Privacy & Policies
The main reason we use your information is to deliver and improve our services. Additionally, we use your info to help keep you safe and to provide you with advertising that may be of interest to you. Read on for a more detailed explanation of the various reasons we use your information, together with practical examples.
- To administer your account and provide our services to you
- Create and manage your account
- Provide you with customer support and respond to your requests
- Complete your transactions
- Communicate with you about our services, including order management and billing
- To help you connect with other participants
Analyse your profile, activity on the service, and preferences to recommend meaningful connections to you and recommend you to others; For more information on our profiling and automated decision-making,
Show participants’ profiles to one another
- To provide new FEM Ltd. services to you
- Register you and display your profile on new FEM Ltd. participant and update your profile as an existing participant for our upcoming events.
- Communicate with you by email, phone, social media or mobile device about products or services that we think may interest you.
- To improve our services and develop new ones
- Administer focus groups and surveys
- Conduct research and analysis of participants’ 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 participants’ behaviour)
- Develop new features and services (for example, we may decide to build a new interests-based feature further to requests received from participants).
- To prevent, detect and fight fraud or other illegal or unauthorised activities
- Address ongoing or alleged misbehaviour on and off-platform
- Perform data analysis to better understand and design countermeasures against these activities
Retain data related to fraudulent activities to prevent recurrences
- To ensure legal compliance
- Comply with legal requirements
- Assist law enforcement
- Enforce or exercise our rights, for example, our Terms
- To process your information as described above, we rely on the following legal bases:
- Provide our service to you: Most of the time, the reason we process your data is to perform the contract that you have with us. For instance, as you go about using our service to build meaningful connections, we use your information to maintain your account and your profile
- Legitimate interests: We may use your information where we have legitimate Interests to do so. For instance, we analyse participants’ behaviour on our services to improve our offerings continuously, we suggest offers that we think it might interest you, and we process information for administrative, fraud detection and other legal purposes.
Since our goal is to help you make meaningful connections, the leading sharing of participants’ information is, of course, with other participants. We also share some participants’ information with service providers and partners who assist us in operating the services, with other Match Group companies and, in some cases, legal authorities. Read on for more details about how your information is shared with others.
With other Vendor’s
You share information with other vendoer when you voluntarily disclose information on the service (including your public profile). Please be careful with your information and make sure that the content you share is stuff that you’re comfortable being publicly viewable since neither you nor we can control what others do with your information once you share it.
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.
- We may also share information with partners who distribute and assist us in advertising our services. For instance, we may share limited information on you in hashed, non-human readable form to advertising partners.
- We follow a strict vetting process before engaging any service provider or working with any partner. All of our service providers and partners must agree to strict confidentiality obligations.
- We share your information with other Partner Group companies for them to assist us in processing your data, as service providers, upon our instructions and on our behalf. Assistance provided by other Partner Group companies may include technical processing operations, such as data hosting and maintenance, customer care, marketing and targeted advertising, finance and accounting assistance, better understanding how our service is used and participants’ behaviour to improve our service, securing our data and systems and fighting against spam, abuse, fraud, infringement and other wrongdoings.
- We may also share information with other Partner Group companies for legitimate business purposes such as corporate audit, analysis and consolidated reporting as well as compliance with applicable laws. We may also share participant information with other Match Group companies to remove participants who violate our terms of service or have been reported for criminal activity and bad behaviour. In some instances, we may transfer that participants from all platforms.
For corporate transactions
- We may transfer your information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganisation, dissolution, bankruptcy or other change of ownership or control.
- When required by law
- We may disclose your information 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 information:
- If disclosure would mitigate our liability in an actual or threatened lawsuit;
- As necessary to protect our legal rights and legal rights of our participants, business partners or other interested parties;
- To enforce our agreements with you; and
- 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 information with third parties. In any such case, we will make it clear why we want to share the information.
Sharing of information laid out in Section 6 sometimes involves cross-border data transfers, for instance to the Nigeria and other jurisdictions. As an example, where the service allows vendor to be located in the European Economic Area (“EEA”), their personal information is transferred to countries outside of the EEA. We use standard contract clauses approved by the European Commission or another suitable safeguard to permit data transfers from the EEA to other countries. Standard contractual clauses are commitments between companies transferring personal data, binding them to protect the privacy and security of your data
We want you to be in control of your information, 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 information that you provided to us, and that’s associated with your account directly within the service. If you have any question on those tools and settings, please contact our customer care team for help here.
- 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 information or the display of the relevant notifications. Of course, if you do that, certain services may lose full functionality.
- You can delete your account by using similar 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 information. Applicable privacy laws may give you the right to review the personal information 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 information by putting in such a request here.
- You are updating your information. If you believe that the information 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 here.
- For your protection and the protection of all of our participants, we may ask you to provide proof of identity before we can answer the above requests.
- Keep in mind; we may reject requests for specific reasons, including if the application is unlawful or if it may infringe on trade secrets or intellectual property or the privacy of another participant. If you wish to receive information relating to another participant, such as a copy of any messages you received from him or her through our service, the other participants will have to contact our Privacy Officer to provide their written consent before the information is released.
- Also, we may not be able to accommodate individual requests to object to the processing of personal information, 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.
- You can stop all information 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.
- In certain countries, including in the European Union, you have a right to complain about the appropriate data protection authority if you have concerns about how we process your personal information. The data protection authority you can submit a complaint with notably may be that of your habitual residence, where you work or where we are established.
- We work hard to protect you from unauthorised access to or alteration, disclosure or destruction of your personal information. As with all technology companies, although we take steps to secure your information, we do not promise, and you should not expect, that your personal information will always remain secure.
- We regularly monitor our systems for possible vulnerabilities and attacks and periodically review our information collection, storage and processing practices to update our physical, technical and organisational security measures.
- We may suspend your use of all or part of the services without notice if we suspect or detect any breach of security. If you believe that your account or information is no longer secure, please notify us immediately here
- To ensure that our systems and your data are protected against unauthorised access, theft and loss, we implemented a bug bounty program. For more information about our bug bounty program, please click here.
We keep your personal information only as long as we need it for legitimate business purposes (as laid out in Section 5) and as permitted by applicable law. To protect the safety and security of our participants on and off our services, we implement a safety retention window of three months following account deletion. During this period, account information will be retained although the account will of course not be visible on the services anymore.
In practice, we delete or anonymise your information upon deletion of your account (following the safety retention window) or after six months of continuous inactivity, unless:
we must keep it to comply with applicable law (for instance, some “traffic data” is kept for one year to comply with statutory data retention obligations);
there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or
The data must be kept for our legitimate business interests, such as fraud prevention and enhancing participants’ safety and security. For example, information may need to be kept preventing a participant who was banned for risky behaviour or security incidents from at the event location.
Keep in mind that even though our systems are designed to carry out data deletion processes according to the above guidelines, we cannot promise that all data will be deleted within a specific timeframe due to technical constraints.
Our services are restricted to Vendor who are 21 years of age or older. We do not permit participants under the age of 18 on our platform, and we do not knowingly collect personal information from anyone under the age of 18. If you suspect that a Vendor is under the age of 18, please use the reporting mechanism available through the service.
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.