Privacy policy

Wematchmake Privacy Policy

PRIVACY POLICY

This Agreement was last revised on April 16th, 2023.

DUE TO THE WAR IN UKRAIN, WEMATCHMAKE WILL PAUSE SERVICES TO RUSSIA AND ITS TERRITORIES. WEMATCHMAKE WILL CONTINUE TO ACTIVELY MONITOR THE SUITUATION CLOSLY AND WILL UPDATE OUR PRIVACY POLICY ONCE THE SUITUATIOIN CHANGES IN UKRAIN.

This Privacy Policy discloses the privacy practices of Wematchmake Of Next com Data Processing Ltd., (“Wematchmake,” "wematchmake.com," “us,” “our,” or “we”) with respect to your information collected, stored, disclosed and used by Wematchmake, its subsidiaries and corporate affiliates, through our Services, including our Websites and Applications (as defined in the Terms and Conditions of Service or Agreement).

YOUR USE OF OUR SERVICES IS SUBJECT TO THIS PRIVACY POLICY AND THE APPLICABLE TERMS AND CONDITIONS OF SERVICE. BY USING OUR SERVICES, YOU ARE ACCEPTING THE PRACTICES SET OUT IN THIS PRIVACY POLICY AND THE APPLICABLE TERMS AND CONDITIONS OF SERVICE. If we decide to change our Privacy Policy, we will post those changes to this page and any other places we deem appropriate so that you are aware of what personal information we collect, how we use it, and under what circumstances, if any, we disclose it.

We reserve the right to modify this Privacy Policy at any time, so please review it frequently. If we make material changes to this Privacy Policy, we will notify you here, or by other means, such as e-mail, at our discretion. Your continued use of any portion of our Services following the posting of the updated Privacy Policy will constitute your acceptance of the changes.

This Policy applies when you use our services through our websites linked to this Policy, as well as our products and applications (including our mobile applications, downloadable products and applications and pages operated by us on social networking sites and other platforms) (collectively, the “Services”).

We may choose or be required by law to provide different or additional disclosures relating to the processing of personal information about residents of certain countries, regions or states. Please refer below for disclosures that may be applicable to you:

1. IMPORTANT INFORMATION AND WHO WE ARE

2. THE DATA WE COLLECT ABOUT YOU AND HOW IT IS COLLECTED

3. HOW WE USE YOUR PERSONAL DATA

4. DISCLOSURES OF YOUR PERSONAL DATA

5. CONTACT US

6. MISCELLANEOUS

1. IMPORTANT DETAILS AND WHO WE ARE

1. WHO WE ARE AND OUR ROLE

This Policy is issued on behalf of Nextcom Data Processing Ltd. (“Wematchmake” ) and any affiliated entities (“Wematchmake.com”), so when we mention “Wematchmake”, “we”, “us” or “our” in this Policy, we are referring to Wematchmake / Wematchmake.com responsible for processing your data. The Wematchmake is the controller and primarily responsible for the Services.

AGE RESTRICTIONS

We restrict the use of our Services to individuals age 18 and above. We do not intentionally collect or maintain personal data from children under the age of 18. If you become aware that personal data about a person under 18 has been provided to us, please immediately contact us using the details below.

THIRD-PARTY CONTENT AND LINKS

The Services may include content or links from third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU AND HOW IT IS COLLECTED

When we use the term “personal data” or “personal information” in this Policy, we mean information that identifies, relates to, describes, is reasonably capable of being associated with or could reasonably be linked, directly or indirectly, to you. It does not include aggregated or deidentified information that is maintained in a form that is not reasonably capable of being associated with or linked to you.

WHAT WE COLLECT AND HOW

We may collect, use, store and transfer different kinds of personal data about you that we have categorized as follows:

a. Information You Provide. When you register, use or subscribe to any of our Services or take part in any interactive features of the Services (such as any contests, games, promotions, quizzes, surveys, research or other services or features), we may collect a variety of information, including:

i. Contact Information such as your name, email address, phone number, and address (“Contact Information”); and

ii. Sensitive Information such as race, ethnicity, sexual preferences and experiences, political affiliation, religious affiliation, union memberships, or any biometric information you provide through the use of our Services (your “Sensitive Personal Data”).

iii. Other Information such as birth date, videos, password, billing information, credit card information, demographic information, place of work or education, your personal interests and background, gender, age, dating age range preference, physical characteristics, personal description, life experiences, geographic location, your photos and any information derived from them, and any other information you share with the Services. We may collect billing or payments information if you engage with a paid Service.

b. Information About How You Use the Services. We may automatically collect information about your participation and actions on the Services. This may include information such as the pages and profiles you view, how you browse the Services, dating insights, your Wematchmake Wecoin balance and purchases you make through the Services such as boosts and gifts. It can also include the various functions and features that you use, the connections you make, other friends or contacts you invite to the Services and profile searches you perform or your use of our applications.

c. Information and Content You Upload. When you upload photos, videos or other content to the Services, we may collect information about the content, such as the time, date and place the photo or content was taken or uploaded (also known as metadata), and how you use them, who views them or with whom you share them. We may also scan, monitor, store and analyze the photos, videos and other content you provide to us using third party services for several purposes, including for anti-fraud purposes, for the assessment of whether the photos are consistent with our Terms of Use, to help identify your interests and activities—such as if your photo includes pets, sports or trips—and to help us provide better matches for you. To share photos and videos, we may request to access your device camera roll and camera with your permission.

d. Information Automatically Collected. When you access our Services, we and our third party partners automatically record information from your device and its software, such as your IP address, browser type, Internet service provider, platform type, the site from which you came and the site to which you are going when you leave our website, date and time stamp and one or more cookies that may uniquely identify your browser or your account. When you access our Services using a mobile device, we may also receive or collect identification numbers associated with your device (such as a unique device ID, IDFA, Google AdID), device type, model and manufacturer, mobile device operating system brand and model, mobile carrier, phone number, email address, and other apps that you have downloaded. We also collect information about your usage of, and activity on, our Services, including internet navigation details (for example, how your mouse moves on a screen which tells us if you’re a bot or real person). This information is typically collected through a variety of tracking technologies, including cookies, web beacons, embedded scripts, location-identifying technologies, file information and similar technology. You can find out more about our use of cookies and similar technologies in our Cookie Policy.

e. Cookies and Similar Technologies. We and our third party partners may use cookies and similar technologies, including those from third parties, to collect, analyze and store information, to provide customized advertising on our site and applications and on other sites or applications, to provide and improve the Services or other products or services offered by us, and to identify and prevent fraudulent activities. You can find out more about our use of cookies and similar technologies in our Cookie Policy.

f. Your Communications with Us and Other Users. We collect communications you send to us (such as emails), comments that you post on the pages we have on a third-party service, such as our Instagram, Twitter, Facebook, Pinterest, Tumblr, and YouTube pages and messages that you send us directly through those services. We may also collect and analyze any comments, photos, messages or other content or communications you and other users share on the Services or send to each other, including through in-app messages, chat or other functionalities.

g. Third-Party Social Networking Sites You Connect to the Services. When you have enabled the use of our Services through a third-party social networking site or mobile or other application such as Facebook, Google or Twitter (a “Social Networking Site”) or connect or link our Services to a Social Networking Site, you permit us to access and use certain information about you that is made available to us through or from that Social Networking Site. The information obtained by us varies by Social Networking Site and may be affected by the permission and privacy settings you establish at that Social Networking Site, but can include information such as your name, profile picture, public Facebook profile, network, gender, username, user ID, age range or birthday, place of work, relationship interests, language, location, country, interests, photos, photos you are tagged in, videos, contacts list, friends lists or followers and other information such as information about Facebook friends you might share in common with other members of the Services. By using or linking our Services through or with a Social Networking Site, you are authorizing us to collect, store, retain and use, in accordance with this Policy, any and all of your information that we have obtained from the Social Networking Site, including to create a profile page and account for you. Depending on the Social Networking Site and your privacy settings, we may also post information to your Social Networking Site. Your agreement to the foregoing takes place when you “accept” or “allow” or “go to” (or other similar terms, such as tapping “Okay”) our application from a Social Networking Site, when you go to a Social Networking Site from the Services, when you sign up or login to the Services through a Social Networking Site (such as by tapping “Sign up with Facebook” or “Log in with Facebook” on the Services), when you otherwise connect or link your Social Networking Site to our Services or when you transfer information to us from such site. If there is information about your “friends” or people you are associated with in your Social Networking Site account, the information we obtain about those persons may also depend on the privacy settings such people have with the applicable Social Networking Site. You acknowledge and agree that we are not responsible for, and have no control over, any applicable privacy settings on any Social Networking Sites (including any settings related to any messages or advertisements about us that the Social Networking Site may send to you or your friends). You should always review, and if necessary, adjust your privacy settings on Social Networking Sites before getting or using applications such as ours or linking or connecting your Social Networking Site account to the Services.

h. Location Data. We collect information about your location through GPS, Wi-Fi, wireless network triangulation, or other methods in order to obtain your location for the purposes of providing our Services. We may also approximate your location by your IP Address. In some cases, we assign the latitude and longitude of the center of a city or state on record for you to your profile as a way to improve our analytics and matches for you.

i. Social Networks Through Your Interactions. When you interact with our Services through various social media networks, such as when you “Like” us on Facebook or when you follow us or share our content on Facebook, Twitter, LinkedIn, Instagram or other social networks, we may receive some information about you that you permit the social network to share with third parties. The data we receive is dependent upon your privacy settings with the social network. You should always review and, if necessary, adjust your privacy settings on third-party websites and social media networks and services before linking or connecting them to our Services.

j. Information Provided by Wematchmake. We may receive information about you from other companies and affiliates in Wematchmake, so that information you provide may be used by us to provide you the Services, communicate with you or provide you advertisements or other personalized content.

k. Information Provided by Others. We may be provided with information relating to you or your conduct on the Services by other users of the Services. For example, we will collect your email address if another user tries to refer us to you. We also collect information that third-party organizations may provide to us, such as contact details, demographic information, credit reference or fraud prevention information. Financial institutions or payment processors may also provide us updated payment information or payment methods related to your paid account or paid subscription and services.

l. Address Book. We may also offer you the ability to import your address book contacts from your mobile device with your permission or to manually enter email addresses so that you can (i) locate your contacts on the Services or other products or services offered by us; or (ii) invite your contacts to join you on the Services or other products or services offered by us. We will store those contacts for purposes of alerting you when your contacts join the Services or other products or services offered by us at a later time, so that you may connect with them on our platform, and to suggest friends and connections to other members of the Services or other products or services offered by us.

We also collect, use and share aggregated, deidentified and/or anonymous data (“Aggregated Data”) for any purpose. Examples include aggregated statistical or demographic data or data provided in hashed, non-human readable form. For example, we may aggregate your usage data on how you use the Services (“Usage Data”) to calculate the percentage of users accessing a specific website feature. Aggregated Data may be derived from your personal data but does not directly or indirectly identify you and therefore does not amount to personal data.

CROSS DEVICE TRACKING

If you log in to your account with us using multiple devices (for instance, your phone and laptop), we will link your devices to your account. This allows us to provide a seamless user experience to you. We also work with third parties to employ technologies, including the application of statistical modelling tools, which attempt to recognize you across multiple devices so that we understand how you use our Service across various devices, to ensure the safety and security of your data and the Wematchmake Services, to show you targeted advertising (with your consent) tailored to your interests and experience, and to measure the performance of advertising campaigns.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where you do not provide the personal data detailed in this Policy, we may not be able to provide you with the Services.

3. HOW WE USE YOUR PERSONAL DATA

Generally, we will use your personal data in the following circumstances:

- To process your registration on our services, including verifying your information to ensure its accuracy and validity.

- To fulfill your purchases (e.g., to process credit card payments and all other forms of payment method in connection with your transaction) and fulfill your requests (e.g., to provide you with information that you request).

- To personalize your experience and customize content on our Wematchmake relevant to your interests, including but not limited to targeted offers and ads through our website, email, social media channels, third-party sites or on other devices you may use.

- To operate, maintain and provide to you the features and functionality of the Services.

- To send you important information regarding the Services, such as certain changes to our terms, conditions, policies and/or other administrative information. Because this information may be material to your use of the services, you may not opt out of receiving such communications.

- To inform you of products, programs, services, and promotions that we believe may be of interest to you, including, without limitation, adding you to our email/mailing lists and permitting you to participate in sweepstakes, contests and similar promotions.

- To help maintain the safety, security and integrity of our service, technology assets and business.

- For our internal business purposes, such as data analysis, customer research, audits, fraud prevention, developing new products and/or features, enhancing the Services, improving our services, identifying usage trends and determining the effectiveness of our promotional campaigns, including to inform our machine learning for purposes such as user engagement.

- Where we need to perform the contract we are about to enter into or have entered into with you for the Services.

- Where you have given consent for us to use your personal data and your sensitive personal data to provide certain Services (you may withdraw your consent for some uses of the data at any time by contacting us at the information provided below).

- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

- Where we need to comply with a legal or regulatory obligation, such as to respond to law enforcement requests and as required by applicable law, court order or governmental regulations and enforce our corporate reporting obligations and our Terms of Use here or to comply with applicable laws.

- For purposes disclosed at the time you provide your personal data or as otherwise set forth in this Policy.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so.

Purpose/Activity -: To register you as a new member

Type of data -: (a) Profile Data, such as name, age, sexual orientation, marital status, number of children, and location (b) Contact Data such as email address, phone number, or social media user account, as limited by your privacy settings (c) Data from Social Networking Sites (If you use Facebook or Google to log-in to Wematchmake Services), including any interests or other data imported from your Social Networking Sites (d) Technical Data, such as device ID or IP Address, including timestamps

Lawful basis for processing including basis of legitimate interest -: (a) Performance of a contract with you (b) With your consent in the case of sensitive personal data

Purpose/Activity -: To provide Wematchmake Services to you, including: (a) Maintaining a profile, answering questions, and providing information about yourself; (b) Analysing your personal data to match you with other users; (c) Allowing you to communicate with other users of our platform to make a match; and (d) Enabling you to purchase subscriptions and premium add-ons to enhance your opportunities to make a match with other users of our platform.

Type of data -: (a) Profile Data, such as name, age, sexual orientation, race, marital status, number of children, and location (b) Contact Data such as email address, phone number, or social media user account (c) Data from Social Networking Sites (If you use Facebook or Google to log-in to Wematchmake Services), including any interests or other data imported from your Social Networking Sites (d) Transaction Data, including, if applicable depending on your payment mechanism, your credit card, expiration date, name, address, transaction ID, timestamps, email address, bank account, and routing number (e) Communications Data, including the content of messages, the name and ID of the recipients of the communications, the timestamp, IP address and/or Device ID of the parties to the messages (f) Photos, including various analytics and scoring results (g) Usage Data (h) Analytics and other scores used to make matches with other users of our platform (i) Technical Data

Lawful basis for processing including basis of legitimate interest -: (a) Performance of a contract with you (b) With your consent (with regard to your Sensitive Personal Data)

Purpose/Activity -: To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Communicating with you

Type of data -: (a) Profile Data (b) Transaction Data (c) Contact Data (d) Communications Data (e) Photos (f) Usage Data

Lawful basis for processing including basis of legitimate interest -: (a) Performance of a contract with you (b) Necessary to comply with a legal obligation

Purpose/Activity -: To enable you to partake in a prize draw, competition or complete a survey

Type of data -: (a) Profile Data (b) Contact Data (c) Usage Data (d) Any information, content, or submissions required as set forth in the contest rules when published

Lawful basis for processing including basis of legitimate interest-: (a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

Purpose/Activity -: To administer and protect our business, Wematchmake Services, this website and your personal data (including security, fraud, troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Type of data -: (a) Profile Data (b) Contact Data (c) Technical Data (d) Usage Data (e) Communications Data (f) Third Party Data provided to us by trusted partners, including proprietary scores, red flags, demographic information, usage data, and other information used to determine whether a Wematchmake account is being used improperly, accessed by an unauthorized third party, or represents a security or fraud risk to our community

Lawful basis for processing including basis of legitimate interest-: (a) Necessary for our legitimate interests (for running our business, providing administration and IT services, cybersecurity, preventing fraud and in the context of a business reorganization or group restructuring exercise) (b) Necessary to comply with a legal obligation

Purpose/Activity -: To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

Type of data -: (a) Device ID (b) IP Address (c) Location (at country, state, city, or postal code level) (d) Gender (e) Age (f) Technical Data such as OS version, hardware type, software type. (g) Cookies, pixels, or advertising tags (h) Usage Data

Lawful basis for processing including basis of legitimate interest -: (a) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) (b) With your consent for targeted advertising and profiling to serve more accurate advertising content to you.

Purpose/Activity -: To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

Type of data -: (a) Profile Data (b) Usage Data (c) Technical Data (d) Communications Data

Lawful basis for processing including basis of legitimate interest -: Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

Purpose/Activity -: To respond to requests from law enforcement

Type of data -: (a) Profile Data (b) Transaction Data (c) Usage Data (d) Communications Data (e) Location Data (at country, state, city, or postal code level) (f) Technical Data (g) Any other information we are compelled to provide by law

Lawful basis for processing including basis of legitimate interest -: Necessary to comply with our legal obligations

MARKETING

Where you have interacted with us, we will send you marketing communications from time to time. If you do not want to receive such marketing communications, you have the opportunity to inform us.

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You may choose to opt out of receiving marketing communications from us at any time by going into your account settings.

When you receive communications from us, including marketing communications, we may share your personal data with third party companies who help us conduct marketing activities. For example, we may use a third party to help us send email messages to you and help us understand how you have interacted with that email.

CHANGE OF PURPOSE

We will generally only use your personal data for the purposes for which we collected it. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. 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. DISCLOSURES OF YOUR PERSONAL DATA

Our Services allow you to share information about yourself with other individuals and other companies, including other users and potential users of the Services or other products or services offered by us and third-party Social Networking Sites. Consider your own privacy and personal safety when sharing your information with anyone, including information you share through your profile, as profiles include basic information that was provided at registration and information provided through a Social Networking Site and may include other information added by you or your friends (for example, your religion, ethnicity and physical characteristics), as well as information about your use of the Service (for example, whether you were recently logged in to our platform). Please review our Online Dating Tips for tips in using our Services.

Information on your profile is viewable by other users or visitors to our Services, and may also be viewable through public search or on third-party sites that you use. We do not control who reads the information you share or what others may do with this information, so we encourage you to use discretion and caution with respect to your personal data. Also, when sharing information about others, please consider their safety and privacy and get their consent for that sharing.

We may also share your personal data with the parties set out below for the purposes in the table above.

- With our parent company, Nextcom Data Processing Ltd. and other affiliates within Wematchmake.com (which includes any affiliates and subsidiaries of Nextcom Data Processing Ltd.) in order to provide you with the Services.

- Services Providers, consultants and other vendors who perform functions or services on our behalf and under our instructions to make our Services available to you, including infrastructure partners, customer support service providers, marketing outreach and analytics service providers, safety check providers, payment providers, cybersecurity partners, anti-fraud analytics companies, payment providers, chargeback representation services and similar partners.

- Advertising networks and technology companies, including Google, Facebook and Twitter, and companies that measure advertising performance and attribution. We share personal data with advertising networks or permit these networks to collect information from you directly on our websites to facilitate online advertising, such as search engines and social network advertising providers, to serve targeted ads to you or to groups of other users who share similar traits, such as likely commercial interests and demographics, on third-party platforms. For more information, including how to opt out of interest-based advertising, please read our Cookie Policy.

- Promotional partners with whom we partner to provide contests and sweepstakes or other joint promotional activities. These partners will usually be identified in the contest rules or promotional materials.

- Social Networks, to the extent applicable, such as Facebook and Google, where you have given permission to do so or where you have used your social network account to log in to our platform. If you have chosen to do this, your data will be governed by the privacy policy of that social network.

- The public when you provide feedback or post user content on our Services (e.g., if you post a product review on our website or comment on our social media sites), your information (e.g., your first name and comments) may be displayed on our websites or on our social media pages. When you engage with us on social media, we may tag your social media account or the social media account of others (e.g., to give photo credit to another user).

- To, in our discretion, (i) satisfy any applicable law, regulation, subpoena/court order, legal process or other government request, (ii) enforce our Terms of Use Agreement, including the investigation of potential violations thereof, (iii) investigate and defend ourselves against any third party claims or allegations, (iv) protect against harm to the rights, property or safety of Wematchmake, its users or the public as required or permitted by law and (v) detect, prevent or otherwise address criminal (including fraud or stalking), security or technical issues.

- In connection with any Wematchmake transaction, such as a merger, sale of assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by another company or third party or in the event of bankruptcy, dissolution, divestiture or any related or similar proceedings.

- With your consent or at your direction. In addition to the sharing described in this Policy, we may share information about you with third parties whenever you consent to or direct such sharing.

We may also share Aggregated Data with third parties.

5. CONTACT US

Email: info@wematchmake.com

6. MISCELLANEOUS

This Policy does not create rights enforceable by third parties or require disclosure of any personal data relating to users of the Service.

We reserve the right to modify this Policy from time to time. If we make changes to this Policy, we will change the “Last Revision” date below and will post the updated Policy on this page.

The language of this Policy is English. Where we have provided a translation of the English version of this Policy, you agree that the translation is provided for your convenience only and that the English language version of this Policy will govern your relationship with us. If there is any contradiction between what the English language version of this Policy says and what a translation says, then the English language version will take precedence.

This Agreement was last revised on April 16th, 2023.