Last updated on:August 20, 2019
1. INFORMATION WE COLLECT ABOUT YOU
1.1. In General. Through the Service, we may collect information that can identify you personally such as your name and email address (“personal information”), as well as other information that does not identify you. By using the Service, you are authorizing us to collect, use, and store data in connection with providing the Service. When you provide personal information through the Service, the information may be sent to and stored in servers located in the United States.
1.2. Information You Provide to Us. In order to use the App, you will be required to create a user profile (“ Profile”). As part of this process, you will need to sign-in using your Facebook login and permit Mutual to access certain information from your Facebook account (“ FB Account Info”) such as your birthday, email address, current city, hometown, photos, employment information, schools you have attended, friend list, and information about and photos of your Facebook friends who might be common Facebook friends with other Mutual users. Once you have logged into the App and as part of creating your Profile, you may be prompted to permit Mutual to access certain information from Instagram and/or your other social media accounts such as your photos and caption information (such information together with FB Account Info, collectively, your “ Social Media Account Info”). In addition to your Social Media Account info, you will also be asked to allow Mutual to collect your location information from your device when you use the App. Also, we may collect and store any personal information you provide as part of creating your Profile or during your use of the Service. This may include identifying information, such as your name, email address, telephone number, and, if you transact business with us, financial information. You may also provide us photos, information about you and your interests, and information about your preferences for matching with other Mutual users, such as search distance and age range. If you chat with other Mutual users, you provide us the content of your chats, and if you contact us through the App or Website, you provide us with the content of that communication.
1.3. Use of Technologies to Collect Information. We use various technologies to collect information from your device and about your use of the Service.
1.3.1. Information Collected Automatically. We automatically collect information from your browser or device when you visit the Service. This information could include your IP address, device ID and type, your browser type and language, the operating system used by your device, access times, your mobile device’s geographic location when the App is opened or is actively running, and the referring website address.
1.3.2. Cookies and Use of Cookie Data. When you use the Service, we may assign your device one or more cookies to facilitate access to the Service and to personalize your experience. Through the use of a cookie, we also may automatically collect information about your activity on the Service, such as the pages you visit, the time and date of your visits, and the links you click. If we advertise, we (or third party advertisers) may use certain data collected on the Service to show you Mutual advertisements on other sites or applications.
1.3.3. Pixel tags. We may embed pixel tags (also called web beacons or clear GIFs) on web pages, ads, and emails. These tiny, invisible graphics are used to access cookies and track user activities (such as how many times a page is viewed). We use pixel tags to measure the popularity of various aspects of the Service. Ad companies also use pixel tags to measure the number of ads displayed and their performance (such as how many people clicked on an ad).
1.3.4. Mobile Device IDs: If you're using the App, we use mobile device IDs (the unique identifier assigned to a device by the manufacturer), or advertising IDs (for iOS 6 and later), instead of cookies, to recognize you. We do this to store your preferences and track your use of the App. Unlike cookies, device IDs cannot be deleted, but advertising IDs can be reset in “Settings” on your iPhone. Ad companies also use device IDs or advertising IDs to track your use of the App, track the number of ads displayed, measure ad performance and display ads that are more relevant to you. Analytics companies use device IDs to track information about app usage.
1.4. Information Collected by Third Parties. We may allow service providers, advertising companies and ad networks, and other third parties to display advertisements through the Service. These companies may use tracking technologies, such as cookies or web beacons, to collect information about users who view or interact with their advertisements. We do not provide any non-anonymized personal information to third parties.
2. HOW WE USE THE INFORMATION WE COLLECT
2. HOW WE USE THE INFORMATION WE COLLECT 2. HOW WE USE THE INFORMATION WE COLLECT 2.1. In General. We may use information that we collect about you to do any of the following: verify your eligibility to use the Service; provide and improve the Service, and operate our business; manage your account and provide customer support; perform research and analysis about your use of, or potential interest in, our or third parties’ content, products and services; communicate with you by email or through the App about our or third parties’ content, products or services that may be of interest to you; analyze, display, and track content and advertising tailored to your interests through the Service and other sites, including providing our advertisements to you when you visit other sites; perform website and mobile application analytics; enforce or exercise any rights under our Terms of Service ; and perform functions or services as otherwise described to you at the time we collect information from you.
3. WHO WE SHARE INFORMATION WITH 3. WHO WE SHARE INFORMATION WITH 3.1. Information Shared with Other Users. When you complete your Profile and begin using the App, your Profile will be viewable by other users of the App. You can see the information in your Profile by going to “Settings” and “View My Profile” in the App. If you swipe up to indicate that you are interested in another user, you will be able to chat with that user if they also swipe up to indicate that the interest is mutual. If you chat with users with whom you have matched, those users will be able to see the content of your messages to them just as they would through Apple’s iMessage or any other mobile messaging service.
3.2.2. Other Circumstances. We may disclose your information, including personal information in the following circumstances: In response to a court order or a request for cooperation from law enforcement or another government agency; to exercise or establish our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us. When we believe disclosure is appropriate in connection with efforts to investigate, prevent, or take other action to prevent or stop illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property, and safety of our business and our users, shareholders, employees, service providers and others; to comply with applicable law or cooperate with law enforcement; or to enforce our Terms of Service and any other agreements, guidelines or policies applicable to our users. In connection with a corporate transaction, such as the sale of all or part of our business, a divestiture, merger, consolidation, or in the unlikely event of bankruptcy.
3.3. Non-Personal Information. We may use and share non-personal information we collect under any of the above circumstances. We may also share it with third parties to develop and deliver targeted advertising through the Service 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. We also may share aggregated, non-personal information, or personal information in hashed, non-human readable form, with third parties, including advertisers and investors, for the purpose of conducting business analysis or other business purposes. For example, we may engage a data provider who may collect web log data from you (including IP address and information about your browser or operating system), or place or recognize a unique cookie on your browser to enable you to receive customized ads or content. The cookies may re?ect de- demographic or other data linked to data that you voluntarily submitted to us (such as your email address), which we may share with a data provider solely in hashed, non-human readable form.
6. YOUR CHOICES ABOUT COLLECTION AND USE OF YOUR INFORMATION
6.1. Limiting the Information You Provide. You can choose not to provide us with certain information, but that may result in your not being able to use certain features of the Service.
6.2. Notifications. The Service may from time to time deliver notifications to your mobile device. You can disable these notifications by going to “Settings” and then “Notification Settings” in the App or by changing the notification settings on your mobile device.
6.3. Cookies. You can delete or decline cookies by changing your browser settings. Click “help” in the toolbar of most browsers for instructions.
7. PROTECTING YOUR PERSONAL INFORMATION
7.1. Mutual Security Measures. We take security measures to help safeguard your personal information from unauthorized access and disclosure. However, no system can be completely secure. Therefore, we cannot promise, and you should not expect, that your personal information, chats, or other communications will always remain secure.
7.2. What Else You Can Do to Protect Your Information. When you disclose personal information as part of your Profile or in chats with other Mutual users, that information will be viewable by other Mutual users (or in the case of chats, by the user with whom you are chatting). We encourage you to use discretion and caution when choosing what personal information to disclose.
8. CHILDREN'S PRIVACY We restrict use of the App to individuals who are at least 18 years old, and we do not knowingly collect, maintain, or use personal information from children under the age of 13.
us at: email@example.com.
Data (defined below) you provide us and (ii) informs you of what choices you have with respect to
our use of your Personal Data. Please contact us with any questions you have about this Privacy
Policy at the e-mail address in the Contacting Us section below. 1.PERSONAL INFORMATION WE COLLECT
2.HOW WE USE YOUR PERSONAL DATA 3.CATEGORIES AND PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
4.PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA 5.NON-PERSONAL DATA 6.WHO WE SHARE YOUR DATA
WITH 7.OUR COMMITMENT TO DATA SECURITY 8.YOUR CHOICES 9.INTERNATIONAL TRANSFERS OF INFORMATION
10.YOUR RIGHTS 11.ADDITIONAL INFORMATION ABOUT YOUR RIGHTS 12.E.U. RESIDENTS AND E.U. U.S. PRIVACY
SHIELD FRAMEWORK 13.DISPUTE RESOLUTION (E.U. RESIDENTS) 14.PRIVACY RIGHTS & DATA PROTECTION OFFICER
15.INFORMATION SECURITY & CONFIDENTIALITY 16.DATA RETENTION 17.NOTICE TO CANADIAN RESIDENTS
18.CALIFORNIA PRIVACY RIGHTS 19.OTHER SITES LINKED TO SERVICES 20.UPDATES 21.DOWNLOAD A COPY OF OUR
2. HOW WE USE YOUR PERSONAL DATA We will only use the details collected from you: (a) To manage your Account; (b) To provide you with Services; (c) To improve customer service; (d) To administer and maintain our Services (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data); (e) To contact you including sending information and updates relating to Services, questions or requests and/or for the provision of customer services; (f) To use data analytics to improve our Services, user relationships and experiences. (g) To address problems with our Service and to protect the security or integrity our business.
3. CATEGORIES AND PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA 3.1 Data Categories (i) Account Data. Account Data includes first name, last name, username, marital status, age, gender and other preferences. (ii) Contact Data. Contact Data includes billing address, email address and telephone numbers. (iii) Payment Data. Payment Data includes payment card/account details. (iv) Technical Data. Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Service. (v) Profile Data. Profile Data includes your username, password and/or photos used in connection with your Account. (vi) Usage Data. Usage Data includes information about how you use our Service. 3.2 Purpose for use. We identify the purpose for which we use your Personal Data as follows: PURPOSE DATA CATEGORY BASIS FOR PROCESSING Account and Membership (a) Account Data (b) Contact Data (c) Payment Data Required for Service and to provide you with customer service Administration of Services (a) Account Data (b) Contact Data (a) Performance of providing you with Service (b) Necessary to comply with our legal obligations (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our Service) To contact you (including sending information and updates relating to our Service. (a) Account Data (b) Contact Data (c) Usage Data (d)Technical Data Necessary for our legitimate business interests (to study how users use our Service, and to develop and improve them) To use data analytics to improve our Services, products/services, marketing, user relationships and experiences (a) Technical Data (b) Usage Data Necessary for our legitimate business interests (to define types of users for our Service and to keep our Service updated) (i) Change of Purpose. We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. PLEASE NOTE THAT WE MAY PROCESS YOUR PERSONAL DATA WITHOUT YOUR KNOWLEDGE OR CONSENT, IN COMPLIANCE WITH THE ABOVE RULES, WHERE THIS IS REQUIRED OR PERMITTED BY LAW.
4. LIMITING OR PROHIBITING USE OF YOUR PERSONAL DATA DEPENDING ON YOUR JURISDICTION YOU MAY PARTIALLY OR WHOLLY OUT-UP OF HAVING YOUR PERSONAL DATA USED BY EMAILING US. PLEASE INCLUDE "OPT-OUT" IN THE SUBJECT LINE OF EACH OPT-OUT NOTIFICATION ALONG WITH A SHORT CONCISE DESCRIPTION SPECIFYING HOW YOU WOULD LIKE TO LIMIT OR RESTRICT THE PROCESSING OF YOUR PERSONAL DATA. PLEASE NOTE THAT RESTRICTING THE PROCESSING OF YOUR PERSONAL DATA WILL LIKELY IMPACT YOUR ABILITY TO ACCESS AND USE ALL FEATURES OF OUR SERVICE.
6. WHO WE SHARE YOUR DATA WITH We share your Personal Data as follows: (a) Service Providers. We may share your information with third-party service providers that provide business, professional, or technical support functions that make products, our Service available to you. (b) Third-Parties. We do not share Personal Data with third-parties for their direct marketing purposes without your permission. (c) Legal Matters; Safety. We may access and disclose your information to respond to subpoenas, judicial processes, or government requests and investigations, or regarding an investigation on matters related to public safety, as permitted by law, or otherwise as required by law. We may disclose your information to protect the security of our Service including our servers, network systems, and databases. We also may disclose your information as necessary, if we believe that there has been a violation of our Agreement, any other legal document or contract related to our Service, or the rights of any third-party. (d) Sale or Transfer of Business or Assets. We may sell or purchase assets during the normal course of our business. If another entity acquires us or any of our assets, the information we have collected about you may be transferred to such entity. In addition, if any bankruptcy or reorganization proceeding is brought by or against us, such information may be considered an asset of ours and may be sold or transferred to third-parties. (e) Non-Personal Data. We may share Aggregate Data, anonymous, or de-identified Non-Personal Data with third-parties for their marketing or analytics uses.
7. OUR COMMITMENT TO DATA SECURITY To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect online. We regularly monitor our systems for possible attacks and vulnerabilities, but we can’t warrant the security of the data you send us even with the safeguards we have put in place.
8. YOUR CHOICES You have the following choices regarding your Personal Data. To protect your privacy and security, we may take reasonable steps to verify your identity before any request for access or alteration of your Personal Data. (a) How You Can Access or Correct Your Information. You can access a variety of your personally identifiable information that we collect online and maintain it either online, or by contacting our customer service representatives via the e-mail address in the Contacting Us section below. We use this procedure to better safeguard your information. You can correct factual errors in your personally identifiable information by sending us a request that credibly shows error. (b) How You Can Cancel Your Account. You can ask us to cancel your Account at any time using the "cancel account" feature. When you ask us to cancel your account, we will remove it from our Service and it will no longer be viewable by other users or the public. Upon Account cancellation, you will be able to reactivate your account within two years, after which your Personal Data will be destroyed and/or anonymized. (c) How You Can Request for Your Information To Be Deleted. You can ask us to delete your personal data at any time using the "delete my account and data" feature (provided it is no longer necessary for legal purposes or to provide services to you). You may also place a request by contacting our privacy team via e-mail at the e-mail address in the Contacting Us section below. We will delete and/or anonymize all your Personal Data we are not legally required to maintain within 30 days. IF YOU REQUEST YOUR PERSONAL DATA BE DELETED, ANY OUTSTANDING ORDER OR TRANSACTION WILL BE IRREVOCABLY TERMINATED AND YOU WILL NOT BE ABLE TO RESTORE YOUR ACCOUNT OR RETRIEVE YOUR PERSONAL DATA UPON DELETION. (d) Opting out (i) E-mail. Any subscription to various marketing e-mails can be cancelled by clicking the "unsubscribe" links in the e-mails, changing preferences in the "Your Account" area online, or sending a request to the e-mail address in the Contacting Us section below.. (ii) Analytics. You may learn more about opting-out of analytics by visiting http://www.play.google.com/store/apps/details?id=com.hello.mj. (iii) Cookies. You may disable, or delete cookies in your Web browser, but doing so may impact the usability of the website. To block cookies, you can also browse our Service using your browser's anonymous usage setting (called "Incognito" in Chrome, "In Private" for Internet Explorer, "Private Browsing" in Firefox and Safari etc.)
9. INTERNATIONAL TRANSFERS OF INFORMATION Information collected in the European Economic Area ("EEA") may be transferred, stored and processed by us and our services providers in the United States and other countries whose data protection laws may be different than the laws of your country. 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. In particular, 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. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries. Where we use providers based in the U.S., 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 the Europe and the U.S. For further details, see European Commission: EU-US Privacy Shield on https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/eu-us-privacy-shield_en. Please contact us at the e-mail address in the Contacting Us section below if you want further information on the specific mechanism used by us when transferring your Personal Data out of the EEA.
10. YOUR RIGHTS Under certain circumstances, you have the following rights under Data Protection laws. To protect your privacy and security, we may take reasonable steps to verify your identity before any exercise of the following rights according to applicable law. (a) Request access to your Personal Data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. (b) Request correction of your Personal Data. Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. (c) Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. (d) Object to processing of your Personal Data. Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third-party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. (e) Request restriction of processing your Personal Data. Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (i) if you want us to establish the data’s accuracy; (ii) where our use of the data is unlawful but you do not want us to erase it; (iii) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. (f) Request transfer of your Personal Data. Request the transfer of your Personal Data to you or to a third-party. We will provide to you, or a third-party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. (g) Right to withdraw consent. Withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain features of our Services to you. We will advise you if this is the case at the time you withdraw your consent. If you wish to exercise any of the rights set out above, please contact us at the e-mail address in the Contacting Us section below.
11. ADDITIONAL INFORMATION ABOUT YOUR RIGHTS (a) No fee usually required. You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. (b) What we may need from you. We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. (c) Time limit to respond. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
13. DISPUTE RESOLUTION (E.U. RESIDENTS) (a) General. If you reside in E.U. and have any questions or concerns regarding the use or disclosure of Personal Data, you should first contact us for assistance. We will promptly investigate and attempt to resolve all complaints regarding our use of Personal Data. In the event we are unable to mutually resolve a complaint; we will work with you and agree to refer your complaint to an independent dispute resolution mechanism. In the event we are unable to resolve your claim, you should contact our U.S. based third-party dispute resolution provider free of charge at JAMS in SF. In certain instances conditions, described on the Privacy Shield’s website https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may invoke binding arbitration when other dispute resolution procedures have been exhausted. (b) Questions and concerns. Any questions or concerns regarding the use or disclosure of Personal Data should first be directed us. We will promptly investigate and attempt to resolve all complaints regarding our use of Personal Data. In the event we are unable to mutually resolve a complaint; we will work with you and agree to refer your complaint to an independent dispute resolution mechanism. You may also work with the Data Protection Authority in your country http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm to assist with this process as well.
14. PRIVACY RIGHTS & DATA PROTECTION OFFICER (a) General. You may modify the information you have provided to us at any time through your Account. You can also opt-out of receiving marketing communications, deactivate, or delete your Account at any time. (b) Data Protection Officer. We have appointed a Data Protection Officer to ensure continued commitment to privacy and security practices. For further information please contact us at the e-mail address in the Contacting Us section below..
15. INFORMATION SECURITY & CONFIDENTIALITY We maintain (and requires its subcontractors and service providers to maintain) appropriate organizational and technical measures designed to protect the security and confidentiality of any information we process. However, no organizational or technical measures are 100% secure so you should take care when disclosing information online and act reasonably to protect yourself online.
16. DATA RETENTION How long will you use my Personal Data for? We will only retain your Personal Data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, audit, reporting and/or corporate compliance requirements. To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.
17. NOTICE TO CERTAIN INTERNATIONAL MEMBERS If you are a citizen of Canada, Brazil or Mexico and have questions about the accuracy of information that we have collected about you, you can have access to that information in order to verify and update it, unless we are permitted or required under applicable laws to refuse your access to such information. You may write or email us the e-mail address in the Contacting Us section below
18. CALIFORNIA PRIVACY RIGHTS Section 1798.83 of the California Civil Code entitles residents of California to request a notice detailing the categories of Personal Data that we have shared with third-parties for direct marketing purposes during the preceding calendar year, as well as the identity of those third-parties. To request a copy of your Personal Data maintained by us, please contact us as at the e-mail address in the Contacting Us section below.