In simple terms, whilst you’re enjoying the FFWD mobile application (“App”), we collect some information about you. In addition, you may choose to use the App to share information with other FFWD users, including your friends and contacts (“Users”). We may also need to share your information sometimes. But we do not want you to worry about your privacy. We want you to enjoy using the App and focus on finding meaningful connections. Please leave the worrying about privacy to us. We at FFWD take your privacy very seriously and protecting the information you entrust us is our top priority.
If you have any questions or comments about this Policy, please feel free to contact us at firstname.lastname@example.org.
1. Collection of Information
Info You Provide Us
When you download the App and create an account (“Account”), we may collect certain background information (“Registration Information”) about you. Registration Information includes basic profile details and what type of people you would like to meet, as described below:
- When you create an account, you will provide certain login credentials, as well as some basic details necessary for the App to do its job, such as your phone number, gender and date of birth;
- As you complete your profile, you will have to upload photos and generate videos (“Scenes”) that will be uploaded and broadcast on the App. To add/generate such content, you may allow us to access your camera or photo album.
- You may also add to your profile certain other background information. Certain such information that you choose to provide us may be considered “special” or “sensitive” in certain jurisdictions, for example, your racial or ethnic origins, sexual orientation and religious beliefs. By choosing to provide this information, you consent to our processing of that information.
After you register, you will be able to review and make changes to this information at any time through your “Profile” page. You control your user profile and are able to correct or update (other than your email address, mobile number, date of birth (which will be updated on your birthday), gender and current location (which is automatically updated)) your information at any time.
Info We Receive From Others
We may also receive information about you from other sources, including:
- Other users may provide information about you as they use our services. For instance, we may collect information about you from other users if they contact us about you;
- You may be able to use your social media account (such as Facebook Login) to create and log into your FFWD account. This saves you from having to remember yet another user name and password and allows you to share some information from your social media account with the App.
- We may receive info about you from our partners, for instance where FFWD ads are published on a partner’s websites and platforms (in which case they may pass along details on a campaign’s success).
Info Collected When You Use the App
In addition, we collect information in connection with your use of the App’s functions, including:
- We collect information about your activity on our services, for instance how you use them (e.g., date and time you logged in, features you’ve been using, searches or search parameters, clicks and pages which have been shown to you, referring webpage address, advertising that you click on) and how you interact with other users (e.g., users you connect and interact with, time and date of your exchanges, number of messages you send and receive).
- We collect information from and about the device(s) you use to access our services, including hardware and software information such as IP address, device ID and type, device-specific and apps settings and characteristics, app crashes, advertising IDs (such as Google’s AAID and Apple’s IDFA, both of which are randomly generated numbers that you can reset by going into your device’ settings), browser type, version and language, operating system, time zones, identifiers associated with cookies or other technologies that may uniquely identify your device or browser (e.g., IMEI/UDID and MAC address); and information on your wireless and mobile network connection, like your service provider and signal strength.
If you give us permission by turning on the location services, when you use your mobile device, we will collect information about Wi-Fi access points as well as other location information about your longitude and latitude and may save your device’s coordinates to offer certain features to you. This information helps us identify your physical location and we may use it to personalize the App experience and make it easier for you to interact with other users, by enabling the information to be displayed and shared with other members who choose to view “nearby” posts.
If you have enabled location services, but wish to turn them off, you can do so in the settings of the App.
Log and Usage Data
We keep your personal information only as long as we need it for legitimate business purposes and as permitted by applicable law.
In practice, we delete or anonymize your information upon deletion of your account (following the safety retention window), unless:
- 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);
- there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or
- 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 behavior or security incidents from opening a new account.
We may collect information about your device when you use the App including the unique device identifier, device model, operating system, and MAC address.
We may keep track of how you interact with links available on the App including third-party services and clients by redirecting clicks or through other means. We may share aggregate click statistics such as how many times a particular link was clicked on.
These cookies are not the yummy kind, unfortunately. They are small data files that are stored onto your device based on sites or apps you access. They typically contain information about the source of the cookie, and if or when the cookie will expire. Cookies may also have information about your device, user settings, browsing history or activity.
Cookies store information about your website visits and can recognize you and your preferences each time you visit the FFWD website. The cookies we collect enable us to learn how people interact with the App, which in turn helps us make a better product for you!
We use the following types of cookies:
- Performance – We need to use certain cookies and save data to your local storage devices to ensure our members have the best possible experience. They assist with your navigation of our site, ensuring pages load quickly and respond promptly to your requests – no one likes snail pace technology!
If for any reason you decide that you do not want all of your FFWD activities to be stored you may set your browser and mobile settings to block cookies and local storage devices, but please remember that if you do so, you may not be able to access all of the features offers.
Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) have a “Do Not Track” (“DNT”) feature that tells a website that a user does not want to have his or her online activity tracked. If a website that responds to a DNT signal receives a DNT signal, the browser can block that website from collecting certain information about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many businesses, including Hinge, do not currently respond to DNT signals.
3. Use of Information
One of our main goals is to ensure your experience on the App is a pleasant one and makes you want to come back! In order to deliver an enjoyable experience to you, we may use your information to:
- administer your account and provide the services and features of the App;
- personalize the App and the content we deliver to you;
- improver the App’s features and services and develop new ones;
- provide any of our loyalty programs, send gifts or deliver merchandise;
- help you connect with other users (certain information about you may be used to make suggestions about your potential matches but you may have the option to not disclose such information);
- ensure a consistent experience across your devices;
- contact you with information about the App (including updates and new offerings);
- keep in touch with you to make sure you know about the great promotions and offers we have available;
- conduct research and analytics about how you use and interact with the App;
- resolve disputes between you and other users;
- address and resolve any query from you;
- investigate fraud, protect our legal rights, and to enforce our Terms;
- process your payment for our awesome premium features and retain this securely for the prevention of fraud and for audit/tax purposes; and
- to ensure legal compliance.
To process your information as described above, we rely on the following legal bases:
- Provide our service to you – Most of the time, the reason we process your information is to perform the contract that you have with us. For instance, as you go about using our service to build meaningful connections, we use your information to maintain your account and your profile, to make it viewable to other users and recommend other users to you.
- Legitimate interests – We may use your information where we have legitimate interests to do so. For instance, we analyze users’ behavior on our services to continuously improve our offerings, we suggest offers we think might interest you, and we process information for administrative, fraud detection and other legal purposes.
4. Disclosure of Information
Our policy is to not disclose your Registration Information, except in the below listed limited circumstances:
- According to Your Privacy Settings – We share your information with other people as per your privacy settings (and in the case of any sharing features available on the App, the individuals or apps with whom you may choose to share your information with) when you voluntarily disclose information on the App (including your public profile). Please be careful with your information and make sure that you are comfortable with the content that you share being publicly viewable since neither you nor we can control what others do with your information once you share it. If you choose to limit the audience for all or part of your profile or for certain content or information about you, then it will be visible according to your settings.
- Your Consent – If you consent, we may share or disclose your information, such as when you use a third-party web client or application to access your Account.
- Moderators – To monitor activity on the apps and approve content.
- Payment Processing and Telecommunications Companies – To facilitate payments for our premium services.
- Law and Harm – As we mentioned in the Terms, we think it is very important that all FFWD community members behave respectfully whilst using the App. We will cooperate with all third parties to enforce their intellectual property or other rights. We will also cooperate with law enforcement inquiries from within or outside your country of residence where we are required to by law or to protect the vital interests of a person. This may include preserving or disclosing any of your information, including your Registration Information, if we believe in good faith that it is necessary to comply with a law or regulation, or when we believe that disclosure is necessary to comply with a judicial proceeding, court order, or legal request; to protect the safety of any person; to address fraud, security or technical issues, e.g. through anti-spam providers to protect the service from criminal activity or to protect our rights or property or those of third parties. In such cases we may raise or waive any legal objection or right available to us. We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.
- Business Transactions – In the event that FFWD or any of our affiliates undergoes a business transition or change of ownership, such as a merger, acquisition by another company, re-organization, 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.
- Aggregated Information – We may share aggregated information with third parties that includes your personal data (but which doesn’t identify you directly) together with other information including log data for industry analysis and demographic profiling. You may opt-out of receiving marketing messages by using the opt-out mechanisms and links provided in each email.
- Express Consent – We may also ask for your consent to share your information with third parties. In any such instance, we will make it clear why we want to share the information.
5. Cross-border transfers
Sharing of information laid out in Section 4 sometimes involves cross-border data transfers, for instance to the United States of America and other jurisdictions. As an example, where the service allows users to be located in the European Economic Area (“EEA”), their personal information is transferred to countries outside of the EEA. We use standard contract clauses approved by the European Commission or other suitable safeguards to permit data transfers from the EEA to other countries. Standard contractual clauses are commitments between companies transferring personal data, binding them to protect the privacy and security of your data.
6. What others may see about you
Our community of users (you included) is amazing, and we want as many people as possible to experience this awesomeness! So we have built certain features to enable this. The App is designed to make it easier for you to connect with other Users and to interact with them.
When using the App, you should assume that anything you post or submit on the App may be publicly-viewable and accessible, both by Users of the App and non-users of the App. We want our users to be careful about posting information that will eventually be made public.
If you register or login to the App using your Facebook account, you are authorizing us to access certain Facebook account information, including information you make available via Facebook, your friends list, current location and those friends you have in common with other FFWD members.
You also understand that your FFWD profile and other information you make available via the App, including information you provide directly or indirectly through Facebook (i.e., your Facebook photos, your name, age, approximate location, friends you have in common with other Users and other profile information), may be viewed and shared by FFWD with individuals who may or may not be users or via third-party applications in such user’s discretion. For example, a user may recommend you as a match to his or her Facebook friends by sharing your picture, regardless of whether such friend(s) is also a user of the App.
You might share information like the photos, videos, and messages you send or upload and any metadata provided with those messages, along with any comments or information you provide in connection with your photos.
7. Modifying your registration info
You may access or modify the Registration Information you provided at any time or permanently delete your Account (that would be sad unless you have a really awesome reason to delete!)
When your Account is deactivated, we take reasonable efforts to make sure it is no longer viewable on the App. For up to 30 days it is still possible to restore your Account. Removed and deleted information may persist in backup copies for up to 30 days to enable restoration, but will not be available to others in the meantime (please see Section 10 of the Terms for further information on this). After 30 days, we begin the process of deleting your Account from our systems. We are not responsible for any information, pictures, comments, or other content that is deleted from our systems resulting from the deactivation of your Account.
To prevent abuse and/or misuse of the App by a user following termination or deletion of a profile/Account we shall retain such information as we deem in our sole discretion may be necessary to ensure that User does not open a new Account and profile in breach of our Terms and to ensure compliance with all laws and regulations.
Even after you remove information from your profile or delete your Account, copies of that information may still be viewable and/or accessed to the extent such information has been previously shared with others, or copied or stored by other users or to the extent such information has been shared with search engines. We cannot control this, nor do we accept any liability for this. If you have given third-party applications or websites access to your personal information, they may retain such information to the extent permitted under their terms of service or privacy policies.
8. Protecting your information
We make great efforts to taking commercially reasonable security measures to help protect your information against loss, misuse and unauthorized access, or disclosure. We use reasonable security measures to safeguard the confidentiality of your personal information.
We regularly monitor our systems for possible vulnerabilities and attacks and regularly review our information collection, storage and processing practices to update our physical, technical and organizational security measures.
Also, for safety and security and to ensure you have the best possible user experience, we require users to verify their accounts and ask for your phone number. That’s because we want to make sure you are not a robot! And we also want to avoid fake accounts being created which can be used for malicious activities and cybercrime – they threaten the FFWD community and spoil the experience for all of our awesome well-intentioned, phenomenal users. We use a third-party provider for account verification who will keep your phone number for up to 90 days for fraud identification purposes across a range of online platforms and services like the App.
To prevent abuse of our App and website, FFWD 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. If an account or message meets certain criteria that demonstrate that the Terms 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 FFWD to contest the decision.
Your Registration Information, such as your name and username, may be visible to the public on your profile page. You may elect to keep certain information (at any time) private by making the proper selection on your Profile.
We recommend and encourage you (and all other users) to think carefully about the information you disclose about yourself. We also do not recommend that you put email addresses, URLs, instant messaging details, phone numbers, full names or addresses, credit card details, national identity numbers, driver’s license details and other sensitive information on your profile, which is open to misuse and abuse.
We also ask that you be careful about posting sensitive personal information (such as religious denomination and health details) about yourself on your profile. While you may voluntarily provide certain personal information to us when you create your profile, you are not required to provide any such information beyond your birthdate, gender identity (which will be displayed only if you choose) and gender preference in your partner (which will also not be displayed). Please remember that photographs that you post and video that you record on the App may reveal information about yourself as well. When you do record and upload and choose to tell us sensitive information about yourself, you are explicitly consenting to our processing of your information and making this public to other users.
We may suspend your use of all or part of the services without notice if we suspect or detect any breach of security. If you believe that your account or information is no longer secure, please notify us immediately at email@example.com.
If you ever think someone has had access to your social media password, please report it to the relevant social media platform and change your password immediately. We cannot guarantee the security of your personal data while it is being transmitted to our site and any transmission is at your own risk.
You can stop all information collection by the App by uninstalling it using the standard uninstall process for your device. If you uninstall the App from your mobile device, the unique identifier associated with your device will continue to be stored. If you re-install the application on the same mobile device, we will be able to re-associate this identifier to your previous transactions and activities.
As with all technology companies, although we take steps to secure your information, we do not promise, and you should not expect, that your personal information will always remain secure. Despite our best efforts and security measures, unfortunately, no website or Internet transmission is ever completely, absolutely, 100% secure and even we cannot guarantee that unauthorized access, hacking, data loss or other breaches will never occur, but here are some handy tips to help keep your data secure:
- make sure you log out of your Account after use as you never know who may stumble onto your Account!
- don’t share your social media password with anyone else!
- change your social media password periodically.
WE EXPRESSLY DISCLAIM ANY REPRESENTATION OR WARRANTY, WHETHER EXPRESS OR IMPLIED, WITH RESPECT TO ANY BREACHES OF SECURITY, DAMAGE TO YOUR DEVICE, OR ANY LOSS OR UNAUTHORISED USE OF YOUR REGISTRATION INFORMATION OR OTHER DATA.
9. Retention of your info
We keep your personal information only as long as we need it for legitimate business purposes (as laid out in Section 3 and as permitted by applicable law).
In practice, we delete or anonymize your information upon deletion of your account, unless:
- we must keep it to comply with applicable law;
- we must keep it to evidence our compliance with applicable law;
- there is an outstanding or potential issue, claim or dispute requiring us to keep the relevant information until it is resolved; or
- the information is 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 behavior or security incidents from opening a new account).
Keep in mind that even though our systems are designed to carry out data deletion processes according to the above guidelines, we cannot promise that all data will be deleted within a specific timeframe due to technical constraints.
10. Our policy towards age
Although we welcome adults of all ages, you have to be a legal adult (that is, at least 18 years old) to use the App.
We do not permit users under the age of 18 on the App and do not knowingly collect any information about or market to children, minors or anyone under the age of 18.
If you are less than 18 years old, we request that you do not submit information to us. If we become aware that a child, minor or anyone under the age of 18 has registered with us and provided us with personal information, we will take steps to terminate that person’s registration and delete their Registration Information from the App. If we do delete a profile because you violated our no children rule, 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.
If you suspect that a user is under the age of 18, please use the reporting mechanism available through the service.
11. Changes to this policy
12. Third-party accounts
If you have registered with the App using a third-party social media platform (Facebook), your FFWD profile will be available to all users – whether via our App or our partners’ websites.
Remember that when you register with a third-party, you are also giving them personal information, so we recommend that you read their privacy policies as FFWD does not control how they use their information.
If you have registered on one of these third-party websites, or you have verified your Account via a third-party website, we may connect your FFWD profile with your profile on such a website. We may do this by way of new products and applications which we introduce from time to time.
If you have created your FFWD profile through a third-party website and you do not want to link your FFWD profile to your profile on the third-party website, FFWD cannot amend these settings. Please visit the application settings on your third-party website profile and follow the instructions to remove the FFWD access permissions.
We only use the APIs, OAuth Tokens, Widgets, or other means provided by the applicable Social Media Account to integrate your Social Media Account with our App. As such, we only receive the limited information that each Social Media Account permits to be transferred.
13. Data Storage
By using the App, you acknowledge that FFWD is a global application operating through servers located in a number of countries around the world, including the United States. Your information will be sent to and used in the United States regardless of the country you reside in. If you live in a country with data protection laws, the storage of your personal data may not provide you with the same protections as you enjoy in your country of residence.
14. Residents of California
If you are a California resident, you can request a notice disclosing the categories of personal information about you that we have shared with third parties for their direct marketing purposes during the preceding calendar year. To request this notice, please submit your request to firstname.lastname@example.org. Please allow 30 days for a response. For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer such a request.
15. Governing Law