(Last Updated October 30th, 2020)
LoveLifePartners.com (the Website) is owned and operated by SimplySophisticated Lda, NIF 516078640, a Portuguese registered limited company.
SimplySophisticated Lda is committed to protecting user privacy. We understand that visitors and users of the Website are concerned about their privacy, and the confidentiality and security of any Personal Data that is provided.
Our contact details are:
Online contact form: Click here.
Post: SimplySophisticated Lda, Rua Tenente Valadim 57, 3E, 2750-502 Cascais, Portugal.
(c) Your consent
Contrary to many sites, we ethically believe we do not need to have your full name to provide our high-quality services to you. Therefore, we do not collect it thus decreasing potential risk or hacking and cross-referencing data. This way we can provide a much higher level of confidentiality over your personal data.
However, when registering for our services you are required to provide otherwise truthful and accurate information about you.
1.3 Collection of data
(a) All users
Whenever you (including non-member users) visit our Website, our servers automatically record information for statistical purposes about your usage of the Website such as:
(i) the type of browser used;
(ii) the referring URL;
(iii) the IP address;
(iv) the number and type of pages viewed;
(v) the date and time of visits; and
(vi) the exit URL.
This information we collect about you is not Personal Data and, in any event, remains anonymous. We do not link the anonymous information to any other Personal Data unless you have either registered as a member or logged on as a member at the time of use. Accordingly, if you have not identified yourself on the Website, such as by registering as a member or logging on as a member, we will not link a record of your usage of our Website to you personally.
Upon your registration as a member we collect information about you to provide you with the full benefits of membership. We collect non-identifying information as well as Personal Data from you directly when you first register, and from time to time thereafter if you provide us with additional information.
Personal Data which may be collected by us includes (please note that, for further confidentiality and ethical reasons, we do not collect, contrary to other sites, your full name, your residential address or your phone number):
(i) your email address;
(ii) a photograph of you;
(iii) your birthdate;
(iv) your occupation;
(v) a description of your appearance;
(vi) your credit card and billing information (if provided by you).
For legal compliance and to properly enable you to utilize our services, we may also collect certain Special Category Personal Data including:
(i) your gender;
(ii) your marital status;
(iii) your main sexual orientation;
(iv) some details about your kids (if you have any) and related aspirations for the future;
(v) your religious beliefs or affiliations;
(vi) your phenotype or ethnic origin;
(vii) how you live today;
(viii) details indirectly linked to your health such as height, weight, diet preferences, smoking and drinking habits;
(ix) your annual income range;
(x) your net debt/wealth range;
(xi) your willingness to relocate to another country;
(xii) your expectations about a long-lasting relationship or about your dream lifetime partner, future wife or husband;
(xiii) your dislikes.
(c) Cookies and other tracking technologies
Our Website uses Google Analytics and Google Tag Manager, services which transmits website traffic data to Google servers in the United States. We may use reports provided by Google Analytics to help us understand website traffic and web page usage. You may however customize or opt out of Google Analytics for Display Advertising using the Ads Settings for your Google account.
(i) Google Marketing Platform integrations;
(ii) Demographic and Interest Reporting;
(iii) Display Advertising including Remarketing and Google Display Network Impression Reporting to advertise our services online;
(iv) optimizing and personalizing ad services based on your past visits to our Website; and
(v) reporting the use of ad services and interactions with ad impressions and how they are related to visits to our site.
Cookies and other tracking technologies may also be used to support analytics by other third parties.
(d) Third party interactions
We may allow third parties, including authorized service providers, advertising companies, data management platforms, and ad networks to serve advertisements on our Websites.
These companies may use tracking technologies (such as cookies, pixel tags, web beacons, device IDs, or advertising IDs) to collect information about users who view or interact with their advertisements. Any information that these third parties collect via cookies is completely anonymous and is non-identifiable.
You may refuse the use of third-party data collection by selecting the appropriate settings on your browser.
(e) Social media
1.4 Purposes of collecting, holding, using and disclosing Personal Data
(a) Collect from you only
Where it is reasonable or practical to do so we will only collect Personal Data about you from you directly.
(b) Purposes of collecting Personal Data
We will only collect Personal Data that is reasonably necessary for:
(i) enabling us to process your application for membership and enabling us to provide services to you (including creating your publicly viewable profile, allowing members to search for suitable members and providing mechanisms for communication between members);
(ii) our internal research and statistical purposes (including market segmentation and customer value analysis);
(iii) enabling us to forward to you other information or material which we believe may be of interest to you;
(iv) enabling a payment processor to process payments that you make to us; and
(the "Primary Purpose").
(c) Use and disclosure of Personal Data
Use of Personal Data for the Primary Purpose will include the use of Personal Data in automated decision-making processes.
We will only use or disclose Personal Data about you for a purpose other than the Primary Purpose (being a "Secondary Purpose") where the following apply:
(i) the Secondary Purpose is related to the Primary Purpose and, if the Personal Data is Special Category Personal Data, the Secondary Purpose is directly related to the Primary Purpose; and
(ii) you would reasonably expect us to use or disclose the Personal Data for the Secondary Purpose; or
(iii) you have consented to the use or disclosure for the Secondary Purpose; or
(iv) the use or disclosure of the Personal Data is required or authorized under law, regulation, or court order.
In order to promote our products and services to you, we may also provide a hash of your email address (and no other Personal Data) to third parties, such as Facebook, in order to better target our advertising to you, by using products such as Facebook's Custom Audiences.
A comparison of your hashed email address will only be for the purpose of promoting our goods and services to you and will not be used by that third-party for any other purpose. The comparison of the hash of your email address will not be used to identify you or your email address, and no further information about you will be provided by us to that third party.
(d) Holding of Personal Data
We will use best practice processes and take all reasonable steps to protect Personal Data that we hold from:
(i) misuse, interference, and loss; and
(ii) unauthorized access, modification, or disclosure.
In the unlikely event that there is a serious data breach that is likely to result in a risk to your rights and freedoms, we will without undue delay notify the appropriate supervisory authority in your jurisdiction. Where there is a high risk that a serious data breach will impact upon your rights and freedoms, we will also notify you of that breach.
(e) Overseas disclosures
Any profile information that you have provided to us will be publicly viewable on your profile, irrespective of the location of the viewer. By creating a profile you acknowledge that overseas recipients will be able to view your profile.
In order to provide customer support, perform back office functions, perform fraud prevention tasks, or provide services to you we may need to allow our staff or suppliers (who may be located or whose resources may be located other than your country of residence) to access your profile information, billing information or other Personal Data that you have supplied.
In all other circumstances we will only disclose Personal Data to a Third-Party Country recipient or International Organization if the disclosure of the information is required or authorized by law, regulation or court order.
(f) Unsolicited information
(g) Information not confidential
Any material or information provided by you for inclusion in any member profile will be treated as non-confidential and non-proprietary. We may use such material or information without restriction within the scope of our Company. Any such material or information provided by you will be made available for other members or users of the Website to read.
We reserve the right to send electronic mail to you regarding recommended profile matches, notification alerts of activity such as interest alerts or message alerts, promotions or offers, changes or additions to our services.
1.5 Destruction of Personal Data
We will keep your Personal Data only for as long as we need it for legitimate business purposes and as required by applicable law. We will take reasonable steps to erase any Personal Data that we hold about you, where:
(i) we no longer need the Personal Data for the purposes for which it was collected, and we are not otherwise entitled to retain such data; and
(ii) we are not required or obligated by law, regulation, or court order to retain the information.
1.6 Access, correction, and portability
(a) Access to Personal Data
We will provide you with access upon request to the Personal Data held by us in relation to you except to the extent that:
(i) giving access would be unlawful; or
(ii) denying access is required or authorized by or under a relevant law, regulation or court order.
Following your request, we will contact you within one (1) month from the date of receipt of your request and provide you with the Personal Data requested, unless we have determined that some reason or obligation exists requiring us to withhold access to the Personal Data.
(b) Third-party disclosure
(c) Data portability
Insofar as it does not adversely affect the rights and freedoms of others and where you have communicated a request to us:
(i) where we have employed an automated means to process your Personal Data, we will provide you with a copy of such Personal Data in a structured, commonly used, and machine-readable format; and
(ii) after receiving your request, where technically feasible, we will transmit your personal data directly to another data holder.
(d) Commercially sensitive information
Where providing you access to your Personal Data would reveal commercially sensitive information, we are unable to give you access to that information. However, we will provide you with the reasoning behind our determination.
(e) Use of intermediaries
Where we cannot directly provide you with access to your Personal Data we may, if it is reasonable, engage the services of an intermediary to do so.
(f) Correction and erasure of Personal Data
It is your responsibility to ensure that the information you provide to us is accurate and to update your Personal Data as necessary. If for any reason you are unable to correct any Personal Data held by us, please contact us using the details provided in clause 1.1(b).
If after receiving your request we choose not to correct your information, we will notify you within one month of the reason of our refusal and the mechanisms available to you to object to our refusal.
(g) Refusal to correct or erase
If at any time we refuse or deny you access to your Personal Data, or refuse to correct or erase your Personal Data, we will provide you with reasons for such denial or refusal.
(h) Restriction of processing
You may request that we limit or restrict the manner in which we deal with and process your Personal Data, in which case we will only process your Personal Data: with your consent; for the establishment, exercise or defence of legal claims against us; or for the protection of the rights of another person.
Access to, erasure and rectification of your Personal Data, including any communications related thereto, will generally be provided free of charge.
Where your requests are manifestly unfounded or excessive in nature (particularly due to repetitiveness) we may charge you a reasonable fee for providing the information or communication, or taking the action requested. Where your requests are manifestly unfounded or excessive in nature, we may also refuse your request.
(j) Specific objection rights
If it becomes necessary for us to process your Personal Data without your consent for reasons of:
(i) performing a task in the public interest;
(ii) the exercise of an official authority that has been vested in us; or
(iii) where it is in our legitimate interests or the legitimate interests of a third party to do so;
you will have the right to object to such use.
If you object to our use of your Personal Data we will refrain from using your Personal Data unless compelling legitimate grounds exist for us to use that Personal Data, or for the establishment, exercise or defence of legal claims.
Upon receiving an objection, we will, as soon as is reasonably practical, cease using your Personal Data for the purposes of direct marketing.
(a) Making a complaint
(b) Our response
Within 30 days of receipt of your complaint we will notify you in writing as to what action we propose to take in relation to your complaint and will provide you with details of what further action you can take if you are not satisfied with our response.
"General Data Protection Regulation" and "GDPR" mean Regulation (EU) 2016/679 of The European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC.
"International Organization" means an organization and its subordinate bodies governed by public international law, or any other body which is set up by, or on the basis of, an agreement between two or more countries.
"Personal Data" means any information relating to an identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person and includes Special Category Personal Data.
"Processing" means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
"Special Category Personal Data" means personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, criminal record, genetic and biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning your sex life or sexual orientation.
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