing actions and patterns. We collect this data by using cookies, server logs and other similar technologies. Please see our Cookie Policy for further details.

Third parties or publicly available sources.

We will receive data about you from various third parties as set out below:

Technical Data from the following parties:

  • (a)analytics providers such as Google based outside the EU;
  • (b)advertising networks based inside and outside the EU; and
  • (c)search Data providers based inside and outside the EU

Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside and outside the EU.

Please see our Cookie Policy for further details.

HOW WE USE YOUR DATA

We only use your data where we are allowed to by law. The main reason we use your data is to deliver our services to you. Additionally, we use your data to help keep you safe, where we are required to by law or where we can show it is in our legitimate interests to do so. We may also use your data to provide you with information about our products or services which are similar to the services or products you use and which we believe may be of interest to you.

Generally, we do not rely on consent as a legal basis for processing your data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us

Read on for a more detailed explanation of the various reasons we use your data, together with practical examples and the lawful basis for which we process it.

To administer your account and provide our services to you

  • Create and manage your account: We use your Identity Data and Contact Data and we do this lawfully so that we can fulfill our contractual obligations with you.
  • Provide you with customer support and respond to your requests: We will use your Identity Data and Contact Data and we do this lawfully so that we can fulfill our contractual obligations with you.
  • Complete your transactions: We use your Financial Data and we do this lawfully so that we can fulfill our contractual obligations with you.
  • Communicate with you about our services, including order management and billing: Identity Data and Contact Data and we do this lawfully so that we can fulfill our contractual obligations with you and in the area of billing it is in our legitimate interests to obtain payment for our services.

To help you connect with other users

  • Analyse your profile and that of other users to recommend meaningful connections: Identity Data and Contact Data and we do this lawfully so that we can fulfill our contractual obligations with you.
  • Show users’ profiles to one another: Your user profile which may contain some Identity Data and Contact Data and we do this lawfully so that we can fulfill our contractual obligations with you.

To ensure a consistent experience across your devices

Link the various devices you use so that you can enjoy a consistent experience of our services on all of them. We do this by linking devices and browser data, such as when you log into your account on different devices or by using partial or full IP address, browser version and similar data about your devices to help identify and link them: Usage Data and Device Data and we do this lawfully as it is necessary for our legitimate interests to develop and grow our business by increasing ease of use of our services.

To provide new Reveal services to you

  • Register you and display your profile on new Reveal features and apps: Identity Data and Contact Data and we do this lawfully so that we can fulfill our contractual obligations with you.
  • Administer your account on these new features and apps: Contact Data and Identity Data and we do this lawfully so that we can fulfill our contractual obligations with you.

To serve you relevant offers and ads

  • Administer discounts or other offers: Usage Data, Contact Data and Identity Data and we do this lawfully as it is necessary for our legitimate interests to study how customers use our products/services, to develop them and grow our business.
  • Develop, display and track content and advertising tailored to your interests on our services and other sites: Usage Data, Contact Data and Identity Data and we do this lawfully as it is necessary for our legitimate interests to study how customers use our products/services, to develop them and grow our business.
  • Communicate with you by email, phone, social media or mobile device about products or services that we think may interest you. Usage Data, Contact Data and Identity Data and we do this lawfully as it is necessary for our legitimate interests to study how customers use our products/services, to develop them and grow our business.

To improve our services and develop new ones

  • Administer focus groups and surveys (where you tell us you wish to participate): Contact Data, Identity Data, Survey Data and we do this lawfully as it is necessary for our legitimate interests to study how customers use our products/services, to develop them and grow our business.
  • Conduct research and analysis of users’ behaviour to improve our services and content (for instance, we may decide to change the look and feel or even substantially modify a given feature based on users’ behaviour): Usage Data and we do this lawfully as it is necessary for our legitimate interests to study how customers use our products/services, to develop them and grow our business.
  • Develop new features and services: Usage Data and we do this lawfully as it is necessary for our legitimate interests to study how customers use our products/services, to develop them and grow our business.

To prevent, detect and fight fraud or other illegal or unauthorized activities

  • Address on-going or alleged misbehaviour on and off-platform: Identity Data, Usage Data, Contact Data and we do this lawfully as it is necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud and is necessary to comply with a legal obligation
  • Perform data analysis to better understand and design countermeasures against on-going or alleged misbehaviour on and off-platform: Identity Data, Usage Data and Contact Data, and we do this lawfully as it is necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud and necessary to comply with a legal obligation
  • Retain data related to fraudulent activities to prevent against recurrences: : Identity Data, Usage Data, Contact Data and we do this lawfully as it is (a) necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud (b) necessary to comply with a legal obligation

To ensure legal compliance

  • Comply with legal requirements: Identity Data, Contact Data, Usage Data, Financial Data and we do this lawfully as it is necessary to comply with a legal obligation.
  • Assist regulators: Identity Data, Contact Data, Usage Data, Financial Data and we do this lawfully as it is necessary to comply with a legal obligation.
  • Enforce or exercise our rights, for example our rights under the contract we have with you: Identity Data, Contact Data, Usage Data, Financial Data and we do this lawfully as it is necessary for our legitimate interests for running our business, administration and protection of our business.

HOW YOUR DATA MAY BE SHARED WITH OTHERS

Since our goal is to help you make meaningful connections, the main sharing of users’ data is, of course, with other users. Read on for more details about how your data is shared with others.

With other users

As part of the services you may select to share data with other users when you voluntarily disclose data (including your public profile). Please be careful with your data and make sure that the content you share is stuff that you’re comfortable being publically viewable since neither you nor we can control what others do with your data once you share it.

If you choose to limit the audience for all or part of your profile or for certain content or data about you, then it will be visible according to your settings.

With our service providers and partners

We use third parties to help us operate and improve our services. These third parties assist us with various tasks, including data hosting and maintenance, analytics, customer care, marketing, advertising, payment processing and security operations. This is necessary for us to fulfill our contractual obligations with you.

We follow a strict vetting process prior to engaging any service provider or working with any partner. All of our service providers and partners must agree to strict confidentiality and data processing obligations and only process your data lawfully. We do not allow our third-parties to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

For corporate transactions

We may transfer your data if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

When required by law

We may disclose your data if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government / law enforcement investigation or other legal requirements; (ii) to assist in the prevention or detection of crime (subject in each case to applicable law); or (iii) to protect the safety of any person.

To enforce legal rights

We may also share data: (i) if disclosure would mitigate our liability in an actual or threatened legal proceedings; (ii) as necessary to protect our legal rights and legal rights of our users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.

With your consent or at your request

We may ask for your consent to share your data with third parties. In any such case, we will make it clear why we want to share the data.

We may use and share non-personal data (meaning data that, by itself, does not identify who you are, such as device data, general demographics, general behavioural data, geolocation in de-identified form), as well as personal data in hashed, non-human readable form, under any of the above circumstances. We may also share this data with third parties (notably advertisers) to develop and deliver targeted advertising on our services and on websites or applications of third parties, and to analyse and report on advertising you see. We may combine this data with additional non-personal Data or personal data in hashed, non-human readable form collected from other sources. More data on our use of cookies and similar technologies can be found in our Cookie Policy

CROSS-BORDER DATA TRANSFERS

Sharing of data sometimes involves cross-border data transfers, for instance to the United States of America and other jurisdictions. As an example, where the service allows for users to be located in the European Economic Area (“EEA”), their personal data is transferred to countries outside of the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.

Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

YOUR RIGHTS

We want you to be in control of your data, so we have provided you with the following tools:

  • Access / Update tools in the service. Tools and account settings that help you to access, rectify or delete data that you provided to us and that’s associated with your account directly within the service. You may also contact us to request a copy of your data by making an access request 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. If you have any question on those tools and settings, please contact our customer care team for help at help@revealdating.com or Kemp House, City Road, London EC1V 2NX.
  • 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. To request this please contact us.
  • Device permissions. Mobile platforms have permission systems for specific types of device data and notifications, such as phone book and location services as well as push notifications. You can change your settings on your device to either consent or oppose the collection of the corresponding data or the display of the corresponding notifications. Of course, if you do that, certain services may lose full functionality.
  • 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.
  • 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 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.
  • Deletion. You can delete your account by using the corresponding functionality directly on the service.

We want you to be aware of your privacy rights. Here are a few key points to remember:

  • Reviewing your Data. Applicable privacy laws may give you the right to review the personal Data we keep about you (depending on the jurisdiction, this may be called right of access, right of portability or variations of those terms). You can request a copy of your personal Data by putting in such a request at help@revealdating.com or writing to us at Kemp House, City Road, London EC1V 2NX
  • Updating your Data. If you believe that the Data we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion or object to its processing, please contact us at  help@revealdating.com or Kemp House, City Road, London EC1V 2NX.
  • Uninstall. You can stop all data collection by an app by uninstalling it using the standard uninstall process for your device. If you uninstall the app from your mobile device, the unique identifier associated with your device will continue to be stored. If you re-install the application on the same mobile device, we will be able to re-associate this identifier to your previous transactions and activities.
  • Accountability. In certain countries, including in the European Union, you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how we process your personal Data. The data protection authority you can lodge a complaint with notably may be that of your habitual residence, where you work or where we are established.

Charge to accessing your data

You will not have to pay a fee to access your 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 could refuse to comply with your request in these circumstances.

What we may need from you when you make a data access request

We may need to request specific information from you to help us confirm your identity and ensure your right to access your data (or to exercise any of your other rights). This is a security measure to ensure that your 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.

We may reject requests for certain reasons, including if the request is unlawful or if it may infringe on trade secrets or intellectual property or the privacy of another user. If you wish to receive personal data relating to another user, such as a copy of any messages you received from him or her through our service, the other user will have to contact us to provide their written consent before the Data is released.

Also, we may not be able to accommodate certain requests to object to the processing of personal Data, notably where such requests would not allow us to provide our service to you anymore. For instance, we cannot provide our service if we do not have your date of birth.

Time limit to respond to your data access request

We try to respond to all legitimate requests within one month. Occasionally it could 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.

HOW LONG WE RETAIN YOUR DATA

We keep your personal data only as long as we need it for the purposes we collected it for, including any period as may be required by law or to satisfy. We may retain your data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. During this period, account information will be retained although the account will of course not be visible to other users of the services anymore.

In some circumstances we will anonymise your data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

CHILDREN’S PRIVACY

Our services are restricted to users who are 18 years of age or older. We do not permit users under the age of 18 on our platform and we do not knowingly collect personal Data from anyone under the age of 18. If you suspect that a user is under the age of 18, please use the reporting mechanism available through the service.

PRIVACY POLICY CHANGES

Because we’re always looking for new and innovative ways to help you build meaningful connections, this policy may change over time. We will notify you before any material changes take effect so that you have time to review the changes.

HOW TO CONTACT US

If you have questions about this Privacy Policy, here’s how you can reach us:
By email:  help@revealdating.com

  • By post:
  • Privacy Officer
  • Reveal Dating Ltd
  • Kemp House
  • London EC1V 2NX