Privacy Policy

Who we are

Whindr is operated by Whindr Limited, a company registered at Kyjská 264/24 Praha 14 - Hloubětín 19800. Company number follows soon.

What information does Whindr process

Whindr is a meeting place for adults, and we provide that service by operating a social network site offering users the opportunity to connect to our global community of users and also Interacting wit our Entertainment profiles (for further Information see our Terms and Conditions). By joining Whindr, you enter a legal agreement with us and we process your data in order to provide your service under the terms of that agreement. You can only become a member of Whindr or use its features if you’re aged 18 or over or the age of majority in the country in which you reside if that happens to be greater than 18.

To join the Whindr network you will have to complete our online registration form, where we may ask you to provide us with information about you such as your name, your email address, your gender, your date of birth, your location details. You also have the opportunity to provide other details about yourself, but these are optional. Because you control your user profile, these details are available to you at any time by accessing your “Profile” page, which gives you the chance to correct or update (other than your email address and gender) your information at any time by just logging in to Whindr. You can contact Whindrs Support Service in your Matches to change the gender on your profile and/or email address. Please be careful about posting sensitive details about yourself on your Profile such as your religious denomination and health details. While you may voluntarily provide this information to us when you create your Profile, including your sexual preferences and ethnic background, there is no requirement to do so. Please remember that photographs or any video clips that you post on Whindr may reveal these kinds of sensitive personal data. Where you do upload and choose to tell us sensitive data about yourself, you are explicitly consenting to our processing your information and making this public to other users.

For safety and security and to ensure you have the best possible user experience, we require users to verify their accounts and might ask for your phone number. We want to make sure you are not a robot! And we also want to avoid fake Whindr accounts not created by Whindr Limited, being created which can be used for malicious activities and cyber crime – they threaten the Whindr network and spoil things for everyone. We use a third party provider for account verification. We will keep your phone number when you add it to your profile. We collect and use your phone number on the basis of our legitimate interests identified above and for the prevention of fraud.

To prevent abuse of the app/site, Whindr uses automated decisions to block accounts as part of its anti-spam procedures. In order to do this, our systems check accounts and messages for content that indicates breaches of our Terms and Conditions of Use. If an account or message meets certain criteria that demonstrate that the Terms and Conditions of Use are likely to have been breached, the relevant account will automatically be blocked. All users of accounts that have been blocked will be notified that their account has been blocked and affected users can contact Whindr to contest the decision.

Whindr also uses automated decisions to prevent fraudulent payment transactions being processed as part of its anti-fraud procedures. In order to do this, our systems check payment transactions for behaviour that indicates breaches of our Terms and Conditions of Use. If a transaction meets certain criteria that demonstrate that the Terms and Conditions of Use are likely to have been breached and the transaction is likely to be fraudulent, the relevant transaction may automatically be blocked. Where a transaction is blocked, the user will be notified that their transaction cannot be processed and affected users can contact Whindr to contest the decision.

Please note that if your account is blocked, any account(s) that you have on our other group platforms/applications may also be blocked as part of our anti-spam and anti-fraud procedures.

If you decide to purchase any of our premium services, we will process your payment information and retain this securely for the prevention of fraud and for audit/tax purposes. Under data protection law, it is necessary for us to collect and process this payment data to enable us to perform our contract with you and our ongoing retention of this data is justified by our legitimate interests set out above.

To enable Whindr to provide a free non-premium service, we process some limited data (demographics and location) to drive targeted advertising in our legitimate interest including sharing such data with advertising networks. We may also receive data indirectly from such advertising networks. You can stop this within Settings but you will still see adverts, though they will be less relevant to you. Through your device’s security settings you also have the option to prevent or limit device identifiers being shared with third party advertisers and what use is made of the device identifiers. If you would like more information about this practice and to know your choices about not having this information used by these companies, please visit this page. Finally, we want to keep in touch with you to make sure you know about the great promotions and offers we have available. If you’ve told us it’s OK, we will use your email address and phone number to send you information on these. You can withdraw this consent at any time via Settings in the app or website.

What does Whindr collect about me if I use the mobile App?

Whindr offers you the opportunity to stay in touch with the friends and contacts you’ve made no matter where you are. You can do this by using your mobile phone or by downloading an application to your desktop that allows you to share your location with other users.

When you use your mobile application, we will collect information about WiFi access points as well as other location information about your longitude and latitude. That information helps us identify your physical location so that it can be displayed and shared with other members choosing to view “nearby” posts.

If you have enabled location services, but wish to turn them off, you can do so by the following methods:

1. iPhone app — settings, privacy, location services, Whindr

2. Android — settings, location, Whindr, permissions, location

We, or our third-party advertising partners, may also collect and use your device identifier to serve relevant ads to you through the App. You can opt out of targeted advertising by (i) becoming a payer and/ or (ii) opting not to share data with any partner platforms but still to receive advertisements.

If you log in to or access Whindr through your Facebook profile, we may collect data including your email address, name and profile picture, date of birth, a list of your friends who also use the app, pages you have liked, location and photos in order to create and update your Whindr profile. You may also appear on your friends’ Facebook apps as a Whindr user.

What is the legal basis that allows Whindr to use my data?

We are only permitted to use your data when we have a lawful basis to do so. The table below provides an overview of the legal bases that Whindr relies on to use your data. Where the legal basis is consent, you can withdraw consent at any time. Where the legal basis is legitimate interests, you have a right to object to our use of your data. We explain in the relevant sections in this privacy notice how you can withdraw consent or opt-out of certain data uses (where applicable).

Purpose for which data is used

To provide you with the Whindr social networking service To facilitate networking opportunities on the Whindr site To verify your identity and prevent fraud and to ensure the safety and security of users To take payment for premium services To serve targeted advertisements to users of the site/app To send you marketing information about our offers and services To contact you in order to run surveys for research purposes and to obtain feedback To enable users to create their Whindr profile and log into the app via Facebook To show “nearby” location information to you and other users of the site/app To serve advertisements through the Whindr mobile app To provide the lookalikes function To carry out analysis to help us improve the app To respond to correspondence and queries that you submit to us To block accounts as part of our anti-spam procedures To block payment transactions as part of our anti-fraud procedures

Data

Name, email address, date of birth, location Optional information that you choose to provide in your profile, which may include information about your sexual preferences, religion, ethnic background, photos etc. Phone number Payment card details Demographic and location information Email address and mobile phone number Email address and mobile phone number Data from Facebook, including email address, name and profile picture, date of birth, friends who use the app, pages liked, location and photos Wifi access points and location data when you use the mobile app Device ID Photos and faceprint Log and usage data, including IP address, browser type, referring domain, pages accessed, mobile carrier and search terms Email address and IP address Email address, phone number, IP address and IP session information, social network ID, username, faceprint, user agent string Name, IP address, email address, mobile number, cardholder name, payments received, type of payment, user ID, country

Legal basis

Contractual necessity Consent Legitimate interests – it is in our legitimate interests to ensure that accounts are not set up fraudulently and to safeguard users of the site Contractual necessity and legitimate interests – we have a legitimate interest in receiving payment for our premium services Legitimate interests – it is in our legitimate interests to target advertisements so that users see relevant advertisements and to allow us to generate income from advertising revenue Legitimate interests – it is in our legitimate interests to promote our products and services Legitimate interests – it is in our legitimate interests to carry out research so that we can further develop the app and improve the service Legitimate interests – it is in our legitimate interests to promote our products and services Legitimate interests – it is in our legitimate interests to provide this functionality as part of the services Legitimate interests – it is in our legitimate interests and the interests of third party advertisers to deliver advertisements to you to promote their products Legitimate interests – it is in our legitimate interests to provide this functionality Legitimate interests – it is in our interests to analyse the way in which users are accessing and using our services so that we can further develop the app and improve the service Legitimate interests – it is in our legitimate interests to respond to your queries to ensure that we provide a good service to users and troubleshoot problems Legitimate interests – it is in our legitimate interests to prevent unauthorised behaviour and to maintain the safety and security of our services Legitimate interests – it is in our legitimate interests to prevent fraudulent transactions and to maintain the security of our services

How long will Whindr keep my data?

We keep your personal information only as long as we need it for legitimate business purposes (as set out above) and as permitted by applicable law.

In practice, we delete or anonymise your information upon deletion of your account (following the safety retention window), unless:

1. we must keep it to comply with applicable law (for instance, some “traffic data” is kept for one year to comply with statutory data retention obligations);

2. we must keep it to evidence our compliance with applicable law (for instance, records of consents to our Terms, Privacy Policy and other similar consents are kept for five years);

3. there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or

4. the information must be kept for our legitimate business interests, such as fraud prevention and enhancing users' safety and security. For example, information may need to be kept to prevent a user who was banned for unsafe behaviour or security incidents from opening a new account.

Where Whindr uses machine learning, for example, to help us detect and prevent fraudulent card transactions, and to detect and prevent spam communications on the App (as explained above), we may need to keep personal information for a longer period than the retention periods explained above, to enable the machine learning to work properly. Where this is the case, we always seek to minimise the amount of personal information that is used and we ensure that it is ring-fenced and kept securely from other user personal information. We regularly review the period for which personal information is required for machine learning purposes and delete any identifiable information when it is no longer required.

What information does Whindr collect about me if I’m under 18?

Whindr does not knowingly collect any information about or market to children, minors or anyone under the age of majority. If we become aware that a child, minor or anyone under the age of 18 has registered with us and provided us with personal data, we will take steps to terminate that person’s registration and delete their Profile information from Whindr. If we do delete a Profile because you violated our no children rules, we may retain your email and IP address to ensure that you do not try to get around our rules by creating a new Profile.

What information does Whindr collect about my friends and contacts?

You can choose to invite your friends to join Whindr to make sure that they also get the benefits of meeting new people. To make it easier to search and find friends and acquaintances on Whindr, users may search for other members by email address. If you want to invite your friends and contacts to Whindr, we will send an email invitation from Whindr in your name or you can send an SMS (if you use our Android or iPhone App) to your friends and contacts encouraging them to sign up to Whindr. If any of the individuals you have invited do not register within a few days, Whindr may occasionally send reminder emails on your behalf to those individuals. You can choose to invite all your friends or only a select few by simply unticking the names of those friends you do not wish to invite, but please remember you must not invite any children to join. You are responsible for ensuring that your friend has agreed to receiving a Whindr invite.

When you import your contacts, we store their name and email address or their mobile number so that we can automatically connect you and your friend. Whindr mayt sell these email addresses or mobile numbers or use them to send any other communication besides email invitations. The friend may contact Whindr to request the removal of their information from our database by contacting whindr support at info@whindr.com. Any such request will only apply to addresses or mobile numbers we have at the time of the request and not to any addresses or mobile numbers that the member/user provides to us later.

Who does Whindr share information with?

We may share aggregated information with such parties as Foursquare that includes your personal data (but which doesn’t identify you directly), together with other information including log data with third parties for industry analysis and demographic profiling and to deliver targeted advertising about other products and services.

We share your data with the following categories of third-parties:

1. Information technology companies (hardware and software) which provide services to support our products

2. Fraud prevention and anti-spam providers to protect the service from criminal activity

3. Moderators to monitor activity on the site/apps and approve content

4. Advertising partners, market places and providers of targeted advertising.

5. Law enforcement agencies, where we are required to by law or to protect the vital interests of a person

6. Payment processing and telecommunications companies to facilitate payments for our premium services

We ensure these parties must adhere to strict data protection and confidentiality provisions that are consistent with this Policy. Measures are taken to ensure that the data shared is non-attributable to the greatest extent possible.

In the event that Whindr or any of its affiliates undergoes a business transition or change of ownership, such as a merger, acquisition by another company, re-organisation, or sale of all or a portion of its assets, or in the event of insolvency or administration, we may be required to disclose your personal data.

Your data may be shared with other Whindr group companies, for example, to block accounts and suspected fraudulent payment transactions as part of our anti-spam and anti-fraud procedures.

Your rights

Under UK and EU law, you have the right to lodge a complaint with data protection regulators. Whindr has its main office in the UK and the Information Commissioners’ Office (ICO) is our lead regulator. You can find out how to raise a concern with the ICO by visiting their website at www.ico.org.uk. If you’re within the EU, you may also get in touch with your local Data Protection Regulator who may liaise with the ICO on your behalf.

You have a number of rights under European Data Protection law if you are an EU citizen.

1. Right to be informed: what personal data an organisation is processing and why (this notice).

2. Right of access: you can request a copy of your data.

3. Right of rectification: if the data held is inaccurate, you have the right to have it corrected.

4. Right to erasure: you have the right to have your data deleted in certain circumstances.

5. Right to restrict processing: in limited circumstances, you have the right to request that processing is stopped but the data retained.

6. Right to data portability: you can request a copy of your data in a machine-readable form that can be transferred to another provider.

7. Right to object: in certain circumstances (including where data is processed on the basis of legitimate interests or for the purposes of marketing) you may object to that processing.

8. Rights related to automated decision making including profiling: there are several rights in this area where processing carried out on a solely automated basis results in a decision which has legal or significant effects for the individual. In these circumstances your rights include the right to ensure that there is human intervention in the decision-making process.

If you want to exercise any of your rights listed above please visit our Feedback Page or email us at info@whindr.com.

How does Whindr protect my personal data?

Whindr has implemented appropriate security measures to protect and prevent the loss, misuse, and alteration of the information under our control, including your personal data. Our technical experts at Whindr work hard to ensure your secure use of our site.

While we take reasonable precautions against possible security breaches of our website, member database and records, no website or internet transmission is completely secure and we cannot guarantee that unauthorised access, hacking, data loss, or other breaches will never occur. We urge you to take steps to keep your personal data safe (including your password) and to log out of your account after use. If you lose your password or give it out, or another service provider that you use suffers a data breach and you have used the same credentials with that service provider as you have with Whindr, your personal data may be compromised. If that happens, please report it to Support via our Feedback page.

Where is my personal data kept?

We want you to be able to access Whindr wherever you happen to be in the world. To enable us to provide that service servers Czech Republic. The hardware is located in third-party data centres but is rented by Whindr. Data collected by advertising partners may also be held outside the European Economic Area. We ensure that the data is adequately protected by ensuring that valid, legal mechanisms are in place such as: EU approved model clauses (which can be found here), US privacy shield certification (more information can be found here); and implementing robust contractual standards. If you want more information relating to the nature of the safeguards we have in place please email info@whindr.com.

Does Whindr collect any other personal data about me?

If you contact our Customer Support team via Whindr support in your matches or email info@whindr.com. we will receive your email address, and may track your IP address as well as the information you send to us to help resolve your query. We will keep records of our communications with you, including any complaints that we receive from you about other users (and from other users about you) for 6 years after deletion of your account.

Does Whindr use my personal data for any other purpose?

We may use material that you post on the open access areas of Whindr in advertising and promotional materials on our partner sites and partner products. We believe these uses are in line with our legitimate interests in enabling us to improve our site and better tailor your online experience to meet your needs.

From time to time we may run surveys for research purposes and we may contact you to find out if you would like to take part. Such surveys are optional and more information will be provided at the point of contact. If you do not wish to be contacted to take part in a survey, please contact our Customer Support Team at info@whindr.com. We use your personal data to resolve disputes, troubleshoot problems and enforce our Terms and Conditions.

What are ‘cookies’ and what ‘cookies’ does Whindr use?

We collect information by placing cookies on your computer or mobile. A cookie is a piece of text stored on your computer or mobile by your web browser. They are basically a tool that stores information about website visits, recognises you and your preferences each time you visit Whindr, and ensures site functionality and enables us to provide the services our members request.

When you visit the publicly available sections of Whindr, a session ID cookie is placed on your computer that only lasts while you’re visiting. We also place persistent cookies (also known as local storage devices) on members’ computers, so that Whindr remembers them and makes their login experience faster and easier. We may use persistent tracking cookies on your mobile device, mainly for security protection purposes, such as to prevent phishers, scammers, unauthorised login attempts, and to help you access your hacked account. We do not use any information whilst you are logged off.

You may set your browser and your mobile settings to block cookies and local storage devices, but if you do so, you may not be able to access the features that Whindr offers.

Whindr´s use of cookies and local storage devices basically falls into the following categories:

- those that are strictly necessary to deliver the services and products you have requested, such as, for example purchasing Whindr Premium;

- cookies related to the performance of Whindr´s site, such as analytics that help us determine how our site is performing and ensure a smooth and trouble-free experience for our members and visitors;

- cookies related to the functionality of Whindr´s site, such as remembering your preferences at login or your preferred language or allowing you to chat, add photos and instant message Whindr members;

- third party cookies which link to other social networks and which you request via social plugins; and

- cookies used to improve and target advertising to you based on what’s relevant to you, to improve reporting on any advertising campaign and to avoid showing you ads you have already seen.

Whindr uses cookies and local storage devices so that we know who you are, what interests you and so that you can do the things online that you want to do, like chat with new people, share your content and buy Whindr Premium knowing that your data will be secure. Below is a table to explain Whindr´s cookie functions and why they’re used.

Cookie Functions

Analytics and research Authentication Security and site integrity Site features and services Performance Targeted advertising

Whindr uses Google Analytics to collect information about how visitors use the Whindr site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. For more information about Google’s privacy policy, please visit http://www.google.com/intl/en/policies/ These cookies help us to identify our members so that when you’re logged in, you can enjoy Whindr´s offerings, experiences and various features, such as uploading photographs, chatting and can localise your experience, such as when you’ve requested to view Whindr´s site in your local language or when you’ve asked Whindr to ‘remember me’. These cookies also help to remember who invited you to join Whindr. We use cookies and other devices, such as CAPTCHAs, to help keep Whindr and our members safe and secure. These cookies do things like protect Whindr users from spam and fraud, by ensuring the safety of your personal data when you shop on Whindr for things like Whindr Premium. We may use persistent cookies, which will help us to ensure we have identified the same device is logging in to the correct account. These types of cookies also help with our anti-spam measures and may help us to prevent phishers, scammers, unauthorised login attempts to your account and accessing any hacked accounts. These cookies and local storage devices provide the functionality that our Whindr members enjoy, such as uploading photographs, chats, instant messaging, your account settings and your request to have Whindr as your homepage or your search preference. We also use cookies to help provide experiences, such as links to other social media sites, social plugins and video content, including making it easier for you to share content between Whindr with your other favourite social networks. In some cases, the site feature you choose may allow a third party to place cookies or local storage devices on your computer. The third party who places cookies on your device is responsible for how they process their data and Whindr recommends that you read their privacy policies. Third parties who place cookies on your device when you use Whindr include, and we have included a link to their privacy policies: • Twitter, https://twitter.com/privacy • Facebook, https://en-gb.facebook.com/policy.php • YouTube, http://www.google.co.uk/intl/en/policies/privacy/ • AddThis, http://www.addthis.com/privacy We need to use certain cookies and local storage devices to ensure our members have the best possible experience, such as assisting with your navigation of our site, ensuring pages load up quickly and respond faster to your requests for Whindr services We sometimes conduct advertising campaigns using DoubleClick, a Google company, who will also place cookies. To find out about DoubleClick cookies and how to control those cookies, go to: https://policies.google.com/technologies/ads.

Our use of cookies and local share devices, including the specific cookie names, may change over time, but will generally fall into the above categories. We will notify you of any important changes to our use of cookies and local storage devices If you would like to know more about cookies, including flash cookies/local storage devices, the following websites provide useful information:

www.allaboutcookies.org

www.youronlinechoices.eu

http://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html

This Privacy Policy was last updated on 01.11.