PRIVACY POLICY
Effective Date: 1 December 2022

1. GENERAL PROVISIONS

  1. 1.1. This Privacy Policy explains how we collect, use, and share the information we collect on the secretspotdating website (www.secretspot.dating) (the "Site"). The Site is owned and operated by Company, a legal entity incorporated under the laws of Finland ("we," "us," "our"), who acts as the "Data Controller" of the personal data that Site visitors and users share with us or that we automatically collect when you visit or use the service provided through the Site (the "Services").
  2. 1.2. This Privacy Policy describes the methods and purposes of processing your personal data when you use our Services and applies to the processing of personal data obtained through your use of our Services.
  3. 1.3. This Privacy Policy is effective as of the date posted above. By using the Site and submitting information, you agree that we may use and disclose your information according to the terms of this Privacy Policy.

2. INFORMATION WE COLLECT

  1. 2.1. We collect information when you visit our Site, use our Services, or otherwise interact with us. This includes information you provide, information we receive from other sources, and information that we automatically collect (as discussed below).
  2. 2.2. "Personal Information" is information that directly or indirectly identifies you or another individual.
  3. 2.3. We collect the following information that you provide when you register and create an account on the Site and use our Services:
    • 2.3.1. Your full name, date, and place of birth
    • 2.3.2. Your photo
    • 2.3.3. Your bank or credit card details
    • 2.3.4. Your contact details, including your email address and phone number
    • 2.3.5. Your username and password
    • 2.3.6. Profile information you submit when creating your account
    • 2.3.7. Comments or communications you submit when using the Services
    • 2.3.8. Your browser and device information (including Internet Protocol (IP) address), attributes of your device such as resolution or OS version and browser, and information collected through cookies and other similar technologies.
  4. 2.4. We automatically collect the following information when you visit the Site or use the Services. We use common information-gathering tools, such as log files, cookies, web beacons, and similar technologies, to automatically collect information, which may contain Personal Information, from your computer or mobile device as you navigate our Site or interact with emails that we have sent you.
    • 2.4.1. The date and time of your visits to the Site
    • 2.4.2. User clicks, page views, field fills, banner and video impressions and views
    • 2.4.3. Data describing the audience segments
    • 2.4.4. Session parameters
    • 2.4.5. User ID stored in cookies.
  5. 2.5. We also collect information about you from other sources. We may use third-party service providers to assist in operating our business, such as payment processors, and these service providers may collect information directly from you. We may also collect information from other Site visitors who submit information or comments about you.

3. COOKIES AND TRACKING

  1. 3.1. We use cookies and similar technologies to collect aggregate (non-personal) information about Site usage by all of our visitors and to help us remember you and your preferences when you revisit the Site. These cookies may stay on your browser into the future until they expire or you delete them.
    We also use technologies to remember your preferences. As these technologies are strictly necessary for the Site to function, we do not need your consent to use them. These cookies are usually erased when you close your browser window. An explanation of cookies and similar technologies is set out below. Further general information about cookies and how they work is available at www.allaboutcookies.org.
  2. 3.2. Cookies: A cookie is a text file that websites send to a visitor's computer or other internet-connected device to uniquely identify the visitor's browser or to store information or settings in the browser. We use a variety of cookies, such as session, persistent, and analytics cookies, among others, to identify and authenticate visitors and to store information in your electronic shopping baskets so it can be retrieved later.
  3. 3.3. We may allow selected third parties to place cookies on your device through the Site to provide us with better insights into the use of the Site or user demographics or to provide relevant advertising to you. These third parties may collect information about a consumer's online activities over time and across different websites when he or she uses our website. We may also permit third-party service providers to place cookies through our Site to perform analytic or marketing functions such as Google Analytics. We do not control the use of such third-party cookies or the resulting information, and we are not responsible for any actions or policies of such third parties.
  4. 3.4. Web Beacons and Pixel Tags: We and our third-party service providers may use web beacons or pixel tags to control the automated collection of non-Personal Information. These small electronic tags on specific web pages on our Site help us monitor the activity on our Site to improve the performance of certain features and your shopping experience.
  5. 3.5. JavaScript: In order to collect the kinds of information described in this Privacy Policy and to see how you interact with our Site, we or third parties may use JavaScript or other languages to send instructions to your devices.
  6. 3.6. Do Not Track: Some browsers may provide a "Do Not Track" option, which signals to websites and web services that you do not wish to have your online activities tracked over time or across different websites. A "Do Not Track" option may also allow you to opt out of behavioral advertising. At this time, the Site neither responds to nor supports "Do Not Track" requests and will continue to collect information about your online activity as mentioned in this Privacy Policy, notwithstanding our receipt of such a signal or request.

4. HOW WE USE YOUR INFORMATION

  1. 4.1. We use the collected information for our general commercial purposes, such as improving our Site, growing our business, and offering our own or third-party products or services that we think you may find interesting. We use your contact information to respond to your inquiries or to provide information on products or Services to you.
  2. 4.2. The legal basis for processing your personal data is your consent to the processing of your personal data, contracts, and agreements with us. Where you have provided your consent for our processing of Personal Information, such consent may be withdrawn at any time.
  3. 4.3. Where your consent is not mandatory, we may process Personal Information on the following lawful bases:
    • 4.3.1. For the performance of a contract between you and us or to answer questions or take steps at your request prior to entering into a contract.
    • 4.3.2. As necessary for certain legitimate interests (including our business interests), provided such interests are not overridden by your interests or fundamental rights and freedoms, including ensuring the operation of the website, sending information and advertising messages to your email address;
    • 4.3.3. As necessary for our compliance with legal obligations to which we are subject (such as tax reporting and accounting processes).
  4. 4.4. We will process Personal Information for the following purposes as necessary for the performance of a contract or transaction between you and us or to answer questions or take steps at your request prior to entering into a contract:
    • 4.4.1. To administer or otherwise carry out our obligations in relation to any agreement to which we are a party;
    • 4.4.2. To assist you in completing a transaction or order;
    • 4.4.3. To prepare and process invoices or facilitate the preparation and processing of invoices by third parties;
    • 4.4.4. To respond to queries or requests and to provide the services and associated support;
    • 4.4.5. To provide customer relationship management;
    • 4.4.6. To create and manage our accounts;
    • 4.4.7. To notify you about changes to our services; and
    • 4.4.8. To send you routine customer service messages or information on updates.
    • 4.4.9. We will process Personal Information for the following purposes as necessary for certain legitimate interests, including:
    • 4.4.10. To offer our services to you in a personalized way;
    • 4.4.11. To send you personalized marketing communications where your consent is not required;
    • 4.4.12. To allow you to participate in questionnaires, contests, and surveys and benefit from personalized promotional offers;
    • 4.4.13. To monitor quality control and ensure compliance with any and all applicable laws, regulations, codes, and ordinances, for example, in response to a request from a court or regulatory body, where such request is made in accordance with the law;
    • 4.4.14. To resolve any disputes;
    • 4.4.15. As part of our efforts to keep our Site, services, and premises safe and secure;
    • 4.4.16. To ensure the security of your account and our business and to prevent or detect malicious activity or abuses of our Site and services, for example, by requesting verification information to reset your account password (if applicable);
    • 4.4.17. To administer our Site and services and for internal business administration and operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
    • 4.4.18. To create products or services that may meet your needs; and
    • 4.4.19. To develop and improve our products and services.
  5. 4.5. We will process Personal Information for the following purposes as necessary for our compliance with legal obligations to which we are subject, including:
    • 4.5.1. Preventing or detecting fraud; and
    • 4.5.2. Ensuring compliance with any applicable laws, regulations, codes, and ordinances, for example, in response to a binding request from a court or regulatory body, where such request is made in accordance with the law.
  6. 4.6. We do not anticipate routinely processing special categories of personal information. However, we may do so in certain circumstances, for example, where:
    • 4.6.1. You have included such information in any communications that you send us, in which case we will consider the provision of such information to constitute your express consent for us to process it; or
    • 4.6.2. Processing such personal data is strictly necessary in relation to a legal claim.

5. DATA RETENTION

  1. 5.1. We will store your Personal Information in a form that permits us to identify you for as long as necessary for the purpose for which the Personal Information is processed. We may retain and use your Personal Information as necessary to comply with our legal obligations, resolve disputes, enforce our agreements and rights, or if it is not technically reasonably feasible to remove it.

6. SECURITY

  1. 6.1. When processing Personal Information, we take reasonable physical, organizational, and technical measures to protect information from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution, as well as from other illegal activity.
  2. 6.2. The Site is run on software, hardware, and networks, any component of which may, from time to time, require maintenance or experience problems or breaches of security beyond our control.
  3. 6.3. You also play a role in protecting your information. You must maintain the security of your online transactions by not sharing your passwords and account information with any unauthorized parties. As a security measure, we encourage you to use a password for your account that is unique to our Site and not to use the same passwords for multiple online accounts. If we receive instructions using your log-in information, we will consider that you have authorized the instructions. Please also be aware that despite our best intentions and the guidelines outlined in this Privacy Policy, no data transmission over the Internet or encryption method can be guaranteed to be 100% secure. We cannot guarantee the security of any information you transmit to us or our Site, and therefore you use our Site at your own risk. Please also take care when sending us Personal Information by email as email communications are not secure.
  4. 6.4. In the unlikely event that we believe the security of your Personal Information in our control may have been compromised, we will try to notify you. To the extent you have provided us with your email address, we may notify you by email, and you agree to our use of email as a means of such notification. If you prefer for us to use another method to notify you in this situation, please contact us using the information under "Contacting us" below, with the alternative contact information you wish to be used.

7. DISCLOSING YOUR INFORMATION

  1. 7.1. We may reveal information about you to unaffiliated third parties:
    • 7.1.1. if you request or authorize it;
    • 7.1.2. if it is necessary to provide the information to complete a transaction for you;
    • 7.1.3. if the information is provided to comply with the law, applicable regulations, governmental and quasi-governmental requests, court orders or subpoenas, to enforce our Terms of Use or other agreements, or to protect our rights, property, or safety or the rights, property, or safety of our users or others (e.g., to a consumer reporting agency for fraud protection, etc.);
    • 7.1.4. if the disclosure is done as part of a restructure, purchase, transfer, or sale of services or assets (e.g., in the event that substantially all of our assets are acquired by another party, customer information may be one of the transferred assets);
    • 7.1.5. if the information is provided to our agents, outside vendors, or service providers to perform functions on our behalf (e.g., analyzing data, providing marketing assistance, providing customer service, processing orders, etc.);
    • 7.1.6. if the information is provided to our professional advisors (such as lawyers or accountants); or
    • 7.1.7. as otherwise described in this Privacy Policy.
  2. 7.2. We do not share your information with unaffiliated third parties for their marketing purposes.

8. RIGHTS OF EUROPEAN UNION RESIDENTS

  1. 8.1. European Union residents may have the right to receive information about our processing of their Personal Information.
  2. 8.2. They may have the right to require us to clarify this Personal Information, block or destroy it if it is incomplete, outdated, inaccurate, illegally obtained, or cannot be considered necessary for the stated purpose of processing, as well as to take measures provided for by law to protect their rights.
  3. 8.3. They may have the right to access their Personal Information, which may be restricted in accordance with federal laws, including if the access of the personal data subject to his personal data violates the rights and legitimate interests of third parties.
  4. 8.4. In order to exercise and protect their rights and legitimate interests, they may have the right to contact us. We process any requests and complaints from European Union residents respecting Personal Information, thoroughly investigate the facts of violations, and take all necessary measures to eliminate them immediately, punish the perpetrators, and resolve disputes and conflict situations in a pre-trial manner.
  5. 8.5. European Union residents may have the right to send us a revocation of their consent to the processing of personal data by email at contact@secretspot.dating. We have the right to process the personal data of such a subject within 30 days from the date of receipt of the review.

9. ACCESSING YOUR INFORMATION AND YOUR CHOICES

  1. 9.1. You can update, amend, or delete your information at any time by logging into your online account.
  2. 9.2. You can choose not to receive emails from us by "unsubscribing" using the instructions in any email you receive from us. This will not stop us from sending service emails about your account or your transactions with us.
  3. 9.3. You can choose to delete or block cookies by setting your browser to either reject all cookies or to allow cookies only from selected sites. If you block cookies, the performance of the Site may be impaired, and certain features may not function at all.

10. CHILDREN'S PRIVACY

  1. 10.1. This Site is not designed nor intended to be attractive to use by children under the age of 18. We do not knowingly collect information from children under the age of 18 and exercise best practices to prevent registration by children. If you are under 18, please do not submit any information to us. You must be at least 18 years of age to register an account or to use the Services available on the Site.

11. DATA PROCESSING AND CROSS-BORDER DATA TRANSFERS

  1. 11.1. Our Site is maintained on servers located in the United States, and Personal Information submitted is stored on our servers in the United States. If you are visiting our Site from outside the United States, please be advised that your information is transferred to our U.S. servers. Disclosing your Personal Information to us pursuant to this Privacy Policy is at your own risk. We strive to comply with laws of jurisdictions in which we maintain operations, but we make no representations that the practices described in this Privacy Policy are compliant with laws outside those jurisdictions that apply to the collection, security, use, and disclosure of Personal Information.
  2. 11.2. Under certain circumstances, we may have to transfer Personal Information subject to the GDPR or UK GDPR (as defined below) to countries outside of the EEA or UK and to entities located in jurisdictions that are not subject to an adequacy decision of the European Commission or UK Government. We will always ensure that we have a legal basis for such data transfer and ensure a relevant safeguard method is in place (e.g., standard contractual clauses, including necessary assessments and supplementary measures) or a derogation applies, so that your Personal Information is treated in a manner that is consistent with, and respects the UK, European, and other applicable laws and regulations on data protection. If you require further information about international data transfers, please send an email to contact@secretspot.dating.

12. NOTICES TO CALIFORNIA RESIDENTS

  1. 12.1. Your California Privacy Rights. California residents with an established business relationship with us are permitted by California law once a year to request information about the manner in which we shared certain categories of information with others for their marketing purposes during the prior calendar year. We do not share information with third parties for their direct marketing purposes.
  2. 12.2. California Privacy Rights Act Notice.
    • 12.2.1. At this time, we are not required to comply with the California Privacy Rights Act (CPRA). We will update this Privacy Policy when we qualify for coverage under the CPRA.

13. NOTICE TO NEVADA RESIDENTS

  1. 13.1. We do not transfer Personal Information for monetary consideration. If you would like to tell us not to sell your information in the future as well, please email us at contact@secretspot.dating with your name, postal address, telephone number, and email address with "Nevada do not sell" in the subject line.

14. NOTICE TO VIRGINIA, COLORADO, CONNECTICUT, AND UTAH RESIDENTS

  1. 14.1. We are currently not subject to the Colorado Privacy Act, the Connecticut Personal Data Privacy Act, the Utah Consumer Privacy Act, or the Virginia Consumer Data Protection Act. If we become subject to any of these laws in the future, we will update this Privacy Policy accordingly.

15. LINKS TO OTHER WEBSITES, APPLICATIONS, AND SERVICES

  1. 15.1. We may permit others to link to this Site or to post a link to their site on ours. We do not endorse these sites and are not responsible for other sites or their privacy practices. Please read their privacy policies before submitting information.

16. ACCESS TO THIS PRIVACY POLICY; CHANGES TO THE PRIVACY POLICY

  1. 16.1. You may access this Privacy Policy at any time by clicking the link at the bottom of each page of the Site.
  2. 16.2. We may amend this Privacy Policy to reflect changes in the legal or commercial landscape in which we operate. The Privacy Policy in effect at the time you use the Site governs how we may use your information. If we make material changes, we will post the revised version of this Privacy Policy and the revised effective date on this Site. Please check back here from time to time to review any changes.

17. CONTACTING US

  1. 17.1. This Site is owned and operated by Company in Finland, you can contact us by email at contact@secretspot.dating.