('We') Together Networks Holdings Limited are committed to protecting and respecting your privacy.
This policy (together with our terms and conditions 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 ticking the acceptance box when signing up to use our Services, and by your continued use of the Services, you agree to bound by this policy as updated from time to time.
This policy will tell you about:
1. WHO WE ARE
(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 and conditions, 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 and conditions – Licence 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 us at firstname.lastname@example.org. 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.
(d) When we disclose your information to third parties and why
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, trade marks or other third parties’ rights by users. 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, fulfilment 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, which will be obtained from you at sign up process if you elect to provide this consent. As we continue to develop our business, we might sell or buy assets. In such transactions, the information we have collected about you will generally be one of the transferred business assets. Also in the unlikely event that any of our Group Companies or our assets are 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 us. Other persons if we are under a duty to disclose or share your information in order to comply with any legal obligation.
(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 during our sign up process, 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 us at email@example.com
6. WHERE WE STORE YOUR DATA
7. 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 on to our Services and use the Services in any way;
(b) Inactive Users: this means that you have not cancelled your account but you haven’t logged in for 4 months, or conducted any activity on our Services in that time;
(c) Cancelled: this means that you have followed our cancellation process and actively cancelled your membership.
(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 you account, including continue to market to you if you have consented to marketing. Just because you haven’t logged on 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) Cancelled Users
If you are a Cancelled User, we will delete all of your data 9 months after the date of cancellation. It is important that we retain your data 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 your account, copies of that information may still be viewable and/or accessed on the Internet to the extent such information has been previously shared with others, or copied or stored by other users or to the extent such information has been shared with search engines. We cannot control this, 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) Storage of activity data
Whilst we retain your Personal Data, Sensitive Personal Data and Anonymous Data as outlined at (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. All other profile and activity information including photographs, blocked list, search histories etc. are stored until 9 months after your account is cancelled.
8. KEEPING 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. Once we have received your information, we will use procedures and security features to try to prevent unauthorised access. Where we have given you (or where you have chosen) a password or user ID code which enables you to access certain parts of the Site, you are responsible for keeping the password or user ID code confidential. We ask you not to share a password or user ID code with anyone.
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 in process faster and easier. You may set your browser to block cookies and local storage devices, but if you do so, you may not be able to access all of the features of the Services. 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:
For further information about cookies visit: www.aboutcookies.org
10. OUR RIGHTS TO AMEND THIS POLICY
11. 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.
12. 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.