PRIVACY POLICY

Last Updated 1 January 2023

We are committed to protecting and respecting your privacy.

This policy (together with our Terms of Use and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. By accessing our website, or by accepting this policy when signing up to use our Services, and/or by your continued use of the Services, you agree to bound by this policy as updated from time to time. If you do not agree with anything contained in this Privacy Policy or our Terms of Use, please stop using the Website (if you are a premium member, please contact us and we will cancel your premium membership).

Quick links for residents of California, USA or Virginia, USA: To quickly access our ’Do Not Sell or Share My Information’.



1. WHO WE ARE

We, flirtysparks.com, are the operator of this website and, for the purposes of the Data Protection Act 1998 (as amended), we are the data controller, maintaining a data controller registration with the Information Commissioner.

Our contact details are:
Name: flirtysparks.com
Address: flirtysparks.com
Phone:
Email for Customer services: support@flirtysparks.com

We operate a large number of social, dating, lifestyle and entertainment sites (including mobile applications/apps) through our Group Companies and Partner Sites. We refer to our sites and apps as, collectively, the "Services" within this policy. Some of our terms will make reference to our Group Companies or Partner Sites and any reference in this policy to "us" or "we" or "our" will include our Group Companies and Partner Sites.

(a) ABOUT OUR GROUP COMPANIES
As a large organization we have a number of subsidiary and sister companies ("Group Companies") that operate some of our sites on our behalf or provide services to us to enable us to provide the Services to you. For data protection purposes, these companies are called data processors. Our Group Companies are all wholly/majorly operated by us, or our parent company.

(b) ABOUT OUR PARTNER SITES
If you are reading this policy you are using one of our sites or apps. We have an extensive network of sites that we categorize as casual sites (for adults looking for short-term consensual casual relationships). We want to offer you a full range of products and services and in order to do that we will share your details across our Partner Sites (See below Creation of duplicate profiles across our Partner Sites) and we will market our different products and services to you (See below Marketing). You authorize us to reproduce and broadcast the information contained in your profile including your name, photograph, "chat up line", description etc. throughout all or part of our Partner Sites and our Group Companies for the purposes of delivering the Services to you.



2A. APPLICABLE LAWS

We value our users’ privacy, and comply with all applicable data privacy laws of the jurisdictions in which we operate, including the General Data Protection Regulation (EU) 2016/679). This version of our Privacy Policy that you are viewing is applicable to residents of the United States. The specific laws that will apply to you and your data may be determined by the location in which you live or in which we are based. Any reference to ‘personal data’ within this Policy has the meaning ascribed to it by the GDPR, which we apply as a baseline standard to our activities. If you are a resident of California, USA, or Virginia, USA, your attention is drawn to Section 3B, which fully details privacy matters under the laws applicable to your state(s). Whenever we refer to any Data Laws, we mean the laws applicable to you and us with regards your personal data protection privacy.



2B. LAWFUL BASIS FOR PROCESSING DATA

In accordance with some Data Laws, we are required to inform you of the lawful basis for processing your Personal Data. Our lawful basis for processing Personal Data is for the purposes of performing a contract to provide the Services to you, or steps prior to entering into a contract. Where this is not appropriate, we obtain the relevant consents from you and consent is the lawful basis. Where neither contract nor consent is appropriate, legitimate interests is the lawful basis. Our purpose for processing is described in detail in section 5(A, B).



3A. YOUR RIGHTS

International Data Laws give you as a user a number of rights regarding any personal data that you have provided to us which you are free to exercise at any time, however, we apply the same standards to all users, as we want to ensure that you have open access to your data and control over its use.

(a) Right to access personal data we hold about you
You can request a copy of the personal data that we hold about you, and we aim to respond within 14 to 30 days. To obtain a copy of your data, simply email our data protection team at privacy@flirtysparks.com attaching a photo or scan of your photo ID (passport or driving license) and a utility bill (to provide proof of your address). We need to make sure you are who you claim to be when requesting copies of data, and once we have verified your identity we will email or post a copy of your data to you. Your identification documents will be viewed for the purpose of verifying your identity prior to us making any personal data disclosures to you, and the identification documents will not be stored for any period of time longer than necessary to do this, nor will they be used for any purpose whatsoever other than facilitating your request for access.

(b) Right to amend/correct the data we hold on you
We want to make sure that data in our database is correct, so please contact us to make any amendments to our records by emailing privacy@flirtysparks.com.

(c) Opting out / restricting our processing
It is ok to change your mind about what personal data you allow us to use and keep and what you do not want us to use or keep. You can amend your settings through your account at any time, or contact privacy@flirtysparks.com. We must advise you, however, that opting out of some personal data processing/storage will result in a loss of functionality of the services and a reduced user experience.

(d) Right to “be forgotten” / right of erasure
You have the right to have all of your personal data erased when you stop using the services and close your account. We may need to keep a record of some data for security purposes (for example to assist law enforcement agencies with any criminal investigations) or for payment processing (to prove to banks that we have been authorized to take payments from you if you pay to use the services). There is more information about how long we keep data for below in section 9 of this Policy. To request erasure of all of your personal data, please contact privacy@flirtysparks.com.



3B. YOUR RIGHTS IF YOU ARE A RESIDENT OF CALIFORNIA, USA OR VIRGINIA, USA

We act in compliance with the California Consumer Privacy Act (as amended by the California Privacy Rights Act of 2020) and the Virginia Consumer Data Protection Act (Va. Code Ann. §§ 59.1-575 to 59.1-585) (together “US Data Laws”) and this section applies to you as an individual if you are a resident of California, USA, or Virginia, USA (“Select US Residents”). For the purposes of Virginia state law, we are the “Controller”.

About Personal Information
When we refer to Personal Information of Select US Residents, we mean any data that may identify you as an individual as prescribed by US Data Laws. If US Data Laws require us to provide a source of your data, the applicable sources of data are clearly stated in section 4 of this Privacy Policy.
How we collect, use and sell/share your Personal Information (summary)
Section 4 of this Privacy Policy details the categories of information we collect. We also collect Personal Sensitive Information that you provide to us, which may include racial or ethnic origin data, sexual orientation, religious beliefs, financial information, geolocation data and content of messages if sent through our platform. All of this information is collected for the purposes described in section 5 (A,B) of this Policy and shared as described in section 6. We do not sell your personal information, however, we do share it as fully explained herein.

How we collect, use and sell/share your Personal Information (in detail)

(a) Categories of Personal Information we collect may include:
Identifiers;
Characteristics of protected classifications;
Commercial information;
Photos and videos, which may identify you if your face is shown or your voice is heard;
Internet or browser/device network activity information, including browser and app logs, and app, browser and device information;
Geolocation data;
Information derived from other Personal Information about you, which could include your preferences, interests, and other information used to personalize your experience; and
Other information you choose to provide.

(b) Categories of Sensitive Personal Information (as defined in US Data Laws) we collect may include:
Social security, driver’s license, state identification card or passport number (when verifying your identity to respond to a data request by you);
Precise geolocation;
Information about your racial or ethnic origin or religious beliefs;
The content of messages you send and receive through any internal platform chat function or correspondence with our support team;
Information about your sexual orientation.

(c) Using your information
How we use your information is fully detailed in section 5(A,B) of this Privacy Policy, however, in summary, we may use your information when:
Providing, personalizing, and improving our products and services, including displaying ads;
Providing measurement, analytics, and other business services;
Promoting safety, integrity, and security;
Marketing communications to you;
Communicating with you for any other reason including customer support; and
Your consent to us processing your Sensitive Personal Information is expressly given in accordance with US Data Laws when you affirmatively create and account or take an affirmative action to make a payment, accept terms, or upload any sensitive content to your account/profile.

(d) Sharing your information
In addition to some of the information you choose to display on your account being shared with other users of our services, we share your personal information with various service providers, partners, vendors, law enforcement and others as fully described in section 6 of this Privacy Policy.

(e) Selling/Sharing your information in accordance with US Data Laws
All our sharing activities are detailed in section 6 of this Privacy Policy, however, there are some specific legalities of note for Virginia and California residents.
Virginia residents: We do not sell your personal information per the definition of “sell” under Virginia state law. Virginia state law provides exceptions for sharing personal information, meaning that, if you opt-out of data sharing, we do not need to honor that opt out if we are required to disclose your information in the following permitted ways (i) to a third party acting as a data processor for us e.g. payment processing provider, (ii) to a third party for purposes of providing a product or service that you have requested we/they provide to you, (iii) to our affiliate companies, (iv) if the information is information you have intentionally made available to the general public via a mass media channel and did not restrict such information to a specific audience, e.g. information which is publicly available through such platforms, and (v) as part of a merger, acquisition or such similar corporate transaction. California residents. We do not sell your personal information, however, we do share it as disclosed in section 6.

Retaining your data
US Data Laws require us to share information with you about our data retention periods, ensuring that we are minimizing the amount of time we hold your personal information and limiting this to only as long as is necessary. We fully describe our data retention policy in section 9 of this Privacy Policy.

Automated Decision-Making/Profiling
We do use profiling on our service. As detailed in the “Profiling” section of this Privacy Policy, to suggest matches to you we perform “profiling” on your data, which means our system analyzes your data and works out who best to match you with, then suggests those matches to you. You have the right to opt-out as described below. Please be aware that opting out will limit the accuracy of search results and potential matches.

Your rights as a resident of California or Virginia, USA
We do not discriminate against you if you exercise your rights, but if you choose to limit certain activities such as profiling, this may impact upon your enjoyment of the services. We respect all user privacy choices and, depending on whether you reside in California or Virginia, the following rights may be available to you:
  • Right of Access/Correction/Portability: You have the right to obtain from us access to the information we hold on you, and you are entitled to know if we have shared this information with any third parties. You can also ask us to correct that information, or request a copy in a machine readable format. If you would like to exercise either right, please submit your request by emailing CADATA@flirtysparks.com or by calling 1 (800) 806-3175. For your protection, it is important that we ensure the person making the request is really you, therefore we will contact you to let you know what else we need from you before we send you a copy of your personal information. This currently involves providing us with photographic identification (which is used for the purpose of verifying your identity and is not otherwise used or stored by us). You are entitled to receive a response from us within 45 days.
  • Right of deletion. You have the right to ask us to delete all the personal information we hold on you. If you would like to request the deletion of your information, please submit your request by emailing CADATA@flirtysparks.com or by calling 1 (800) 806-3175. For your protection, it is important that we ensure the person making the request is really you, therefore we will contact you to let you know what else we need from you before we send you a copy of your personal information. This currently involves providing us with photographic identification (which is used for the purpose of verifying your identity and is not otherwise used or stored by us). You are entitled to receive a response from us within 45 days.
  • Please note that Your Right to Access and Right to Deletion are not absolute and are subject to certain exceptions and may be specific to where you live. For instance, we cannot disclose specific pieces of Personal Information if the disclosure would create a substantial, articulable, and unreasonable risk to the security of the Personal Information, your account with us, or the security of the business’s system of networks.
  • Right to opt-out of sharing/selling information and limiting processing of Sensitive Personal Information. You have the right to understand how we share/sell your personal information and process Sensitive Personal Information (as described in this Privacy Policy), and, importantly, you have the right to opt out of having your Personal Information sold or shared, and to limit how the Sensitive Personal Information you’ve previously shared with us is processed. Please follow the instructions on our dedicated opt out page here. We must act upon your opt-out request within US Data Laws time limits, and we must inform any third parties that you have opted out. Your right to opt-out is not retroactive, and we will not undo, reverse, or otherwise attempt to alter any previous sharing.
  • Right to opt-out of profiling or targeted advertising. To opt out of profiling or targeted advertising please contact us by email CADATA@flirtysparks.com or by calling 1 (800) 806-3175.
  • Appointing an agent. Depending on where you reside, you may have the right to appoint an authorized agent to submit a request to opt-out of the sale of personal information on your behalf if you provide the authorized agent written permission to do so. If you use an authorized agent to submit a request, he or she must provide their name, email address, phone number, and written permission from you that includes your contact information. We will contact you using the information provided and verify your identity directly with us. We cannot respond to your request to provide additional disclosures or delete any personal information if we cannot verify your identity and the authorized agent’s authority to make the request on your behalf. Written permission is not required if the agent provides proof of power of attorney.
  • Appealing a decision we have made (Virginia residents only). You may have the right to appeal our refusal of any data request your make, through an appeal process. To appeal our refusal to provide the information (if this ever occurs), please write to us at CADATA@flirtysparks.com. We are legally obligated to respond to you within 60 days. If we do not accept your appeal you will then be entitled to escalate the matter by submitting a complaint to the Virginia Attorney General’s office by mailing mailoag@oag.state.va.us or writing to 202 North Ninth Street. Richmond, VA 23219. We cannot guarantee these details are accurate, and if you need to contact the AG Office, please double check all contact information.




    • 4. WHAT INFORMATION WE COLLECT ABOUT YOU

    We may collect and process different types of information about you. Some of this data is considered to be Personal Data (that means you can be identified by it including Sensitive Personal Data) and Anonymous Data (that is data that you cannot be identified from).

    (a) Information we collect when you sign up to our Services
    We will collect your personal details including but not limited to your full real name, user name, address, telephone, email address, date of birth, race, religion, sexual orientation and any other information you submit when you create a profile and sign up to our Services.

    (b) Data we collect in respect of customer service and support
    If you contact customer support we will keep any information you provide to us including records of correspondence.
    If you provide feedback to us, or take part in any customer survey, or participate in competitions we, we will keep any information you provide.

    (c) Data we collect/you upload from your activity across our Services
    When you use our Services to search for other users, explore our Services, or interact with other users, we will gather data related to these activities including:
    • Any information you populate your profile with including photographs (see also – Important Notice about how we use your photos);
    • Any messages that you send or receive through our sites;
    • A record of your activity including winks, block lists and search histories for example is also stored by us;
    • Details of any transactions that you carry out, including any information we require to provide the products or services that you sign up to;
    • Data from your other social network accounts if they are linked to our sites (see more details below – Information we collect from other social networks you use);
    • Your location according to the IP address assigned to your computer machine or mobile device by your Internet Service Provider, and mobile location data (see more details below – Information we collect about your location);
    • Usage data about how you use our site, this is what we consider Anonymous Data, which we collect using Cookies (see more details below – Our Cookie Policy).


    (d) Information we collect from other social networks that you use
    Some of our Services have the ability to link your use of the Services to other social networks you might have access to. If you have an account with another social network e.g. Facebook, you can share the data you have on our site with that network. To enhance your experience and create a personalized service we may ask you to log in to your Facebook account. By doing so you grant us access to your information stored on your Facebook profile including without limitation your personal information, photographs, media content, interests and locations. When you log in to the other network or install our app, we will receive the basic information from you including but not limited to your name, photos, gender, networks, user ID, friends list and any other information you make public and your email address. If you have logged in to other social networks and linked them to any of our profiles you grant permission for us to post updates, including location information, on your behalf therefore please exercise caution. You can turn off location data – see below.

    (e) Information we collect about your location
    We can collect location data from your computer and/or mobile device. When accessing the Services from a mobile device you will be given the option to allow location sharing with our application. If you do not wish to share your location data with us please turn off this feature by following your mobile device instructions to do so. We can track your IP address if you are using a computer to access the Services. If you are using a mobile device we use GPS with an accuracy range of 20 to 100 meters. Although location data is anonymous and can’t identify you, it can be shown to other users so please exercise caution if you do not wish to publicize your location. If you choose to change or turn off location sharing, in order to provide you with a more localized service and localized matches, we will show you as being at a randomly generated location within the postal code area that you have provided. We also use your location data to research our own Services, develop new products and improve our Services, including using third parties to help us either provide the Services to you or develop new ones, and target advertising to suit your user experience. Your devices can give us lots of information about the device including the brand, model, version of operating system, installed app details, email accounts, mobile carrier and so on. We may also connect your account with location data from Foursquare and can show your Foursquare check-ins on our map within some of our Services.

    (f) Information we collect about your Contacts
    Some features of the Services allow you to share your user experience with people you know "your Contacts"), or to invite them to join the Services. When given the option to do so you can choose to upload your Contacts information; we will request their name and email address. If you give us your password to upload these Contacts through a web based email provider we shall not store your password after you have uploaded your Contacts’ addresses. You may also choose to invite friends through your connected social networks. You assume all responsibility for ensuring that when you select a friend to be invited by email, application or SMS that the person wants to receive that invite from you.



    5A. HOW WE USE YOUR INFORMATION – AN OVERVIEW

    We process data we collect from you for the following core purposes:
    • To administer your user account with us (including notifying you of any compatible matches, tips, announcements, updates, special offers or services, should you consent to this);
    • To help us improve the structure, layout and usability of the Services;
    • To allow you to participate in any interactive features of the Services (including the features that require the mobile phone number);
    • To help personalize your repeat visits to and usage of the Services;
    • To notify you of any compatible matches or any matches who are near your location;
    • To provide you with information on products or services or news and offers that you request from us (see below under 'Marketing' for more information);
    • To answer any questions you may raise or respond to any comments you may send to us;
    • To notify you about changes to our service or the functionality of the Site;
    • To carry out market analysis and research;
    • To ensure that you are complying with the Terms of Use and to comply with our statutory and regulatory obligations.


    Providing our products and services
    We use the information we collect about you:
    (1) to fulfill your requests for our products, programs, and services;
    (2) to respond to your inquiries about our offerings;
    (3) to provide, personalize, and improve our offerings; and
    (4) to offer you other products, programs, or services from us and our affiliates, business partners, and selected third parties that we believe may be of interest to you.
    We may also use information that we collect about you to
    (1) perform research and analysis about your use of, or interest in, our products, services, or content, or products, services, or content offered by others; or
    (2) develop and display content and advertising tailored to your interests on our Website and other websites, including providing our advertisements to you when you visit other websites.
    We use the information we collect for our online forums and communities to provide an inter-active experience. We use this information to facilitate participation in these online forums and communities and, on one or more occasions, to offer you products, programs, or services.
    If you choose to submit content, we may publish your screen name and other information you have provided to us on our Website, the Internet, or elsewhere.

    Profiling
    To suggest matches to you we perform “profiling” on your data, which means our system analyzes your data and works out who best to match you with, then suggests those matches to you. Profiling and associated automated decision-making is conducted on the lawful basis of being necessary to provide the Services to you, or, where not appropriate, your consent.

    Communications
    We use information about you to communicate with you, including:
    (1) to notify you when we make changes to our terms;
    (2) to otherwise enforce or exercise any rights in our terms;
    (3) to fulfill a request by you for an online newsletter;
    (4) to confirm purchasers you have made through our Website; or
    (5) to contact you about your account with us (including managing your account and providing you with customer support).
    If offered, you may also choose to receive push notifications from us on your mobile device. Please note that any communications from other users are through our internal systems, which we use to match the message to you and generate an email notice without disclosing any information aside from your chosen screen name and the information contained in your profile.
    We use the information that you provide about others to allow us to send them invitations, gifts, cards, or other content on your behalf or through our Website. Occasionally, we also may use this information to offer products, programs, or services to them.

    Mobile device data usage
    When you access our Website on a mobile device, we may use the information collected for any purpose stated in this Privacy Policy.

    Use of non-personal information
    We use aggregate information about our users and non-personal information that we collect to improve the design, functionality, and content of our Website and to allow us to personalize your experience with our Website and offerings. We use this information:
    (1) to provide, maintain, personalize, protect, improve, and develop our products, programs, and services and to operate our business;
    (2) to analyze usage and performance of our Website (including to perform ad tracking and website or mobile application analytics); and
    (3) for us and our affiliates, business partners, and selected third parties to offer you products, programs, or services.

    Safety and security
    We may monitor your user activity to ensure that you and other users are complying with our Terms of Use and our Privacy Policy, and to monitor any suspicious activity on our sites. This monitoring may include monitoring of any user's photos, content, profiles, message and chat histories, and all other user activity on our sites.



    5B. HOW WE USE YOUR INFORMATION – IN DETAIL

    (a) Creation of duplicate profiles across our Partner Sites
    When you sign up to any one of our Services we will send you an email shortly afterwards advising that we have created a duplicate profile on our Partner Sites to enhance your chance of finding a suitable match. When we email you about this you will have the option to decline this service, which costs nothing extra.

    (b) Important notice about how we use your photographs
    As we explain in our Terms of Use, when you upload a photo to any of our Services you are allowing us to use that photo for advertising and other commercial purposes, royalty free. For full details please refer to our Terms of Use – License to My Content.

    (c) How we use your information about your Contacts
    If you choose to upload your Contact’s name and email address and/or mobile number you are allowing us to send an email or social network or mobile invitation on your behalf, inviting your Contact to join the Services. We will store your Contact’s name and email address solely for the purposes of inviting them to sign up to our Services and for associating your Contact with you and other people they may know. If your Contact does not want us to store their email address which you uploaded to our Services, they can ask us to remove it by contacting our support team. We will not store your Contacts information after invitations (up to a maximum of 3) have been sent. Your Contacts will then only receive future emails from us if they choose to accept the invitation and join our Services, or if you use any of our tools to share experiences with your Contacts and you input their email address for us to use again.



    6. SHARING YOUR INFORMATION

    Legal disclosures
    We may be required by law e.g. through potential or actual litigation, court order, public or governmental authorities, or rules and regulations within or out with your country of residence to disclose all or part of your information to third parties. We may also deem it necessary to make such a disclosure in the event of an issue of national security, law enforcement or other such similar situations as we deem necessary including, for example, allegations of alleged infringement of copyright, trademarks or other third parties’ rights by users.

    Third Party Service Providers
    We share your personal information with third party service providers in order to provide the Services to you including third parties who assist us with information processing, credit and payment processing, fulfillment of your subscription order, managing and hosting data, conducting consumer research or satisfaction surveys. These disclosures relate to providing our Services, improving our Services and delivering targeted advertising to you. We do not provide your contact details to third parties for direct marketing by them to you without your express consent.

    Change of ownership of the business
    As we continue to develop our business, we might sell, buy or otherwise transfer our assets either within in our corporate group, or with third parties. In such transactions, the information we have collected about you in accordance with this Privacy Policy and through your use of the services (including payment activity and billing methods) will generally be one of the transferred business assets. Also in the unlikely event that any of our group companies or our assets is purchased, your information will also be one of the transferred assets. We may share information about you with:
    • Other companies in the same corporate group as us;
    • A buyer or prospective buyer of our business;
    • Our professional advisers, such as our lawyers, where it is necessary for them to advise;
    • Other persons if we are under a duty to disclose or share your information in order to comply with any legal obligation.


    Business partners
    When you register or make purchases on our Website or click-through our advertisements offered on third party websites or applications, we may share your personal information with the businesses with which we collaborate to offer you the applicable products, services, or any advertisements. When you elect to engage in a particular merchant’s offer or program, you authorize us to provide your email address and other information to that merchant.

    Advertisement servers
    At our Website, third parties may present or serve advertisements, provide us with data collection, reporting, ad response measurement, and website analytics, as well as assist with delivery of relevant marketing messages and advertisements. These third parties may view, edit, or set their own cookies. The use of these technologies by these third parties is subject to their own privacy policies and governed by this Privacy Policy. They may also obtain information about other applications that you have downloaded to your mobile device, the mobile websites you visit, and other information about you or your device in order to help analyze and serve anonymous targeted advertising on the Website and elsewhere.

    Aggregated or non-personal information
    We may share your non-personal information we collect under any of the above circumstances. We may also share it with other companies and third parties to develop and deliver targeted advertising on our Website and on websites or applications of third parties, and to analyze and report on advertising you see. We may combine non-personal information we collect with additional non-personal information collected from other sources.



    7. MARKETING

    (a) When we market to you directly about our products and services
    We may share your information with our Partner Sites and Group Companies to develop and deliver targeted advertising to you of our Partner Sites and Group Companies’ products and services, or to help us to prepare marketing reports. We may send you information about our Partner Sites and Group Companies’ products and services, news and offers, and selected third party products and services that we think may be of interest to you. We may do this by contacting you through your email address or mobile phone number that you have provided. Any communication received from us, as consented to by you, will clearly state that it is being sent by us. You have the option to opt-out of our marketing communications at any time (see below).

    (b) When third parties market to you (Our "third party Partner Services")
    If you have consented to receive marketing communications from third parties, referred to as Partner Services, your data may be passed on to such third parties as we enter into data sharing agreements with, from time to time, for marketing and analytical reporting purposes. We cannot be held liable for the content of the third party’s communications or products/services they are promoting. If you have provided this consent, but change your mind, you can opt-out at any time (see below). Please be advised that you will also require to contact the individual third parties who have been marketing to you if you wish to stop receiving their communications directly.

    (c) Opting Out of Marketing
    If you change your mind about the marketing consent you have granted to us, you can amend your preferences under the "My Account" section of your chosen Site or emailing our support team.



    8. WHERE WE STORE YOUR DATA

    The personal data that we collect from you may be transferred to, and stored at, a location outside the European Economic Area ('EEA') including but not limited to Canada where we host our servers. It may also be processed by law enforcement agencies, employees and independent contractors of our Group Companies located outside the EEA who work for us or for one of our suppliers (for example, staff who are involved in providing services that you order from us, processing your payment details or providing support services to us). By submitting your personal data to us, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.



    9. HOW LONG WE KEEP YOUR DATA FOR

    Generally speaking, we only store data for as long as it is necessary to provide products and Services to you and others, with information typically being held until you cancel your membership.
    For data storage purposes however our users are considered as either being:
    (a) Active Users; this means you regularly log in to our Services and use the Services in any way;
    (b) Inactive Users: this means that you have not canceled your account but you haven’t logged in for 9 months, or conducted any activity on our Services in that time;
    (c) Canceled: this means that you have followed our cancellation process and actively canceled your membership.
    (d) Deactivated: this means that you have chosen to make your profile temporarily invisible to other users.

    (a) Active Users
    If you are an Active User we will store your data until you cancel your account.

    (b) Inactive Users
    If you are an Inactive User, you should be aware that we will continue to store your data until you cancel your account, including continue to market to you if you have consented to marketing. Just because you haven’t logged in for a few months, we hope you will return to use the Services regularly and we want your information to be there for your convenience so you should be aware that you will still appear in our search results for other users, and your profile will remain visible. The responsibility to change your preferences or cancel your account lies with you.

    (c) Canceled Users
    If you are a Canceled User who had paid for subscription at least once, we will delete all of your data 6 (six) months after the date of cancellation. If you are a free Canceled User and you have never paid for a subscription, we may delete all of your data immediately after you complete the cancellation procedure (remove account). Once you become a Canceled User, you will not be able to restore your data. It is important that we retain data of paid members for this short period after cancellation to ensure that we can answer any payment or other account related queries, or provide information to third parties in line with our disclosure provisions outlined in this policy e.g. assisting police investigations. Even after you remove information from your profile or delete/cancel your account, copies of this information may still be viewable and/or accessed on the Internet to the extent such information has been previously shared with others, copied or stored by other users or has been shared with search engines. We cannot control, 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.

    (c)(i) Canceled Users – Paid users
    If you are a Canceled User who has paid for a subscription at least once during the lifetime of your membership, we will delete all of your data 6 (six) months after the date of cancellation. Once deleted, you will not be able to restore your data. It is important that we retain data of paid members for this short period after cancellation to ensure that we can answer any payment or other account related queries, or provide information to third parties in line with our disclosure provisions outlined in this policy, e.g. assisting police investigations.

    (c)(ii) Canceled Users – Free users
    If you are a Canceled User and have never paid for a subscription, we may delete all of your data shortly after you complete the cancellation procedure (account removal). Once deleted, you will not be able to restore your data. Whether a free user or a paid user, even after you remove information from your profile or delete/cancel your account, copies of this information may still be viewable and/or accessed on the Internet to the extent such information has been previously shared with others, copied or stored by other users or has been shared with search engines. We cannot control, 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.

    (d) Deactivated users
    If you select to 'Deactivate my account' / 'Hide my profile' in the account settings this is considered to mean that you have deactivated your account. Your profile and personal data will continue to be stored, allowing you to reactivate your account. When you use this option, your account / profile will be temporarily invisible to other users, and will remain so until you cancel your account or reactivate your profile. To re-activate your profile simply log in again and your profile will be automatically re-activated. De-activating your profiles does NOT cancel your paid subscriptions, to ensure you are not further charged you must properly cancel your account, not simply de-activate it. For canceling your membership please contact our support and mention your user ID or follow guide by App Store℠, Google Play or other application platforms authorized by application.

    (e) Storage of activity data
    Whilst we retain your Personal Data, Sensitive Personal Data and Anonymous Data as outlined from (a) to (c) above, there are some features of our Services that we store data in respect of, for different periods of time. For example, messages are only stored for 30 days, winks and other similar activities are stored for 10 days. For paid members (including those who have previously paid and are now free users) all other profile and activity information including photographs, blocked list, search histories etc. are stored for a period 6 months post cancellation of your account.

    (f) Banned and terminated users
    If your account is ever terminated by us, or you are detected as a potential or actual scammer, or a potential or otherwise threat to our business or our users, your email address will be retained on our internal blacklist for as long as we deem necessary to protect the business and its users.



    10A. HOW WE KEEP YOUR DATA SECURE

    Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Site; any transmission is at your own risk. We take reasonable administrative, physical, and electronic measures designed to safeguard and protect your information from unauthorized access or disclosure. This includes using Secure Sockets Layer (SSL) software, which encrypts the personal information you input, and storing your information in encrypted form behind a firewall designed to block access from outside our network. Although we use commercially reasonable efforts to safeguard the privacy of your information, transmissions on the Internet cannot be made absolutely secure. Moreover, we cannot assure you that your personal information that we collect will not be used or disclosed inconsistently with this Privacy Policy. We assume no responsibility or liability for disclosure of any of your information due to errors in transmission, unauthorized third party access, or other causes beyond our reasonable control.



    10B. HOW YOU CAN HELP KEEP YOUR OWN DATA SECURE

    We have designed the Website to make it easy for you to find, connect, and interact with other members of the Website by posting information about yourself. You can also use our electronic messaging system, which allows you to communicate with other users provided you are both subscribers. We recommend and encourage you (and all our members) to think carefully about the information they disclose about themselves. 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 in your profile, which is open to abuse and misuse.
    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 and ethnic background, there is no requirement to do so. Please remember that photographs or any media content that you post on the Website may reveal these kinds of sensitive personal data. Where you do upload and choose to tell us sensitive information about yourself, you are explicitly consenting to our processing your information and making this public to other users.
    When you post information about yourself or use the messaging service, the amount of personal information you share is at your own risk. In addition, these postings may appear on other websites or in searches on the subject matter of your posting. Whenever you voluntarily disclose personal information on publicly viewable webpages, you make that information publicly available and others can collect and use that information. For example, if you post your email address, you may receive unsolicited email messages. If you post anything that is inconsistent with our terms, we reserve the right to terminate your account.



    11. OUR COOKIE POLICY

    We may collect information about your computer or mobile device by using Cookies. If you use our site you are consenting to the use of Cookies as explained here. Cookies are small text files that are placed on your computer by websites that you visit and provide statistical data to us, that does not identify you personally but tell us a lot about your browsing habits to tailor your user experience to suit your needs. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the operators of the site. We use cookies to enhance our security, help us gather information during subscription and understand our web traffic trends, and to share your non-personal information with carefully selected third parties for marketing purposes.
    Cookies help us to improve the Services and to deliver a better and more personalized service. They enable us:
    • To estimate our audience size and usage pattern;
    • To store information about your preferences, and so allow us to customize the Services according to your individual interests;
    • To speed up your searches;
    • To recognize you when you return to any website or application;
    • To provide anonymized statistical information: Non-personal data may be gathered on our behalf using cookies, log file data, and code that is embedded on our websites by specific third party partners to help these selected third parties to deliver relevant advertisements to you.

    We use this non-personal information to help improve the services we provide to you. When you visit the publicly available sections of the Services, a session ID cookie is placed on your computer that only lasts while you’re visiting. We also place persistent cookies (also known as local storage devices) on members’ computers, so that we remember them to make your login process faster and easier.

    Controlling and deleting cookies
    You have the right to choose whether or not to accept cookies and we explain how you can exercise this right below. However, please note that if you choose to refuse cookies you may not be able to use the full functionality of our Sites and the websites of other companies. You may block cookies in several ways:

    You can also block cookies by changing your browser settings so that cookies from this Site cannot be placed on your computer or mobile device. In order to do this follow the instructions provided by your browser (usually located within the "Help", "Tools" or "Edit" facility). Disabling a cookie or category of cookie does not delete the cookie from your browser, you will need to do this yourself from within your browser.
    Further information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.aboutcookies.org and www.youronlinechoices.eu.

    What cookies are used for and why we use them on this Site
    This table shows fully the cookie functions and why they are used, although our uses may change over time and it is important that you revisit this page to understand these uses:


    Cookie Functions Cookie Purposes
    Analytics and research We use the information collected by Google Analytics to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. You can opt-out of Google Analytics here.
    Authentication These cookies help us to identify our members so that when you’re logged in, you can enjoy all of the features without having to continually log in – our website "remembers" you and allows you full access without the need to keep entering your login details.
    Security and site integrity We may use cookies and other devices, such as CAPTCHAs, to help keep the Site and our members safe and secure by protecting the Site from fraud and spam attacks to keep your data safe.
    Site features and services These cookies and local storage devices provide the functionality that our members enjoy, such as uploading of photographs, chats, instant messaging, your account settings etc. We also use cookies to help provide experiences, such as links to other social media sites, social plugins and media content, including making it easier for you to share content between the website with your other favorite social networks. In some cases, the site feature you choose may allow a third party to place cookies or local storage devices on your computer. The third party who places cookies on your device is responsible for how they process their data you should always read their privacy policies. Third parties who place cookies on your device when you use the Site include Twitter and Facebook whose own privacy policies apply.
    Performance We need to use certain cookies and local storage devices to ensure our members have the best possible experience, such assisting with your navigation of our site, ensuring pages load up quickly and respond faster to your requests for our Services.
    Ad Serving & Behavioral Advertising We sell space on some of our websites to advertisers. We use several services to help us and advertisers understand what adverts you might be interested in. These cookies hold information about the computer – they don't hold personal information about you (i.e. it's not linked to you as an individual). But they might hold a record of what other websites you've looked at – so we could show you a car advert if you've previously visited a motoring website.
    Advertisements on this Site and the other sites you visit are provided by other organizations. Our advertising partners will serve advertisements that they believe are most likely to be of interest to you, based on information about your visit to the Site and other websites. In order to do this, our advertising partner may need to place a cookie on your computer.
    For more information about this type of online behavioral advertising, about cookies, and about how to turn this feature off, please visit www.youronlinechoices.eu and select your country.
    These are some examples of the services we use and how you can control those cookies. This list is not exhaustive and is subject to change. Please visit www.youronlinechoices.com for active cookie management on your device. Please note that turning off advertising cookies won't mean that you are not served any advertising merely that it will not be tailored to your interests.




    12. OUR RIGHTS TO AMEND THIS POLICY

    We keep our Privacy Policy under regular review and will post any changes to it on this page. We encourage you to regularly review our Privacy Policy to make sure you are always aware of what information we collect, how we use it and under what circumstances, if any, we may share it with other parties. We may also contact you from time to time to advise of any changes if we feel such notification is necessary depending on the extent of the changes. We will update the "last updated date" at the top of these terms, and if we believe a change is material, we will inform you by email using the last known email address we hold for you. It is your responsibility to check this Privacy Policy and Terms of Use regularly. If at any time you do not agree to any of the terms, you must stop accessing or using the website. If you continue to access and use the website your will be deemed to have accepted any changes.



    13. LINKS TO OTHER THIRD PARTY WEBSITES

    Our websites, apps, and promotional materials, may, from time to time, contain links to and from the websites of our third party networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.



    14. ADDITIONAL PRIVACY PROTECTIONS FOR CHILDREN USING THE INTERNET

    We do not solicit or target persons younger than legal age for collection of information online. Our Site does not permit children under the age of 18 to become users and we do not accept any information from children. By submitting information to us you represent that you are over the age of 18. We encourage minors to seek the consent of their parents before providing any information about themselves or their households to anyone on the Internet. We encourage parents to take an active role to protect the privacy and security of their children and to prevent the inappropriate use of information about their children. We support the development of technologies that help parents to control the collection and use of personal information from children who use online services in their households.



    15. QUESTIONS

    If you have any questions about this Privacy Policy or wish to exercise any rights hereunder, please contact our Data Protection Officer in the first instance.

    Our appointed Data Protection Officer is: GDPGuard Ltd, 4th Floor, Silverstream House, 45 Fitzroy Street, Fitzrovia, London, W1T 6EB

    privacy@flirtysparks.com

    In accordance with applicable UK and EU Data Laws, the following representatives are authorized to receive written communications on our behalf from the relevant supervising authorities and any data subjects exercising their rights under the UK Data Protection Act 2018 or the European General Data Protection Regulation (any other communications sent to our Representatives unrelated to privacy rights will be ignored):

    UK Representative (in accordance with the UK Data Protection Act 2018): privacy@flirtysparks.com

    EU Representative (in accordance with EU GDPR): privacy@flirtysparks.com



    16. GOVERNING LAW

    The laws of England and Wales govern this Privacy Policy and any dispute or claim arising out of or in connection with it or its subject matter (including non-contractual disputes or claims). If a conflict exists between this English language version and any translated copies of the Privacy Policy, the English version will prevail.



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