Privacy Policy 

Effective Date: February 16, 2024 

ABOUT US 

For members residing in Canada or the United States of America (“USA”), the company doing business as “Sneak Dating” is 100 Easy Street Carefree, AZ 85377. For members residing elsewhere in the world, the company doing business as “Sneaky Dating” is The Carefree Group, a company located at  100 Easy Street Carefree, AZ 85377, Collectively, these companies are referred to below as “The Carefree Group,” “we,” “our,” and “us.” We are firmly committed to your privacy, as further detailed in this policy (“Privacy Policy”). 

 

We are committed to the protection of your personal data and the transparency of our privacy practices. This Privacy Policy sets out our practices related to the collection, storage, access, use and disclosure (i.e., sharing) of your personal data (collectively, “Processing”) when you visit our websites or use either of our mobile applications (collectively, the “Platform(s)”), make use of the services available on and supporting the Platform(s) (the “Services”), or otherwise communicate or interact with us. To help us meet our commitment to you, we have appointed a Data Protection Officer (a/k/a Chief Privacy Officer) to oversee our privacy practices and our compliance with this Privacy Policy. 

 

If you have any questions or concerns regarding our policies and practices related to your information please use our Contact Form, or you can contact our Data Protection Officer/Chief Privacy Officer at dpo@Sneakydating.com, or by writing to our Toronto address listed above (if you reside in Canada or the USA) or our Cyprus address listed above (if you reside in any country other than Canada or the USA). 

 

By accessing the Platform(s) or using any of our Services, you accept this Privacy Policy and agree to the terms, conditions and notices contained or referenced herein. Your use of our Platform(s) or Services and any dispute(s) over privacy are subject to this Privacy Policy and our Terms and Conditions. 

 

Please note that this Privacy Policy only addresses the use and sharing of information that we collect from you, or that is collected from you on our behalf. This Privacy Policy does not apply to any Personal Data (as defined below) that you may disclose to other parties through your use of the Platform(s), our Services or on other sites throughout the internet, including to or through third-party sites that are hyperlinked from our Platform(s). Except as we may otherwise indicate, any Personal Data that you disclose on a third-party site will be subject to the privacy policy of that site. 

 

This Privacy Policy is current as of the Effective Date set forth above. In the event we intend to materially change any of our practices set out in this Privacy Policy, including if we intend to use your Personal Data for any purpose not expressly contemplated herein, we will provide you with notice of such change and obtain your express consent to the updated privacy policy. 

 

OVERVIEW 

The following is a high-level summary of this Privacy Policy. Please read this Privacy Policy carefully in its entirety before accessing the Platform(s) or using the Services. 

 

Controller: Where you are a Canadian or USA resident, The Carefree Group., doing business as Sneaky Dating, will be the organization collecting your personal data. Where you are a resident of any other jurisdiction, The Carefree Group, doing business as Sneaky Dating, will be the “controller” (or the equivalent thereof in your jurisdiction of residence) of your data. 

 

Information Processed: We Process different types of data from you in connection with your access to the Platform(s) and use of the Services. In particular, we collect data when you register for the Services, which can be attributed to you individually (for example, your email address, your location and demographic data). We also collect data automatically from your use of the Platform(s); for example, cookies and your IP address(es). For more information about the types of personal data we collect or otherwise Process, see Section 3, below. 

 

Usage: We use the data we collect from you for a number of different purposes which are described in Section 4, below. The main purpose is to facilitate your use of the Services. 

 

Disclosure: We disclose the data we collect from you in a number of different circumstances, including to our service providers to perform certain functions on our behalf in connection with our provision of the Services. Some of the recipients to whom we disclose your data may be located in jurisdictions outside your own. For more information about who we disclose information to, see Section 5, below. 

 

Security: We take the protection of your personal data seriously. For more information about how we protect your data, see Section 7, below. 

 

Your Rights: Depending on where you are located, you will have various rights in relation to your data. For more information about your rights, see Section 10, below. 

 

WHAT TYPES OF INFORMATION DO WE COLLECT? 

When you use the Platform(s) and/or our Services, we collect and receive two types of data: 

 

Data that, alone or in combination with other reasonably available data, can be used to identify you (“Personal Data”). For clarity, “Personal Data” includes any personal information, personal data or personally identifiable information as defined by the privacy or data protection laws in your jurisdiction; and 

 

Non-Personal Data that cannot be used to identify you (for example, aggregated statistical data about the use of our website, or data about a particular member that does not include any identifying data) (“Non-Personal Data”). For clarity, Non-Personal Data does not constitute Personal Data and any collection or other Processing of Non-Personal Data is not subject to Processing practices contemplated by this Privacy Policy. Any discussion regarding Non-Personal Data made in this Privacy Policy is provided for informational purposes only. 

 

We collect and receive the following Personal Data and Non-Personal Data directly from you and automatically through your use of our Services: 

 

Data we will request from you 

 

When you create a profile on our Platform(s), you will be required to provide the following data. Without this data, we will be unable to create an account for you or provide the Services: 

 

create a username (a unique name of your choice) and a password, 

 

contact information (for example, your email address), 

 

your relationship status, including what you are looking for from the Services (for example, if you are an attached male seeking females*); and 

 

demographic information (your city of residence, zip/postal code and date of birth for the purpose of determining your age). 

 

* This is sensitive Personal Data (because it indicates your sexual orientation) that is necessary for your use of the Services (i.e., so you can find potential connections that might be desirable to you). Accordingly, when you sign up for a new account (or, for existing users, whenever we update this Privacy Policy or the Terms and Conditions), we will require your express consent to our Processing of any sensitive Personal Data that you provide when creating the account or, thereafter, when you edit your profile, send messages to other members, etc. 

 

When you make a purchase from our Platform(s), you are required to provide billing information, including your chosen payment method, in order for us to be able to process your transaction. Some payment methods (e.g., a credit or debit card), will require you also to provide your name and billing address. Failure to provide adequate billing information means we would be unable to provide the requested Services/features. 

 

At your option, you may choose to activate 2-factor authentication for your account through a third-party member authentication service. This service is based on providing you with a verification code, which you enter when logging into your  account, in order to confirm your identity. The third-party vendor sends verification codes by text message to a telephone number that you provide to Sneaky Dating to facilitate your use of this service, we will be required to share your telephone number with the vendor, in order to link it to your Sneaky Dating account, and will therefore ask for your phone number for this purpose. Note that this verification service is not part of our Services, and is subject to the third-party’s terms and conditions, including different policies with respect to the Processing of your Personal Data. We do not have control over the vendor. You will need to make your own independent judgment regarding your interaction with them. Please note that, if you decide to delete your Sneaky Dating account, we will delete your phone number from our records, but this will not affect the third-party vendor with respect to the phone number we provided to them on your behalf. You will need to contact them directly with respect to management of your account, including any deletion requests. As the vendor we use to provide this service may change from time to time, we are not naming them in this Privacy Policy. If you wish to know the name of the current vendor, so you can review their policies or make a deletion request, please contact us using our Contact Form. You also may choose to use an authentication application of your choice to provide you with 2-factor authentication. In such case, the personal data (if any) required to use that application shall be subject to the terms and conditions and/or privacy policy of the company that provides the authentication application, as we do not have control over such authentication applications. 

 

Data that is generated when you use the Platform(s) 

 

You may send messages on the Platform(s), which may include or reveal Personal Data about you. Generally, we do not moderate or actively review the data which you include in messages sent between members but this data is available to us and we may monitor it for fraud, or where we suspect members of being under the age of 18, or of using our Services for the purpose of solicitation or any other violation of our Terms and Conditions or of this Privacy Policy. You only should message sensitive Personal Data (e.g., about your race, health, or sexual preferences) in situations where you are comfortable voluntarily to make this data public and you consent to our Processing of any sensitive Personal Data (in accordance with this Privacy Policy and applicable privacy laws). 

 

Data you may choose to provide to us 

 

While creating your profile, you may choose how much data you share with us. You will be offered the chance to upload/provide: 

 

a photograph (we provide tools to allow you to blur or add masks to any photographs); 

 

personal characteristics such as your height*, weight*, body* type and gender (although you may tell us you would rather not say); 

 

if you reside outside the European Economic Area and the United Kingdom, your ethnicity* (although you may tell us you would rather not say); and 

 

a personal description. 

 

* This is sensitive Personal Data (because it includes information about your health or race). Accordingly, when you sign up for a new account (or, for existing users, whenever we update this Privacy Policy or the Terms and Conditions), we will require your express consent to our Processing of any sensitive Personal Data that you provide when creating the account or, thereafter, when you edit your profile, send messages to other members, etc. 

Once you create an account on the Platform(s), you may include edit details that you already provided to us or provide additional details about yourself through the Profile page such as: 

 

details of any languages spoken; and 

 

details of smoking habits (although you may choose not to specify your habits ). 

 

You are encouraged to create a pseudonymous profile and are not required to include data in your profile that would allow you to be directly identified. If you want to remain anonymous to the general public, please be careful about what you choose to share, especially if you upload photographs, and do not choose a username which could allow you to be identified easily. 

 

Data that will be collected automatically from your device 

 

Where you have enabled the setting on your mobile device, with your permission, we also will collect your location data to help you identify other Platform members in your area who also have enabled this setting. You may turn off this functionality through the location settings on your mobile device. We also collect your IP address(es), which may reveal your general geographic location from your browser access, to help us respond quickly and efficiently to inquiries and requests and to help us protect against fraud. 

 

We also collect Personal Data through use of cookies and other tracking devices. For more information about how we use cookies and other tracking devices, see Section 11, below. 

 

Data collected from third parties 

 

Occasionally, we may receive Personal Data about you from third parties, such as from a credit card company or issuer with respect to a disputed charge, or from another member of the Services respecting a complaint about your activities while using the Services; however, we do not seek or purchase Personal Data about you from third parties. 

 

HOW DO WE USE YOUR INFORMATION? 

We may use the Personal Data and Non-Personal Data that we collect for the following purposes: 

 

to provide you with the Services, including: 

 

to provide you with access to a forum focused on open-minded and discreet relationships, where members can search for and connect with other like-minded individuals; 

 

to allow members to find other members’ profiles based on preferences or member location and to allow you to create a profile and promote that profile to other members of the Services; 

 

to maintain and improve our Services, including improving the content and functionality of our Platform(s) or customizing our pages or screens; 

 

to tailor the content and information that we may send or display to you, to offer location customization and personalized help and instructions, and to otherwise personalize your experiences while using the Platform(s) and the Services; 

 

to conduct surveys and market research in order to improve the Services; 

 

with your consent or as permitted by law, to communicate with you in connection with the Services including, for the purposes of informing you of changes or additions to the Platform(s), or of any our products and Services we believe may be of interest to you; 

 

to detect and combat fraud, and better understand how to protect your information; 

to process your payments and to help resolve payment disputes; 

 

to deliver targeted advertising and promotional offers to you from external companies that are of the highest relevance to your demographic profile; 

 

to manage your account and provide you with customer support; 

 

to protect our own rights and interests, such as to resolve any disputes, enforce our Terms and Conditions, or to respond to legal process; 

 

to protect the rights and interests of members of the site from other members who violate the law or our Terms and Conditions, such as in cases of harassment or threats; 

 

to comply with applicable law; 

 

to save your data, such as your member account, registration, profile data and other data so you do not have to re-enter it each time you visit or use the Services; 

 

to offer more secure access to your account; 

 

to track your return visits to, and use of, the Services in order to create aggregated usage statistics to help us better understand and optimize web usage; 

 

to offer potential match recommendations to you, based on your viewing history and search criteria; and 

 

in connection with a potential sale of our business or assets and/or to manage legal claims against us each of which are described in more detail below. 

 

We also use Non-Personal Data. For example, we may collect and analyze aggregated and/or de-identified information to produce statistical data to help us improve our provision of the Services and manage member activity across the Platform(s). 

 

The following only applies to members residing in the EEA and UK. 

 

We collect your data as a Data Controller when we have a legal basis to do so. The following legal bases pertain to our collection of data: 

 

Our use of your Personal Data is necessary to perform a contract or take steps to enter into a contract with you. For example, this applies to our Processing activities described at 4A, 4G, 4N and 4P above. Where the information Processed is a “special category of personal data” (known as sensitive data – in particular health information or information about your sexual preferences or ethnicity), we require an additional lawful basis, which will be your consent. 

 

Our use of your Personal Data is in our legitimate interest as a commercial organization to make improvements to our products and Services and to expand our business. For example, this applies to our Processing activities described at 4B, 4C, 4D, 4H, 4M, 4Q (save where we need consent by jurisdictional law) and for certain purposes in 4F and 4I. 

 

Our use of your Personal Data is necessary to comply with a relevant legal or regulatory obligation that we have, in particular, where we are required to disclose Personal Data to a court, tax authority or regulatory body in the event of an investigation. For example, this applies to some purposes involved our Processing activities described at 4E, 4F, 4J, 4K and 4L. 

 

Our use of your Personal Data is in accordance with your consent. For example, this applies to our Processing activities described at 4E, 4H, 4K, 4M, 4N and 4O (in each case where required by jurisdictional law). 

 

HOW WILL WE SHARE YOUR INFORMATION? 

We may provide Personal Data to third parties in the following limited circumstances: 

 

To trusted third parties, to assist us in the provision of the Services and the operation of our business. 

 

We may share your Personal Data with third-party service providers that we have engaged to perform services on our behalf, based on our instructions, such as to our parent, subsidiary or sister companies, or to advertising agencies, marketing agents, credit card payment processors, data processing and storage companies or organizations which provide administrative and support services to us. 

 

We limit our disclosure of your Personal Data to such third parties to that which is reasonably necessary for the purpose or service for which the third-party service provider is engaged. 

 

We also use contractual and other means to provide a comparable level of protection while the data is being Processed by such third parties, including limiting such providers to using your Personal Data solely to provide us with the specific service for which those providers were engaged, and for no other purpose. You can obtain more information about our policies and practices with respect to the use of Personal Data by third-party service providers by contacting dpo@ashleymadison.com. 

 

To courts, regulators and law enforcement as required or permitted by law, including: 

 

to government bodies and law enforcement agencies, pursuant to warrant, order, subpoena or statutory requirement; 

 

in connection with any legal proceedings or prospective legal proceedings involving Ruby; and 

 

to otherwise establish, exercise or defend our legal rights and protect against misuse of our Platform(s) (including providing information to third parties for the purposes of fraud prevention and reducing credit risk), or to protect the personal safety and property of our members or the public as permitted by law. This means that if you provide false information or attempt to pose as someone else, information about you may be disclosed as part of any investigation into your actions. 

 

In the event of a sale or merger, including: 

 

as required, in connection with the sale, assignment, bankruptcy proceeding or other transfer of the business or a portion of the business of our Platform(s), including a corporate merger, consolidation, restructuring, sale of assets or other corporate change of our direct or indirect parent companies that affects us, as well as the insurance or securitization of our assets. In any such case, the recipient parties will be required contractually to keep the information confidential and use it only for the purposes of the transaction, or proposed transaction, in question. 

 

In the event a business transaction is completed, assignees or successors of our business or assets may use and disclose your Personal Data, as obtained from Ruby only for the purposes set out in this Privacy Policy, unless your further consent is obtained. 

 

We do not otherwise share, give, rent or sell your Personal Data to any third parties, unless you give us additional consent to do so. 

 

You should be aware that some of your Personal Data will be provided to, or otherwise visible to, other members of the Services as part of the normal operation of the Services (as set out in the terms or descriptions of specific features). For example, your username, profile information and any information that you post to the Platform(s) will be available to, and searchable by, other members of the Platform(s) and Services. In the European Economic Area and the United Kingdom, the lawful basis for this disclosure is voluntarily making the data public. If you are not comfortable making this data public, you can use our Hide Profile feature, which allows your profile to remain private and un-searchable. 

 

Other members of the Services, who may be located in any country in the world where our Services are offered, may also receive notifications (on the Services, via email, or through device notifications) that promote your profile, including your nickname and your profile photo. Please note that we cannot prevent the content you post or share on our Platform(s) or Services from being used by other members in a manner that may violate this Privacy Policy, the law, or your personal privacy, or from being shared or disclosed by other members. 

 

We may disclose Non-Personal Data in a number of circumstances including to third-party advertisers. 

 

DATA TRANSFERS 

As we have a global business operation, your Personal Data may be transferred between Ruby Life Inc. and Ruby Life International Limited, or between either of those entities and our parent, subsidiary or sister entities, or disclosed to service providers to enable their provision of services. As a result, your Personal Data may be collected, stored, accessed, used, and/or disclosed (as aforementioned, these activities involve “Processing” your Personal Data) in countries outside your jurisdiction of residence. For example: (i) we host Sneaky Datingin Canada; (ii) we provide customer support in European Economic Area member states (including Cyprus) and, potentially, other countries; and (iii) some of your information which we use to send you email messages may be stored by a third party in the United States. Additionally, your profile will be accessible by members all over the world. If you are concerned about this, you can stop using our Services at any time. Some of these jurisdictions do not have an equivalent level of data protection laws as those in your country; however, we will take steps to ensure that the information receives the same level of protection as if it remained within your country of residence. In particular, if you are a resident of the European Economic Area or the United Kingdom, whenever we transfer your data outside of Europe/the UK we will either: (a) ensure that the country is deemed adequate by the European Commission; (b) put in place Standard Contractual Clauses or (c) implement appropriate safeguards approved by the European Commission to ensure an adequate level of protection in compliance with applicable data protection laws. You have a right to request details about the appropriate safeguard where this is documented (but it may be redacted to ensure confidentiality). 

 

SECURITY 

We take the protection of your Personal Data seriously. We implement appropriate measures and take steps to protect Personal Data against loss and theft as well as unauthorized access, disclosure, copying, use, and modification using security safeguards, including physical, organizational and technological measures, commensurate with the sensitivity of your Personal Data. Our employees who have access to your Personal Data are made aware of the importance of keeping it confidential. 

 

Where we use service providers who might have access to your Personal Data, we require them to have privacy and security standards that are comparable to ours. We use contracts and other measures with our service providers to maintain the confidentiality and security of your Personal Data and to prevent it from being used for any other purpose. 

 

Please be aware that no data security measures can guarantee complete security. You also should take steps to protect against unauthorized access to your phone, other mobile device, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, relying on two-factor authentication, and keeping your log-in and password private. 

 

HOW LONG DO WE KEEP THE PERSONAL DATA WE COLLECT? 

We keep your Personal Data for as long as it is required for the purposes for which it was collected, or as otherwise permitted by applicable law, after which we delete or de-identify your Personal Data, rendering it Non-Personal Data. 

 

In general, we retain your Personal Data for a period of time corresponding to a statute of limitations setting out the period during which legal claims may be filed in court. For example, we’ll retain your Personal Data during the statute of limitations period, to maintain an accurate record of your dealings with us and, as applicable, assert or defend against a legal claim. We automatically delete data where an account has been inactive (e.g. no messages sent, etc.) for 12 months. As a general rule, we will hold purchase information for 6 months past account deletion to ensure that we can deal with any chargeback/payment penalties. However, in some circumstances, we may retain Personal Data for other periods of time; for instance, where we are required to do so in accordance with legal, tax and accounting requirements, or if required to do so by a legal process, legal authority, or other governmental entity having authority to make the request or demand, for so long as required. 

 

CHILDREN 

The Platform(s) and Services are not for use by individuals under the age of 18 years old. Accordingly, we do not knowingly collect, store, access, use or disclose the Personal Data of individuals under 18 years old. If you are under the age of 18 years, please do not use the Services or provide any Personal Data, even if prompted by the website to do so. 

 

YOUR RIGHTS 

You have the ability to exercise the following rights: 

 

Right to Withdraw Consent. 

 

You have the right to withdraw your consent at any time, subject to legal and contractual restrictions. For example, if you wish to opt out of receiving electronic marketing communications, communications that suggest matches to you, or other types of non-transactional communications, you can change your settings in your account on the website (via the “Notifications” section under “Settings”) or in a mobile application (via the “Contact Options” section), use the ‘unsubscribe’ or ‘email preferences’ link provided in our emails, or otherwise contact us directly (see Section 15, below) and we will stop sending you electronic marketing and/or other non-transactional communications per your instructions. For greater clarification, “transactional communications” include but are not limited to such things as welcome emails, billing information, payment receipts, payment cancellation, password reset instructions, advisory emails about safeguarding your security and privacy, and confirmation of account deactivation. Note that if you wish to stop receiving transactional communications, you will have to delete your account as these communications are necessary to provide you with the Services. 

 

Right of Access, Rectification and Erasure. 

 

You have the right to request access to and obtain a copy of any of your Personal Data that we may hold, to request correction of any inaccurate data relating to you, and to request the deletion of your Personal Data under certain circumstances. Please note that you can hide certain information visible to members of the Platform(s) at any time by going to the “Profile” and “Settings” sections in your account on the website, or the “Profile Options” section in your account in the mobile applications. 

 

Data Portability. 

 

Where the Personal Data is Processed by automatic means, you have the right to receive all such Personal Data which you have provided us in a structured, commonly used and machine-readable format, and also to require us to transmit it to another controller where this is technically feasible. 

 

Right to Restriction of Processing. 

 

You have the right to restrict our Processing of your Personal Data (meaning we could only store it, unless we have your consent or as otherwise required by law) where: 

 

you contest the accuracy of the Personal Data, until we have taken sufficient steps to correct or verify its accuracy; 

 

where we no longer need your Personal Data for the purposes of the Processing, but you require such Personal Data for the purposes of a dispute, complaint or proceeding. 

 

Right to object to direct marketing (including profiling). 

 

You have the right to object to our use of your Personal Data (including profiling) for direct marketing purposes, such as when we use your Personal Data to inform you of our promotions or those of third parties. 

 

You also have the right to lodge a complaint with the privacy commissioner with jurisdiction over your place of residence if you consider that the Processing of your Personal Data infringes applicable law (although we ask you to try resolve any complaints with us first). 

 

If you would like to exercise any of these rights, please contact us using the contact information provided in Section 15, below. 

 

COOKIES AND OTHER TRACKING 

Where we have necessary permissions and consents in accordance with jurisdictional laws, we use cookies, clear GIFs, third-party analytics and other tracking mechanisms to track your use of our Platform(s) and the Services. As you use our sites or mobile applications, these tracking mechanisms may collect information automatically, such as: your IP address, browser type and operating system; web pages you view; links you click; how you move through the Services and the length of time you use the Services, or particular features or pages of the Services; and the referring URL, or the webpage that led you to our Platform(s). We may combine this information with other Personal Data we collect about you for statistical purposes, for measuring effectiveness of advertising, for fraud detection and in order to assist our customer service representatives in responding to your inquiries. 

 

Provided we have obtained necessary permissions and consents in accordance with jurisdictional laws, we use these tools only to provide you with a more personalized member experience, to better understand your needs and preferences, to provide you with content (including advertising and marketing emails) that is most relevant to you, and to monitor trends respecting the usage of our site and mobile applications. 

 

Do-Not-Track. Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies). 

 

Cookies. Cookies are small text files that are placed on your computer’s hard drive, through your web browser, for record-keeping purposes. We might use cookies to uniquely identify your browser/device/IP address, in order to help us to process your transactions and requests, to track aggregate and statistical information about member activity, and to display advertising both on our Platform(s) and on third-party sites. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. If you disable cookies some features of our Platform(s) may not function. Further information may be found at www.allaboutcookies.org. It is important to note that some cookies (including some persistent cookies) may be created by your web browser, rather than by us, so you would need to deal with your web browser’s settings to prevent or delete those, as we would have no control over them. For additional information, please see our Cookie Policy. 

 

Clear GIFs. Clear GIFs (a.k.a. web beacons, web bugs or pixel tags) are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, though, clear GIFs are embedded invisibly on web pages, not stored on your hard drive. These “images” automatically are loaded to your browser/device when you visit our website or open an html format email message from us, thereby letting us know if a certain page was visited or an email message was opened. Clear GIFs allow us to record simple member actions related to our websites and to email communications received from us, in order to help us determine the usage and effectiveness of our site and communications. We might use clear GIFs to track the activities of our website visitors and members, and our mobile application members, to help us manage content and compile statistics about usage. We and our third-party service providers also might use clear GIFs in HTML e-mails to our customers, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded. These may be blocked by using a third-party application (look for a browser extension for content-filtering, including ad-blocking) or, in the case of emails, by changing your settings to prevent images from being downloaded (where your email provider supports this functionality). 

 

Third-Party Analytics. We also may use automated devices and applications, such as Google Analytics (to opt out, go here), AppsFlyer (to opt out, go here) and Dynatrace to evaluate usage of our Platform(s) and the Services we provide. We may use these tools to obtain aggregated statistical information about the use of our Services to help us improve our Services, performance and member experiences. These analytics providers may use cookies and other technologies to perform their services, and may combine the information that they collect about you on our Platform(s) with other information that they have collected about you from your use of other sites. This Privacy Policy does not cover the collection, storage, access, use and disclosure of the tracking data collected by third-party analytics providers. For further information, please see the relevant party’s privacy policy. For a list of additional third0party analytics providers we may be using from time to time, please go here. 

 

Third-Party Ad Networks. We may use third parties such as network advertisers to serve advertisements on our Platform(s) and on third-party websites or other media, and to evaluate the success of our advertising campaigns. This would enable us and these third parties to target your browser with advertisements for products and services in which you might be interested, based on inferences made from browser activity. Third-party ad network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs), and other tracking technologies to measure the effectiveness of their ads and to personalize advertising content to you. These third-party cookies and other technologies are governed by each third party’s specific privacy policy, not this one. In some situations, we may provide these third-party advertisers with limited information about members (e.g., IP address and basic demographic information, solely for the purpose of reconciling payments for third-party advertising), but we would not disclose details such as your name or contact information. You may be able to avoid targeted ads by certain ad networks by blocking cookies (see your browser’s “Help” menu for information on how to do this); however, our Platform(s) may not work if you block or disable cookies. For a list of network advertisers we may be using from time to time, please go here. 

 

reCAPTCHA. We may use the reCAPTCHA service provided by Google Inc. (“Google”) to protect your entries via internet submission forms on this site. This plugin checks if you are a person, in order to prevent certain website functions from being abused by spam bots. This plugin query includes the sending of the IP address and possibly other data required by Google for the Google reCAPTCHA service. For this purpose, your input will be communicated to and used by Google. However, your IP address is previously truncated by Google within member states of the EEA or in other states which are party to the agreement on the European Economic Area and is, as such, anonymized. Only in exceptional cases is a full IP address transmitted to a Google server in the USA and truncated there. On behalf of the operator of this website, Google will use this information to evaluate your use of this service. The IP address provided by reCAPTCHA from your browser shall not be merged with any other data from Google. This data collection is subject to the data protection regulations of Google. For more information about Google’s privacy policy, please go here. By using the reCAPTCHA service, you consent to the processing of data about you by Google in the manner and for the purposes set forth above. 

 

Third-Party Links. Our Services may contain links to third-party websites. When you leave our websites and use a third-party website, that third-party website may collect your IP address and other Personal Data, in accordance with its own privacy policy. Any access to and use of such linked websites, and any Personal Data collected in connection therewith, is not governed by this Privacy Policy but, rather, by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites. 

 

DIRECT MARKETING 

Where we have necessary permissions and consents in accordance with jurisdictional laws: (a) we will send you marketing information about our Platform(s) and our Services, and about other products and services we, our affiliates and/or third parties offer, where we legitimately believe this may be of interest to you; and, (b) this content will be personalized. Where you have specifically requested marketing information from us (which may be about us, our affiliates and/or third parties) or have expressly indicated that you would like to receive details about special offers, we also will send promotional offers (which may be related to our Services or about services offered by our affiliates and/or third parties). 

 

Depending on your marketing preferences, marketing may be carried out by email, push notifications or other electronic channels. If you change your mind, you can choose to unsubscribe from receiving these marketing communications. You can do this by clicking the ‘unsubscribe’ or ‘email preferences’ link in any of our emails, via the “Notifications” section under “Settings” in your account on the website, via the “Contact Options” section in your account in a mobile application, or by contacting us (see Section 15, below). 

 

PROFILING 

We use Personal Data that you provide in your member profile combined with certain algorithms and machine-based learning to improve our Platforms’ search functions and to present profiles to you which are more likely to be of interest, in particular based on the demographic data of individuals with whom you interact in order to present more profiles of other similar members. You can elect to change your preferences at any time in your profile. This does not amount to “automated decision making” which would have any significant impact on you. 

 

ACCESS AND UPDATES 

You have the opportunity to: (i) opt out of certain communications; (ii) modify/update Personal Data you have provided to us; and, (iii) hide certain information visible to members of the Platform(s), at any time by going to the “Profile” and “Settings” sections in your account on the website, or to the “Profile Options” and “Contact Options” sections in your account in the mobile applications. 

 

Please be aware that there may be a short delay for any custom changes you make to take effect on the public areas of the system. Please also note that changing or deleting your information through the “Profile” or “Settings” sections in your account on the website or the “Profile Options” section in your account in the mobile applications, or opting out of email notifications sent by us, only will change the data in our database for the purpose of future activities and communications. 

 

Subject to certain restrictions required or permitted by law, you have the right to access Personal Data we hold about you and to have any concerns you may have about our policies and practices addressed. In addition, you have the right to obtain information regarding our policies and practices as they relate to the collection, storage, access use and disclosure of Personal Data, including with respect to the transfer and storage of your information outside your home jurisdiction, and to request updates to, or correction of, your Personal Data. 

 

CONTACT US 

If you have any questions or concerns regarding our policies and practices related to your Personal Data, please contact our Data Protection Officer/Chief Privacy Officer at dpo@sneakydating.com, or by writing to us as follows: 

 

If you are a Canadian or USA resident 

‍the Carefree Group 

Attn: Chief Privacy Officer 

100 Easy Street 

Carefree, AZ 85377 

 

 

For all inquiries which do not relate to privacy issues or concerns, please contact us using our Contact Form. 

 

We aim to resolve all complaints promptly. For residents of the European Economic Area, if you are not satisfied with any resolutions proposed, or if you have concerns with Processing of data, you may contact your local data protection authority, a list of which is found here. 

 

IMPORTANT ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS 

This section provides information for California residents. Pursuant to California privacy laws, including the California Consumer Privacy Act (“CCPA”), we provide California residents information about how we collect and otherwise Process your Personal Information. 

 

Categories of Personal Information that We Collect, Disclose, and Sell 

 

We collect and Process the same Personal Data of California residents as of other members throughout the world, for the purposes of allowing you to use our Services. This information is set forth in Sections 2-5 of this Privacy Policy. For a California-specific explanation of the categories of Personal Data we collect and how we use that Personal Data, please refer to the chart below. 

 

Personal Information of California Residents: Categories Collected, Processed, Shared with Third Parties 

 

* We may disclose any of the following information if required by law (e.g., in response to a police investigation or a subpoena). 

 

NAME, CONTACT INFORMATION AND IDENTIFIERS: 

 

Identifiers such as name, nickname, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, username, passwords. 

 

Do we collect? YES 

 

Do we disclose for business purposes? YES 

 

Do we sell your Personal Data? NO 

 

Sold or Disclosed for a business or commercial purpose in the prior 12 months? 

We may disclose this information to our payment processors for the following business purposes: 

 

To prevent credit card fraud 

 

To respond to chargeback claims 

 

To process customer refund inquiries 

 

We may use one’s IP address for fraud detection and data security. 

 

We may disclose information contained in your member-facing profile – including your username – to a third-party vendor for the purpose of assisting our moderators in finding activity that contravenes our Code of Conduct. 

CUSTOMER RECORDS: 

 

Paper and electronic customer records containing personal information, such as name, physical characteristics or description, address, telephone number, bank account number, credit card number. 

 

Do we collect? YES 

 

Do we disclose for business purposes? YES 

 

Do we sell your Personal Data? NO 

 

Sold or Disclosed for a business or commercial purpose in the prior 12 months? 

We may disclose this information to our payment processors for the following business purposes: 

 

To prevent credit card fraud 

 

To respond to chargeback claims 

 

To process customer refund inquiries 

 

We may disclose a single account identifier – which will not be enough, on its own, to identify you – to certain third-party affiliates, for fraud detection purposes. 

 

We may disclose information contained in your member-facing profile – including descriptors of yourself – to a third-party vendor for the purpose of assisting our moderators in finding activity that contravenes our Code of Conduct. 

 

PROTECTED CLASSIFICATIONS: 

 

Characteristics of protected classifications under California or federal law, such as race, sex, and age. 

 

Do we collect? YES 

 

Do we disclose for business purposes? YES 

 

Do we sell your Personal Data? NO 

 

Sold or Disclosed for a business or commercial purpose in the prior 12 months? 

We may disclose aggregate data about age groups/range segment conversion data to certain performance marketing campaigns to confirm payment-qualifying transactions. 

 

Members must identify their gender in order to use the Services and for the purpose of being presented with profiles of other members 

 

Members may choose to provide other information, such as their race, to better describe themselves to other members of the Services. 

 

We may disclose information contained in your member-facing profile – including descriptors of yourself – to a third-party vendor for the purpose of assisting our moderators in finding activity that contravenes our Code of Conduct. 

 

PURCHASE HISTORY AND TENDENCIES: 

 

Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. 

 

Do we collect? YES 

 

Do we disclose for business purposes? YES 

 

Do we sell your Personal Data? NO 

 

Sold or Disclosed for a business or commercial purpose in the prior 12 months? 

We may disclose this information to our payment processors for the following business purposes: 

 

To prevent credit card fraud 

 

To respond to chargeback claims 

 

To process customer refund inquiries 

 

BIOMETRIC INFORMATION* 

‍ 

 

Do we collect? NO 

 

Do we disclose for business purposes? NO 

 

Do we sell your Personal Data? NO 

 

Sold or Disclosed for a business or commercial purpose in the prior 12 months? NO 

USAGE DATA: 

 

Internet or other electronic network activity information such as usage of services, and information regarding a resident’s interaction with an internet website, mobile application, or advertisement. 

 

Do we collect? YES 

 

Do we disclose for business purposes? YES 

 

Do we sell your Personal Data? NO 

 

Sold or Disclosed for a business or commercial purpose in the prior 12 months? 

We may disclose this information to our payment processors for the following business purposes: 

 

To prevent credit card fraud 

 

To respond to chargeback claims 

 

To process customer refund inquiries 

 

GEOLOCATION DATA: 

 

City of residence. 

 

Do we collect? YES 

 

Do we disclose for business purposes? NO 

 

Do we sell your Personal Data? NO 

 

Sold or Disclosed for a business or commercial purpose in the prior 12 months? NO 

AUDIO/VISUAL: 

 

Audio, electronic, visual, thermal, olfactory, or similar information. 

 

Do we collect? NO 

 

Do we disclose for business purposes? NO 

 

Do we sell your Personal Data? NO 

 

Sold or Disclosed for a business or commercial purpose in the prior 12 months? NO 

EMPLOYMENT HISTORY: 

 

Professional or employment-related information. 

 

Do we collect? NO 

 

Do we disclose for business purposes? NO 

 

Do we sell your Personal Data? NO 

 

Sold or Disclosed for a business or commercial purpose in the prior 12 months? NO 

EDUCATION INFORMATION: 

 

 

Do we collect? NO 

 

Do we disclose for business purposes? NO 

 

Do we sell your Personal Data? NO 

 

Sold or Disclosed for a business or commercial purpose in the prior 12 months? NO 

PROFILES AND INFERENCES: 

 

Inferences drawn from any of the information identified above to create a profile about a resident reflecting the resident’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. 

 

Do we collect? YES 

 

Do we disclose for business purposes? NO 

 

Do we sell your Personal Data? NO 

 

Sold or Disclosed for a business or commercial purpose in the prior 12 months? 

No, but information you include in your profile will be visible to other members of the Platform(s) (as contemplated in this Privacy Policy). 

 

*Photographs are not deemed to be biometric data. However, in some jurisdictions (more every day), the reviewing of photographs by Artificial Intelligence (“AI”) for facial recognition purposes is deemed to be use of biometric data. We do NOT use AI for facial recognition purposes but would like our members to be aware that we do use AI, to some extent, to scan images for inappropriate content (e.g., to look for photos that appear to be of minors). 

 

If you would like to exercise any of these rights, please contact us using the contact information provided in Section 15. 

‍ 

 

California Residents’ Rights 

 

California law grants California residents certain rights and imposes restrictions on particular business practices as set forth below. 

 

Do-Not-Sell. We do not sell your Personal Data. 

 

Verifiable Requests for Copy, Deletion and Right to Know. Subject to certain exceptions, California residents have the right to make the following requests, at no charge, up to twice every 12 months: 

 

Right of Deletion: California residents have the right to request deletion of their Personal Data that we have collected about them, subject to certain exemptions, and to have such Personal Data deleted, except where necessary for specific purposes exempt under the law. 

 

Right to a Copy: California residents have the right to request a copy of the specific pieces of Personal Data that we have collected about them in the prior 12 months and to have this delivered, free of charge, either: (a) by mail; or (b) electronically in a portable and, to the extent technically feasible, readily useable format that allows the individual to transmit this information to another entity without hindrance. 

 

Right to Know: California residents have the right to request that we provide them certain information about how we have handled their personal information in the prior 12 months, including the: 

categories of Personal Data collected; 

 

categories of sources of Personal Data; 

 

business and/or commercial purposes for collecting and/or selling their Personal Data; 

 

categories of third parties with whom we have disclosed or shared their Personal Data; 

 

categories of Personal Data that we have disclosed or shared with a third party for a business purpose; and 

 

categories of third parties to whom the resident’s Personal Data has been sold and the specific categories of Personal Data sold to each category of third party. 

 

Submitting Requests. Requests to exercise the right of deletion, the right to a copy, and / or the right to know may be submitted by using the Contact Form. We will respond to verifiable requests received from California consumers as required by law. 

 

Incentives and Discrimination. The CCPA prohibits discrimination against California residents for exercising their rights under the CCPA and imposes requirements on any financial incentives offered to California residents related to their personal information. We respect your privacy rights. We do not discriminate against residents who exercise their rights under the CCPA. 

 

California Privacy Rights under California’s Shine-the-Light Law 

 

Under California’s “Shine the Light” law (Cal. Civ. Code §1798.83), California residents who provide us certain Personal Data are entitled to request and obtain from us, free of charge, information about the Personal Data (if any) we have shared with third parties for their own direct marketing use. Such requests may be made once per calendar year for information about any relevant third-party sharing in the prior calendar year. California residents who would like to make such a request may submit a request in writing (see Section 15 for ways to reach us). 

 

Precedence of English Version of this Privacy Policy 

The official text of this Privacy Policy shall be in the English language, and any translation, interpretation or construction of this Privacy Policy shall be based thereon. If any documents or notices relating to this Privacy Policy are translated into another language, the English version shall be controlling in the event of any discrepancy between the two (except to the extent that the law in your jurisdiction forbids this provision).