Privacy Policy


OUR COMMITMENT TO YOU

At updateme, your privacy is a top priority. Your privacy is at the center of the way we designed and built our platform, so that you can fully trust it and focus on building meaningful connections.

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

Our commitment to privacy. We design all of our products and services with your privacy in mind. We involve experts from various fields, including legal, security, engineering, product design and others to make sure that our decisions are taken with the utmost respect for your privacy.

Our commitment to transparency. Because we use many of the same online services you do, we know that insufficient information and overly complicated language are common issues in privacy policies. We take the exact opposite approach: we’re doing our best to write our Privacy Policy and related documents in plain language. We actually want you to read our policies and understand our privacy practices!

Our commitment to security. We have teams dedicated to keeping your data safe and secure. We constantly update our security practices and invest in our security efforts to enhance the safety of your information.

PRIVACY POLICY

Welcome to updateme’s Privacy Policy. Thank you for taking the time to read it.

We appreciate that you trust us with your information and we intend to always keep that trust. This starts with making sure you understand the information we collect, why we collect it, how it is used and your choices regarding your information. This Policy describes our privacy practices in plain language, keeping legal and technical jargon to a minimum.

This Privacy Policy applies from January 1, 2024.

1. Where This Privacy Policy Applies

This Privacy Policy applies to websites, apps, events and other services we operate under the brand updateme. For simplicity, we refer to all of these as our “services” in this Privacy Policy.

Some services may require their own unique privacy policy. If a service has its own privacy policy, then that policy -- not this Privacy Policy -- applies.

2. Information We Collect

It goes without saying, we can’t help you develop meaningful connections without some information about you, such as basic profile details and the types of people you’d like to meet. We also collect information about your use of our services such as access logs, as well as information from third parties, like when you access our services through your social media account or when you upload information from your social media account to complete your profile. If you want additional info, we go into more detail below.

Information you give us

You choose to give us certain information when using our services. This includes:

  • When you create an account, you provide us with at least your phone number and email address, as well as some basic details necessary for the service to work, such as your gender, date of birth, and who you’d like to connect with.
  • When you complete your profile, you have the option to share your sexual orientation, ethnicity, religious beliefs, and political opinions with us. Where you provide such elements to us, you consent to us using it for the purposes identified and as laid out in this Privacy Policy. You can also share additional information with us, such as details on your bio and your interests, as well as content such as photos, videos, and audio clips. To add certain content, like pictures or videos, you may allow us to access your camera, photo album, or microphone.
  • When you subscribe to a paid service or make a purchase directly from us (rather than through a platform such as iOS or Android), you provide us with information related to the purchases you make and our payment processors with information such as your debit or credit card number or other financial information.
  • When you participate in surveys, focus groups or market studies, you give us your insights into our products and services, responses to our questions and testimonials.
  • When you choose to participate in our promotions, events or contests, we collect the information that you use to register or enter.
  • If you contact us (e.g., through our customer care team or on social media), we collect the information you give us during the interaction.
  • If you share with us information about other people (for example, if you use contact details of a friend for a given feature), we process this information on your behalf in order to complete your request.
  • Of course, we also process your chats with other users as well as the content you publish to operate and secure the services, and to keep our community safe.

Information we receive from others

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

  • Users
    Users may provide information about you as they use our services, for instance as they interact with you or if they submit a report involving you.
  • Social Media
    You may decide to share information with us through your social media account, for instance if you decide to create and log into your updateme account via your social media or other account (e.g., Facebook, Google or Apple) or to upload onto our services information such as photos from one of your social media accounts (e.g., Facebook or Instagram).
  • Other Partners
    We may receive information about you from our partners where our ads are published on a partner’s service (in which case they may pass along details on a campaign’s success). Where legally allowed, we can also receive information about suspected or convicted bad actors from third parties as part of our efforts to ensure our users’ safety and security.

Information generated or automatically collected when you use our services

When you use our services, this generates technical data about which features you’ve used, how you’ve used them and the devices you use to access our services. See below for more details.

  • Usage Information
    Using the services generates data about your activity on our services, for instance how you use them (e.g., when you logged in, features you’ve been using, actions taken, information shown to you, referring webpages address and ads that you interacted with) and your interactions with other users (e.g., users you connect and interact with, and when you matched and exchanged messages with them).
  • Device Information
    We collect information from and about the device(s) you use to access our services, including hardware and software information such as IP address, device ID and type, apps settings and characteristics, app crashes, advertising IDs (which are randomly generated numbers that you can reset by going into your device’ settings and, in some cases, disable entirely), and identifiers associated with cookies or other technologies that may uniquely identify a device or browser.
  • Information collected by cookies and similar technologies
    We use and may allow others to use cookies and similar technologies (e.g., web beacons, pixels and SDKs) to recognize you and/or your device(s). Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) have a “Do Not Track” (“DNT”) feature that tells a website that a user does not want to have his or her online activity tracked. If a website that responds to a DNT signal receives a DNT signal, the browser can block that website from collecting certain information about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many businesses, including Updateme, do not currently respond to DNT signals.
  • Other information with your consent:
    Precise geolocation data:
     If you give us your consent, we can collect your precise geolocation (latitude and longitude) from your device. The collection of your geolocation may occur in the background even when you aren’t using the services if the permission you gave us expressly permits such collection. If you decline permission for us to collect your precise geolocation, we will not collect it, and our services that rely on precise geolocation may not be available to you.
    Selfie Verification data: If you choose to participate in our Selfie Verification feature, we collect your face geometry data, which may be considered biometric data in some jurisdictions, to verify that you’re the real you.  
    Other information: We may collect other information with your permission, such as photos and videos (for instance, if you want to publish a photo or video or participate in streaming features on our services).

3. How We Use Information

The main reason we use your information is to deliver and improve our services. Additionally, we use your info to help keep you and our community safe, and to provide you with advertising that may be of interest to you. Read on for a more detailed explanation of the various reasons for which we use your information, together with practical examples.

To administer your account and provide our services to you

  • Create and manage your account
  • Provide you with customer support and respond to your requests
  • Communicate with you about our services
  • Personalize pricing, offer discounts and other promotions, and complete your transactions
  • Administer sweepstakes and contest.

To help you connect with other users

  • Recommend you to other users and recommend other users to you
  • Show users’ profiles to one another
  • Enable users to search for and connect with users

To provide offers and operate advertising and marketing campaigns

  • Perform and measure the effectiveness of advertising campaigns on our services and marketing our services off our platform
  • Communicate with you about products or services that we believe may interest you

To improve our services and develop new ones

  • Administer focus groups, market studies and surveys
  • Review interactions with customer care teams to improve our quality of service
  • Understand how users typically use the services to improve them (for instance, we may decide to change the look and feel or even substantially modify a given feature based on how users react to it)
  • Develop new features and services (for example, we may decide to build a new interests-based feature further to requests received from users).

To ensure legal compliance

  • Comply with legal requirements
  • Assist law enforcement

To process your information as described in this Privacy Policy, we rely on the following legal bases:

  • Provide our service to you: The reason we process your information for purposes A and B above is to perform the contract that you have with us. For instance, as you go about using our service to build meaningful connections, we use your information to maintain your account and your profile, make it viewable to other users and recommend other users to you and to otherwise provide our free and paid features to you and other users.
  • Legitimate interests: We process your information for purposes C, D and E above, based on our legitimate interest. For instance, we analyze users’ behavior on our services to continuously improve our offerings, we suggest offers we think might interest you and promote our own services, we process information to help keep our users safe and we process data where necessary to enforce our rights, assist law enforcement and enable us to defend ourselves in the event of a legal action.
  • Comply with applicable laws and regulations: We process your information for purpose F above where it is necessary for us to comply with applicable laws and regulations and evidence our compliance with applicable laws and regulations. For example, we retain traffic data and data about transactions in line with our accounting, tax and other statutory data retention obligations and to be able to respond to valid access requests from law enforcement. We also keep data evidencing consents users give us and decisions they may have taken to opt-out of a given feature or processing.
  • Consent: If you choose to provide us with information that may be considered “special” or “sensitive” in certain jurisdictions, such as your sexual orientation, you’re consenting to our processing of that information in accordance with this Privacy Policy. From time to time, we may ask for your consent to collect specific information such as your precise geolocation or use your information for certain specific reasons. In some cases, you may withdraw your consent by adapting your settings (for instance in relation to the collection of our precise geolocation) or by deleting your content (for instance where you entered information in your profile that may be considered “special” or “sensitive”). In any case, you may withdraw your consent at any time by contacting us at the address provided at the end of this Privacy Policy.

4. How We Share Information

Since our goal is to help you make meaningful connections, the main sharing of users’ information is, of course, with other users. We also share some users’ information with service providers and partners who assist us in operating the services, with other Match Group companies for specified reasons as laid out below and, in some cases, legal authorities. Read on for more details about how your information is shared with others.

  • With other users
    You share information with other users when you voluntarily disclose information on the service (including your public profile). Please be careful with your information and make sure that the content you share is stuff that you’re comfortable being visible.
  • With our service providers and partners
    We use vendors to help us operate, distribute, market and improve our services, such as data hosting and maintenance, analytics, customer care, marketing, advertising, payment processing and security operations. We also share information with vendors who distribute and assist us in advertising our services. For instance, we may share limited information on you in hashed, non-human readable form to advertising vendors.
    We follow a strict vetting process prior to engaging any vendor or working with any partner. Our vendors and partners must agree to strict confidentiality obligations.
  • For corporate transactions
    We may transfer your information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control.
  • With law enforcement / when required by law
    We may disclose your information if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government / law enforcement investigation or other legal requirements; (ii) to assist in the prevention or detection of crime (subject in each case to applicable law); or (iii) to protect the safety of any person.
  • To enforce legal rights
    We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.
  • With your consent or at your request
    We may ask for your consent to share your information with third parties. In any such case, we will make it clear why we want to share the information.
    We may use and share non-personal information (meaning information that, by itself, does not identify who you are such as device information, general demographics, general behavioral data, location in de-identified form), as well as personal information in hashed, non-human readable form, under any of the above circumstances. We may also share this information with other Match Group companies and third parties (notably advertisers) to develop and deliver targeted advertising on our services and on websites or applications of third parties, and to analyze and report on advertising you see. We may combine this information with additional non-personal information or personal information in hashed, non-human readable form collected from other sources.  

5. Your Rights and Choices

We want you to be in control of your information, so we want to remind you of the following options and tools available to you:

  • Access/Update tools in the service. Tools and account settings can help you access, rectify or remove information that you provided to us and that’s associated with your account directly within the service.  
  • Device permissions. Mobile platforms can have permission systems for specific types of device data and notifications, such as phone contacts, pictures, location services, push notifications and advertising identifiers. You can change your settings on your device to either consent or oppose the collection or processing of the corresponding information or the display of the corresponding notifications. Of course, if you do that, certain services may lose functionality.
  • Uninstall. You can stop all information collection by an app by uninstalling it using the standard uninstall process for your device. Remember that uninstalling an app does NOT close your account. To close your account, please use the corresponding functionality on the service.
  • Account closure. You can close your account by using the corresponding functionality directly on the service.

6. How Long We Retain Your Information

We keep your personal information only as long as we need it for legitimate business purposes and as permitted by applicable law. If you decide to stop using our services, you can close your account and your profile will stop being visible to other users. Note that we will close your account automatically if you are inactive for a period of two years. After your account is closed, we will delete your personal information, as laid out below:

  • To protect the safety and security of our users, we implement a safety retention window of three months following account closure. During this period, we keep your information in the event that it might be necessary to investigate unlawful or harmful conducts. The retention of information during this safety retention window is based on our legitimate interest as well as that of potential third-party victims.
  • Once the safety retention window elapses, we delete your data and only keep limited information for specified purposes, as laid out below:
    • a) We maintain limited data to comply with legal data retention obligations: in particular, we keep transaction data for 10 years to comply with tax and accounting legal requirements. We may also need to keep “traffic data” / logs for one year to comply with legal data retention obligations. We also keep records of consents users give us for five years to evidence our compliance with applicable law.
    • b) We maintain limited information on the basis of our legitimate interest: we keep customer care records and supporting data as well as imprecise location of download/purchase to support our customer care decisions, enforce our rights and enable us to defend ourselves in the event of a claim, profile data in anticipation of potential litigation, for the establishment, exercise or defense of legal claims, and data necessary to prevent users who were banned or people who were found to be under the age of 18 from opening a new account, for as long as necessary to ensure the safety and vital interests of our users.
    • c) Finally, we maintain information on the basis of our legitimate interest where there is an outstanding or potential issue, claim or dispute requiring us to keep information (in particular if we receive a valid legal subpoena or request asking us to preserve data (in which case we would need to keep the data to comply with our legal obligations) or if data would otherwise be necessary as part of legal proceedings).

7. No Children Allowed

Our services are restricted to individuals who are 18 years of age or older. We do not permit individuals under the age of 18 on our platform. If you suspect that a user is under the age of 18, please use the reporting mechanism available on the service.

8. Privacy Policy Changes

Because we’re always looking for new and innovative ways to help you build meaningful connections and strive to make sure explanations about our data practices remain up-to-date, this policy may change over time. We will notify you before any material changes take effect so that you have time to review the changes.

9. How to Contact Us

If you have questions about this Privacy Policy, you have different options below:

Online: hi@updateme.com

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