Privacy

Privacy Policy

Last Updated: January 14, 2024

Evinie Essense Limited, its brands, affiliates, and subsidiaries ("Evinie"," "we," "our," or "us") values your privacy. This Privacy Policy ("Policy") describes how EVINIE collects, uses, discloses, and otherwise processes personal information described in this Policy, as well as the rights and choices you have regarding such personal information.

When you create a profile on one of our Services, your personal information may be visible also to users of our other Services, and other applications we own and other applications and websites not owned by us with which we share our live platform.

By using our Services (as defined below), you agree that your personal information will be handled as described in this Policy. Your use of our Services and any dispute over privacy, is subject to this Policy and our Terms and Conditions, including their applicable terms governing limitations on damages and the resolution of disputes.

Table of Contents

  1. Scope
  2. Personal Information Collected
  3. Purposes for Collection and Processing
  4. Disclosures of Personal Information
  5. Cookies, Targeting, and Analytics
  6. Your Privacy Choices
  7. External Links and Features
  8. User Generated Content
  9. Security
  10. Children's Privacy
  11. Changes to this Policy
  12. Contact Us
  13. Additional Privacy Information for Certain Jurisdictions

1. Scope

Except as otherwise described below, this Policy applies to the personal information EVINIE collects and processes related to: visitors of our website where this Policy is posted, including any of our websites that link to or post this Policy (the "Sites"); individuals who download and use our mobile application ("Mobile App"); individuals who register for or participate in our events, surveys, research, promotions, and sweepstakes conducted by us; current, former, and prospective customers, vendors and service providers, and business partners; and individuals who communicate or otherwise interact or engage with us or the services available through our Sites, Mobile App, or other online services (collectively referred to as the "Services").

2. Personal Information Collected

As further described below, we may collect personal information directly from you, from third-party sources, and automatically through your use of our Services.

Personal Information Collected Directly from You. While the personal information we collect varies depending upon your use of our Services and our interactions with you, in general, we may collect the following categories of personal information directly from you:

  • Contact Information. When you contact us, including if you send us a message or sign up to learn more about our Services, we may collect your name, email address, phone number, or other similar identifiers, as well as your message, the nature of your inquiry, and any other information you so choose to provide.
  • Account and Profile Information. When you sign up for an account in connection with our Services, we may collect your name, email address, phone number, address (e.g., zip code), username and password, date of birth, ethnicity, and gender, profile image and photo, and billing address information, as well as any other information provided in connection with creating or maintaining your account, or that you otherwise submit to us through your account.
  • Purchases, Payments, and Rewards. When you make a purchase or payment through our Services, we may collect information such as payment type, payment card details, billing, shipping address, purchasing information, and any other financial or commercial-related information necessary for facilitating our Services.
  • Communications and Interactions. When you email, call, or otherwise communicate or interact with us or with other EVINIE users, including if you sign up for our mailing lists, complete forms on our Sites or Mobile App, interact with our social media pages, post a review or testimonial, submit content in any online discussion groups, or otherwise enter information into public-facing comment fields, blogs, or community forums sponsored by or affiliated with EVINIE, we may collect, receive, and maintain records of your contact details, communications and interactions, your posts or submissions, and our responses, if applicable.
  • Promotional Information. If you agree to receive marketing communications from us, we may collect your name, email address, phone number, preferences, and if relevant, information about your account and profile, including the Services and features you use. If you participate in special activities, offers, programs, or promotions we offer, we may also collect certain contact details, your age, and any other information that may be required by law. If you win a promotion, we may also need to collect certain tax information and/or waivers and releases, depending on the prize.
  • Responses and Feedback. If you participate in surveys, questionnaires, or research activities or initiatives conducted by us, such as for user satisfaction or other similar purposes, we may collect your responses and feedback, and any other information you choose to provide.
  • Events and Registration Details. We may also collect personal information related to your participation in our events as well as other requests that you submit to us related to our Services. For example, if you register for or attend an event that we host or sponsor, we may collect information related to your registration for and participation in such event.
  • Preferences and Other Requests. We also may collect information about your preferences, including communications preferences, preferences related to your use of our Services, and any other preferences or requests you provide when interacting with us.
  • Business Development Information. To assess and pursue potential business opportunities, we may collect and receive personal information about current, former, and prospective customers, vendors and service providers, business partners, including contact information and other similar identifiers, company and professional information, and communications records.

Personal Information Collected from Third Parties. We may also collect and receive certain personal information about you from third party sources, such as from business partners, customers and other EVINIE users, data analytics and marketing providers, operating systems and social media platforms, public databases, and vendors and service providers who provide services or perform functions on our behalf. For example, we may collect your name, contact details, and other similar information from business partners and vendors and service providers for purposes of providing our Services. In addition, we may collect the following information from third-party sources:

  • Social Media and Platform Registration Information. While using our Services, you may choose to share information or content, log into, or sign on to the Services through various social media platforms, social networking services, or other third-party features or integrated services. When you connect to our Services using your social media accounts or other similar integrated services and features, we may collect or receive personal information about you that you have provided to that social media account, service, or feature. For example, we may collect information from your account and profile, such as your name, email, user ID, profile picture, friend list, and other similar information available on your profile. You should check your privacy settings on each social media platform, feature, or integrated service to better understand how your personal information may be used, disclosed, or otherwise processed by these parties.
  • Referral Information. We may offer you the ability to invite friends or refer other users to access or use our Services. In doing so, we may collect and receive certain personal information about you, including from other current or prospective EVINIE users and customers who similarly engage in these activities.
  • Lead and Prospect Information. We may receive lead and prospect information from third parties about prospective customers that may be interested in our Services. We may also engage with third parties to enhance or update our customer information. For example, we may receive certain personal information from data analytics and marketing providers for purposes of reaching new customers, or from business partners, vendors and service providers for purposes of providing our Services.

Personal Information Collected Automatically. We and our third-party service providers may automatically collect or derive personal information about you related to your use of our Services, including using cookies, pixel tags, and other similar technologies. The personal information we may automatically collect includes:

  • Device and Browsing Information. When you use our Services, we may collect browser type, domain name, page views, access times, date/time stamps, operating system, language, device type, unique ID, Internet service provider, referring and exiting URLs, clickstream data, operating system, language, and similar device and browsing information.
  • Activities and Usage. We also may collect activity information related to your use of the Services, such as information about the links clicked, searches, features used, items viewed, time spent within the Services, your interactions with us and others within the Services, and other similar activity and usage information.
  • Location Information. We also may collect or derive general location information about you, such as through your IP address.

3. Purposes for Collection and Processing

Generally, we may collect, use, disclose and otherwise process the categories of personal information we collect for the following purposes:

  • Services and Support. To provide and operate our Services, manage your account, communicate with you about your use of the Services, provide troubleshooting, technical support, or for similar support purposes, and to respond to your inquiries, fulfill your requests, facilitate payment processing, and to otherwise run our day-to-day operations.
  • Analytics and Improvement. To better understand how users access and use the Services, and for other research and analytical purposes, such as to evaluate and improve the Site, our Services, and business operations, including to develop our Services and its features, and for internal quality control and training purposes.
  • Communication. To respond to your questions, send you requested materials and newsletters, as well as information and materials regarding our Services and offerings. We may also use this information to send administrative information to you, for example, information regarding the Services and changes to our terms, conditions, and policies.
  • Customization and Personalization. To tailor content we may send or display on the Services, including to offer location customization and to otherwise personalize your experiences and offerings.
  • Marketing and Advertising. For marketing, advertising, and promotional purposes. For example, to send you promotional information about our Services, including information about EVINIE events, webinars, presentations, sales, deals, discounts, and new offerings, as well as any other information that you sign up to receive.
  • Research and Surveys. To administer surveys and questionnaires, such as for market research, user satisfaction, or other similar purposes.
  • Insight Development and Data Enhancement. We may combine personal information collected through the Services with other information that we or third parties collect about you in other contexts. In most cases, the information that we may combine with the personal information collected through the Services for market research, such as demographic information, does not directly identify consumers.
  • Planning and Managing Events. For event planning and other management-related purposes, such as event registration and attendance, connecting you with other event attendees and EVINIE users, and contacting you about relevant events, presentations, and our Services. We may also use personal information for purposes of facilitating special events, sweepstakes, contests, and promotions, which may have their own specific rules to participate.
  • Security and Protection of Rights. To protect the Services and our business operations, our rights and those of our stakeholders and investors, to prevent and detect fraud, unauthorized activities and access, and other misuse of our Site, including where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party, or violations of our Terms and Conditions.
  • Compliance and Legal Process. To comply with applicable legal or regulatory obligations, including as part of a judicial proceeding, to respond to a subpoena, warrant, court order, or other legal process, or as part of an investigation or request, whether formal or informal, from law enforcement or a governmental authority.
  • Auditing, Reporting, and Other Internal Operations. To conduct financial, tax and accounting audits, audits, and assessments of our operations, including our privacy, security, and financial controls, as well as for risk and compliance purposes. We may also use personal information to maintain appropriate business records and enforce our policies and procedures.
  • General Business and Operational Support. To assess and implement mergers, acquisitions, reorganizations, bankruptcies, and other business transactions such as financings, and to administer our business, accounting, auditing, compliance, recordkeeping, and legal functions.

4. Disclosures of Personal Information

We may disclose the personal information we collect for the purposes described above, to provide you our Services, to respond to and fulfill your requests, as otherwise directed or consented to by you, and with the following recipients:

  • Brands, Affiliates, and Subsidiaries. We may disclose the personal information we collect with our brands, corporate affiliates, and subsidiaries.
  • Business Partners. In some circumstances, EVINIE may partner with other businesses to offer its Services, including to facilitate certain programs or special offerings, and we may disclose personal information to those business partners.
  • Vendors and Services Providers. We may disclose the personal information we collect to vendors and service providers who perform functions on our behalf, such as IT and website hosting, payment processors, marketing and marketing research providers, customer support, data storage, data analytics providers, auditors, consultants, advisors and agents, and legal counsel.
  • Other EVINIE Users. With other users of the Services in the context of specific features that are social in nature. For example, if you invite others to use our Services, or if you submit or make available information through our public-facing, interactive features, community forums, or discussion blogs, including when you post reviews or testimonials, certain personal information, may be available to, and searchable by, other users of the Services.
  • Third Party Marketing and Analytics Providers. We may also disclose your personal information, such as device and browsing, and activities and usage information, to third party marketing and data analytics providers, and other companies who provide marketing, advertising, campaign management, or analytics services on our behalf.

We may also disclose your personal information in the following circumstances:

  • In Support of Business Transfers. If we or our affiliates are or may be acquired by, merged with, or invested in by another company, or if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may disclose or transfer the personal information we have collected from you with or to the other company in accordance with applicable laws. We may also disclose certain personal information as necessary prior to the completion of such a transaction or other corporate transaction such as a financing or restructuring, to lenders, auditors, and third-party advisors, including attorneys and consultants.
  • Compliance and Legal Obligations. We may also disclose personal information to third parties to the extent required by applicable law and legal obligations. For example, we may disclose information in response to subpoenas, court orders, and other lawful requests by regulators, government entities, and law enforcement, including responding to national security or law enforcement disclosure requirements, or as otherwise required by law or legal process. In addition, and if applicable, we may disclose the names of sweepstakes and contests winners in accordance with applicable law.
  • Security and Protection of Rights. Where we believe doing so is necessary to protect the Services, our rights and property, or the rights, property, and safety of others. For example, we may disclose personal information to (i) prevent, detect, investigate, and respond to fraud, unauthorized activities and access, illegal activities, and misuse of the Services, (ii) situations involving potential threats to the health, safety, or legal rights of any person or third party, or (iii) enforce, detect, investigate, and take action in response to violations of our Terms and Conditions. We may also disclose personal information related to litigation and other legal claims or proceedings in which we are involved, as well as for our internal accounting, auditing, compliance, recordkeeping, and legal functions.
  • Other Disclosures. We may disclose personal information in other ways not described above that we notify you of or that we obtain your consent for, or that are otherwise authorized or required by law.

Notwithstanding anything else described in this Policy, we may use and disclose aggregated, deidentified, and other non-identifiable data related to our business and the Services for quality control, analytics, research, development, and other purposes. Where we use, disclose or process deidentified data (data that is no longer reasonably linked or linkable to an identified or identifiable natural person, household, or personal or household device) we will maintain and use the information in deidentified form and not to attempt to reidentify the information, except in order to determine whether our deidentification processes are reasonable and adequate pursuant to applicable privacy laws.

 

5. Cookies, Targeting, and Analytics

We and our third-party service providers use cookies, pixels, local storage objects, log files, and other mechanisms to automatically collect browsing, activity, device, and other similar information within our Services. We use this information to, for example, analyze and understand how users access, use, and interact with our Services, to identify and resolve bugs and errors in our Services, to assess secure, protect, optimize and improve the performance of our Services, as well as for marketing and analytics purposes, and to personalize content in our Services.

Cookies. "Cookies" are small text files stored on a user's device (such as a computer or smartphone) by a website they visit. Cookies are created by the website's server and sent to the user's browser, where it is stored for future reference. Some cookies allow us to make it easier for you to navigate our Services, while others are used to enable a faster log-in process, support the security and performance of the Services, or allow us to track aggregate and statistical information about user activity within the Services.

Pixel Tags. Pixel tags (sometime called web beacons or clear GIFs) are tiny graphics with a unique identifier, similar in function to cookies. While cookies are stored locally on your device, pixel tags are embedded invisibly within web pages and online content. We may use these, in connection with our Services to, among other things, track the activities of users, and help us manage content and compile usage statistics. We may also use these in our emails to let us know when they have been opened or forwarded, so we can track response rates and gauge the effectiveness of our communications.

Log Files. We may collect certain activity information from log files. Log file information is automatically collected when you access our Sites. We record certain information from these log files, including web requests, IP address, browser type and version, language information, referring and exiting URLs, links clicked, pages viewed and other similar information.

Third Party Analytics. We may use automated devices, applications, and tools, such as Google Analytics, which are operated by third party companies, to evaluate usage of our Services. These third-party companies may use cookies, pixels, and other tracking technologies to collect usage data about our Services and provide us with reports and metrics that help us evaluate usage of our Services and enhance performance and user experiences.

Third-Party Advertising. We work with third-party ad networks, analytics, marketing partners, mobile ad networks, and others ("third-party ad companies") to personalize content and display advertising within our Services, as well as to manage our advertising on third-party websites. We and these third-party ad companies may use cookies, pixels tags, SDKs, and other tools to collect browsing and activity information within our Services (as well as on third-party sites and services), as well as IP address, unique ID, cookie and advertising IDs, and other online identifiers. We and these third-party ad companies use this information to provide you more relevant ads and content within our Services and on third-party sites, and to evaluate the success of such ads and content.

Cross-Device Use. We and our third-party service providers may use the information we collect about you (whether directly from our Sites or Mobile App, through your device(s), or from third party sources) to help us and our third-party service providers identify other devices you use (e.g., a mobile phone, tablet, other computer, etc.). We and our third-party service providers may also use the cross-device use and other information we learn about you to serve targeted advertising or personalize content within our Services. To opt-out of cross-device advertising, you may follow the instructions set forth below. Please note, if you opt-out of these targeted advertising cookies, the opt-out will be specific to the web browser, app, or device from which you accessed the opt-out. If you use multiple devices or web browsers, you will need to opt-out each browser or device that you use.

Custom Lists and Matching. We may share or make available certain customer list information (such as your name, email address and other contact information) with third parties so that we can better target ads and content to you across third party websites, platforms and services. In some cases, these third parties may help us to enhance our customer lists with additional demographic or other similar information so we can better target our advertising and marketing campaigns.

6. Your Privacy Choices

Managing Your Preferences. We make available several ways for you to manage your preferences and privacy choices, as described below:

  • Account and Profile. You can review and update some of the personal information we maintain about you by logging into your account and updating your account and profile information.
  • Marketing Communications. We may send periodic promotional emails, content, or other similar communications to you. You may opt-out of these communications by following the instructions provided to you in the communication. If you opt-out of receiving promotional content from us, we may still send you communications about your account or any services you have requested or received from us. Additionally, you can manage your communication preferences in your account and profile settings.
  • Push Notifications. You can manage the type of push notifications you receive from us by adjusting your mobile device settings or by modifying the settings within our Mobile App.

Cookie Preferences/Targeted Advertising. We also make available several ways for you to manage your preferences regarding cookies, targeted advertising, and other similar tracking mechanisms within our Services. Many of these choices are browser and device specific, which means that you may need to set the preference for each browser and device you use to access our Services. In addition, if you delete or block cookies, you may need to reapply these preferences to each browser and/or device. Further, opting out of cookies and advertising does not mean that you will no longer receive advertising content from us, and you may continue to receive generic or "contextual" ads from us.

  • Cookie Settings. To prevent cookies from tracking your activity on our Sites or visits across multiple websites, you can set your browser to block certain cookies or notify you when a cookie is set. You can also delete cookies. The "Help" portion of the toolbar on most browsers will tell you how to prevent your device from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to delete cookies. Visitors to our Sites who disable cookies will be able to browse the Site, but some features may not function.
  • Browser Signals. To the extent required by applicable law, if our Sites detect that your browser is transmitting an opt-out preference signal, such as a "global privacy control" (or GPC) signal, we will apply that signal to opt that particular browser on your device out of targeting cookies on our Sites. If you come to our Sites from a different device or from a different browser on the same device, you will need to apply GPC for that browser and/or device as well.
  • Industry Ad Choice Programs. You can also control how participating third-party ad companies use the information that they collect about your visits to our Sites and those of third parties, to display more relevant targeted advertising to you.

7. External Links and Features

Our Services may contain links to third-party websites or features or provide certain third-party connections or integrated services. Any access to and use of such linked websites or features is not governed by this Policy, but instead is governed by the privacy policies of those third parties. We are not responsible for the information practices of such third parties, including their collection, use, and disclosure of your personal information. You should review the privacy policies and terms for any third parties before proceeding to those websites or using those features.

8. User Generated Content

We may offer public-facing interactive features, community forums, or discussion blogs in connection with our Services that enable you to share information about the Services, or other issues of interest (e.g., reviews, testimonials, and questions). You should be aware that any communications you submit or post to any such interactive features on the Services may be viewable and searchable by others, including EVINIE users and the public. By submitting or posting to such public-facing, interactive features you acknowledge that you have no expectation of privacy or confidentiality in the content you submit for such features, whether or not it contains personal information about you.

9. Security

We have implemented reasonable precautions aimed to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our best efforts, no data security measures can guarantee security.

10. Children's Privacy

Our Services are not designed for children, and we do not knowingly collect personal information from children under the age of eighteen (18). If we learn that personal information has been collected on the Services from persons under the age of 18, then we will take the appropriate steps to delete this information. If you are a parent or legal guardian and you believe we have collected your child's information in violation of applicable law, please contact us using the contact information below.

11. Changes to this Policy

This Policy is current as of the date set forth above. We may change, update, or modify this Policy from time to time, so please be sure to check back periodically. We will post any updates to this Policy here. If we make any changes to this Policy that materially affect our practices regarding our use of the personal information we have previously collected from you, we will notify endeavor to provide you with notice, such as by emailing you or by posting prominent notice on our Sites, in our Mobile App, or within the Services.

12. Contact Us

If you have any questions or concerns regarding this Policy or our privacy practices, you may email us at support@evinie.com

13. Additional Privacy Information for Certain Jurisdictions

Residents of certain jurisdictions have additional rights under applicable privacy laws, as described in this section.

A. U.S. State Privacy Laws

Residents of certain U.S. states, including Colorado, Connecticut, Utah, and Virginia, may have additional rights under applicable privacy laws, subject to certain limitations, which may include:

  • Access. To confirm whether we are processing their personal information and to obtain a copy of their personal information in a portable and, to the extent technically feasible, readily usable format.
  • Deletion. To delete their personal information provided to or obtained by us.
  • Correction. The right to correct inaccuracies in their personal information, considering the nature and purposes of the processing of the personal information.
  • Opt-Out. To opt out of certain types of processing, including:
    • to opt out of the "sale" of their personal information.
    • to opt out of targeted advertising by us; and
    • to opt out of any processing of personal information for purposes of making decisions that produce legal or similarly significant effects.

You may submit a request to exercise most of your privacy rights under U.S. state privacy laws by contacting us at support@evinie.com. To opt out of sales and targeted advertising by us, you can adjust your cookies settings or download an opt-out preference signal, such as the "global privacy control" (or GPC).

We will respond to your request as required under applicable U.S. privacy law(s). When you submit a request, we will take steps to verify your identity and request by matching the information provided by you with the information we have in our records. In some cases, we may request additional information in order to verify your identity, or where necessary to process your request. If we are unable to verify your identity after a good faith attempt, we may deny the request and, if so, will explain the basis for the denial. If we deny your request, you may appeal our decision by emailing us.

To the extent required under applicable U.S. privacy laws, you may also designate someone as an authorized agent to submit requests and act on your behalf. Authorized agents will be required to provide proof of their authorization in their first communication with us, and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.

 

B. Additional Information for California Residents

This section of the Policy provides additional information for California residents and describes our information practices pursuant to applicable California privacy laws, including the California Consumer Privacy Act (the "CCPA"). To the extent you are a California resident, and we collect "personal information" subject to the CCPA, the following applies. This section does not address or apply to our handling of our handling of publicly available information or personal information that is otherwise exempt under the CCPA.

Categories of Personal Information Collected and Disclosed. The following table identifies the categories of personal information we may collect about you (and may have collected in the prior 12 months), as defined by the CCPA, as well as the categories of third parties to whom we may disclose this information for a business or commercial purpose. Depending on how you use the Services, we may collect and disclose the following categories of personal information:

  • Identifiers. Includes direct identifiers such as name, alias, email, phone number, address, user ID or username, unique personal identifier, online identifier, IP address, or other similar identifiers.

Third Party Disclosures for Business or Commercial Purposes:

    • Advisors and agents
    • Affiliates and subsidiaries
    • Other EVINIE users
    • Data analytics providers
    • Advertising networks
    • Social networks
    • Internet service providers
    • Operating systems and platforms
    • Regulators, government entities and law enforcement
    • Others with your permission or as required by law
  • Customer Records. Includes your account and profile information and customer records that contain personal information, such as username, account name, name, demographics and other characteristics or descriptions, contact information, and financial or payment information (i.e., payment type, payment card details, billing, and shipping address).

Third Party Disclosures for Business or Commercial Purposes:

    • Advisors and agents
    • Affiliates and subsidiaries
    • Data analytics providers
    • Advertising networks
    • Social networks
    • Regulators, government entities and law enforcement
    • Others with your permission or as required by law
  • Commercial Information. Includes records of Services purchased, obtained, or considered, or other purchasing or use histories or tendencies.

Third Party Disclosures for Business or Commercial Purposes:

    • Advisors and agents
    • Affiliates and subsidiaries
    • Data analytics providers
    • Advertising networks
    • Social networks
    • Regulators, government entities and law enforcement
    • Others with your permission or as required by law
  • Internet or Other Electronic Network Activity Information. Includes, but is not limited to, browsing history, clickstream data, search history, and information regarding interactions with our Sites, Mobile App, and the Services, advertisements, or emails, including other usage data related to your use of any of our Services or other similar online services.

Third Party Disclosures for Business or Commercial Purposes:

    • Affiliates and subsidiaries
    • Data analytics providers
    • Advertising networks
    • Social networks
    • Internet service providers
    • Operating systems and platforms
    • Regulators, government entities and law enforcement
    • Others with your permission or as required by law
  • Location Data. Such as general location information about a particular individual or device.

Third Party Disclosures for Business or Commercial Purposes:

    • Affiliates and subsidiaries
    • Other EVINIE users
    • Data analytics providers
    • Advertising networks
    • Social networks
    • Internet service providers, and operating systems and platforms
    • Regulators, government entities and law enforcement
    • Others with your permission or as required by law
  • Audio, Electronic, Visual, or Similar Information. Includes, but is not limited to, information collected via call recordings if you are interacting with us in a customer service capacity or if you call us on a recorded line, recorded meetings and webinars, videos, photographs, and user profile images.

Third Party Disclosures for Business or Commercial Purposes:

    • Advisors and agents
    • Affiliates and subsidiaries
    • Regulators, government entities and law enforcement
    • Others with your permission or as required by law
  • Professional Information. Includes, but is not limited to, job title, company name, business email, business phone number, and other similar professional-related information.

Third Party Disclosures for Business or Commercial Purposes:

    • Advisors and agents
    • Affiliates and subsidiaries
    • Regulators, government entities and law enforcement
    • Others with your permission or as required by law
  • Inferences. Such as inferences drawn from any of the information described in this section about a consumer including inferences reflecting the consumer’s preferences, characteristics, behaviors, attitudes, abilities, and aptitudes.

Third Party Disclosures for Business or Commercial Purposes:

    • Affiliates and subsidiaries
    • Regulators, government entities and law enforcement
    • Data analytics providers
    • Others with your permission or as required by law
  • Protected Classifications. We may collect some information that is considered a protected classification under California or federal law, which may include, but not be limited to your ethnicity, gender, age, and date of birth.

Third Party Disclosures for Business or Commercial Purposes:

    • Affiliates and subsidiaries
    • Other EVINIE users
    • Regulators, government entities and law enforcement
    • Others with your permission or as required by law
  • Sensitive Personal Information. In some circumstances, we may collect account log-in information, payment card information and related details, precise geolocation data, racial or ethnic origin, messages and content shared between users, and personal information collected and analyzed concerning a consumer’s health, sex life, or sexual orientation. Additionally, if you win a contest, promotion, or sweepstakes, we may also collect certain government-issued identifiers, such as social security number or driver’s license number, in accordance with applicable law.

Third Party Disclosures for Business or Commercial Purposes:

    • Affiliates and subsidiaries
    • Regulators, government entities and law enforcement
    • Others with your permission or as required by law

Sources of Personal Information. We generally collect personal information from the following categories of sources: directly or indirectly from you; brands, affiliates and subsidiaries; business partners; vendors and service providers; other EVINIE users; third-party websites and services; social media platforms and social networking websites; Internet service providers; operating systems and platforms; and marketing and data analytics providers.

Purposes of Collection, Use, and Disclosure. As described above in Section 3. Purposes for Collection and Processing, in general, we may collect and otherwise process the categories of personal information we collect for the following business or commercial purposes and as otherwise directed or consented to by you:

  • Services and support;
  • Analytics and improvement;
  • Communication;
  • Customization and personalization;
  • Marketing and advertising;
  • Research and surveys;
  • Insight development and data enhancement;
  • Planning and managing events;
  • Security and protection of rights;
  • Compliance and legal process;
  • Auditing, reporting, and other internal operations; and
  • General business and operational support.

Sensitive Personal Information. We do not collect, use, or disclose "sensitive personal information" beyond the purposes authorized by the CCPA. Accordingly, we only use and disclose sensitive personal information as reasonably necessary and proportionate: (i) to perform our services requested by you; (ii) to help ensure security and integrity, including to prevent, detect, and investigate security incidents; (iii) to detect, prevent and respond to malicious, fraudulent, deceptive, or illegal conduct; (iv) to verify or maintain the quality and safety of our services; (v) for compliance with our legal obligations; (vi) to our service providers who perform services on our behalf; and (vii) for purposes other than inferring characteristics about you.

Retention. We retain the personal information we collect only as reasonably necessary for the purposes described above or otherwise disclosed to you at the time of collection. For example, we will retain your account information for as long as you have an active account with us and additional information as necessary to comply with our tax, accounting and recordkeeping obligations, to provide you with the services you have requested, as well as an additional period of time as necessary to protect, defend or establish our rights, defend against potential claims, and comply with our legal obligations. In some cases, rather than delete your personal information, we may deidentify or aggregate it and use it in compliance with the CCPA.

Sales and Sharing of Personal Information. The CCPA defines "sale" as disclosing or making available personal information to a third-party in exchange for monetary or other valuable consideration, and "sharing" includes disclosing or making available personal information to a third-party for purposes of cross-context behavioral advertising. While we do not disclose personal information to third parties in exchange for monetary compensation, we may "sell" or "share" the following categories of personal information: identifiers; commercial information; location data; and Internet and network activity information. We may disclose these categories to third-party advertising networks, analytics providers, and social networks for purposes of marketing and advertising and to improve and measure our ad campaigns. We do not sell or share sensitive personal information, nor do we sell or share personal information about individuals we know are under age sixteen (16).

California Privacy Rights. The CCPA provides California residents with specific rights regarding personal information. Subject to certain conditions and exceptions, California residents have the following rights with respect to their personal information:

  • Right to Know. You have the right to request: (i) the categories or personal information we collected about you; (ii) the categories of sources from which the personal information is collected; (iii) our business or commercial purposes for collecting, selling, or sharing personal information; (iv) the categories of third parties to whom we have disclosed personal information; and (v) a copy of the specific pieces of personal information we have collected about you.
  • Right to Delete. You have the right to request we delete personal information we have collected from you.
  • Right to Correct. You have the right to request that we correct inaccuracies in your personal information.
  • Right to Opt-Out of Sales and Sharing. You have the right to opt-out of "sales" and "sharing" of your personal information, as those terms are defined under the CCPA.
  • Right to Limit Use and Disclosure. You have the right to limit use and disclose of your sensitive personal information. However, we do not use or disclose sensitive personal information beyond the purposes authorized by the CCPA; thus, this right is not available to California residents.
  • Right to Non-Discrimination. You have the right not to be subjected to discriminatory treatment for exercising any of the rights described in this section.

Submitting CCPA Requests. California residents may exercise their CCPA privacy rights as set forth below:

  • Right to Know, Delete, and Correct. California residents may submit CCPA requests to access/know, delete, and correct their personal by contacting us at support@evinie.com

 

When you submit a request, we will take steps to verify your identity and request by matching the information provided by you with the information we have in our records. In some cases, we may request additional information in order to verify your identity, or where necessary to process your request. If we are unable to verify your identity after a good faith attempt, we may deny the request and, if so, will explain the basis for the denial.

You may also designate someone as an authorized agent to submit requests and act on your behalf. Authorized agents will be required to provide proof of their authorization in their first communication with us, and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.

  • Right to Opt-Out of Sales and Sharing. To exercise your right to opt-out of the "sale" or "sharing" of your personal information, you may do so via our cookie preference manager. We will apply you opt out based upon the personal information in our records that is linked or reasonably linkable to the information provided in your request. You may also click the "Do Not Sell or Share My Personal Information" link at the bottom of our Sites and in our Mobile App.

In addition, if we detect that your browser or device is transmitting an opt-out preference signal, such as the "global privacy control" (or GPC) signal, we will opt that browser or device out of cookies that result in a "sale" or "sharing" of your personal information. If you come to our Sites or use our Services from a different device or from a different browser on the same device, you will need to opt-out, or use an opt-out preference signal, for that browser and/or device as well..

Notice of Financial Incentive. With respect to some of our Services, EVINIE may make available certain programs or offerings, and other sweepstakes, contests, or similar promotional offerings (each a "Program") which may include certain offers, rewards, discounts, services, perks, and promotions ("Rewards and Offers"). These Programs may be considered "financial incentives" under the CCPA. We provide these Rewards and Offers to participating users in order to understand and improve customer satisfaction and experiences, and to foster positive customer relationships.

As a basis for offering these Rewards and Offers, we have valued the personal information we obtain based on a reasonable and good faith calculation determined by considering expenses related to the Programs. In doing so, we value the personal information collected through the programs as the equivalent of the costs and expenses incurred to provide the program, including IT, administration, direct costs, third party costs, discounts, and service development costs.

Your personal information is collected and retained, and may be disclosed to our business partners, vendors and service providers, and other third parties, as described in this Policy, including in order (i) to administer the Program, (ii) for research and analytics purposes, (iii) to improve our products and services, (iv) to better reach you with more relevant, targeted offers, and (v) to send you EVINIE news, updates and offers by email, postal mail, and text message (in accordance with your communications preferences).

You may withdraw from participating in a Program at any time by contacting us using the methods described in this Policy. Please note that if you withdraw from a Program (or submit a CCPA request to delete your Program information), your participation in that Program will be terminated, which means that you will no longer be eligible to earn, use, access or redeem any Program Rewards and Offers, subject to the applicable Program terms.

California's Shine the Light Law. Under California's "Shine the Light" law (Cal. Civ. Code § 1798.83), California residents who provide us certain personal information are entitled to request and obtain from us, free of charge, information about the personal information (if any) we have shared with third parties for their own direct marketing use. Such requests may be made once per calendar year for information about any relevant third-party sharing in the prior calendar year. To submit a "Shine the Light" request, you may contact us by using the methods described in this Policy. Please include in your request a current California address and your attestation that you are a California resident.

Privacy Policy for users having their residence in the European Economic Area or the United Kingdom

Last Updated: January 14, 2024

The Meet Group, Inc., its brands, affiliates, and subsidiaries values your privacy. This Privacy Policy ("Policy") describes how The Meet Group, Inc. ("EVINIE"," "we," "our," or "us") collects, uses, discloses, and otherwise processes personal information (also referred to as personal data in some jurisdictions) described in this Policy, as well as the rights and choices you have regarding such personal information.

For additional information about the privacy choices you have regarding your personal information, please review Section 7. Your Privacy Choices, as well as Section 15. Additional Privacy Information for Certain Jurisdictions, which includes additional information about privacy rights for residents of certain jurisdictions.

If you are a resident of the EU/European Economic Area (EEA), please refer to Section 15.A. Additional Information for Residents of the EU/EEA for information about your rights under the General Data Protection Regulation ("GDPR").

If you are a resident of the UK, please refer to Section 15.B. Additional Information for Residents of the UK for information about your rights under the General Data Protection Regulation as incorporated into United Kingdom law by virtue of section 3 of the United Kingdom's European Union (Withdrawal) Act 2018 ("UK GDPR").

If you are a resident of Switzerland, please refer to Section 15.C. Additional Information for Swiss Residents for information about your rights under the new Swiss Data Protection Law ("nDSG").

When you create a profile on one of our Services, some of your personal information like user name, name, age, gender and sexual orientation in accordance with your privacy settings may be visible also to users of the respective Service and of our other Services, and other applications we own and other applications and websites not owned by us with which we share our live platform. These other users are be based worldwide.

Your use of our Services, is subject to our Terms and Conditions, including their applicable terms governing limitations on damages and the resolution of disputes.

Table of Contents

  1. Scope
  2. Personal Information Collected
  3. Purposes for Collection and Processing
  4. Disclosures of Personal Information
  5. Transfers of personal data in the context of countries located outside the EEA/UK/CH
  6. Cookies, Targeting, and Analytics
  7. Your Privacy Choices
  8. Storage Period of Personal Information
  9. External Links and Features
  10. User Generated Content
  11. Security
  12. Children's Privacy
  13. Changes to this Policy
  14. Contact Us
  15. Additional Privacy Information for Certain Jurisdictions

1. Scope

Except as otherwise described below, this Policy applies to the personal information EVINIE collects and processes related to: visitors of our website where this Policy is posted, including any of our websites that link to or post this Policy (the "Sites"); individuals who download and use our mobile application ("Mobile App", e.g. the Tagged App or the Pets App); individuals who register for or participate in our events, surveys, research, promotions, and sweepstakes conducted by us; and individuals who communicate or otherwise interact or engage with us or the services available through our Sites, Mobile App, or other online services (collectively referred to as the "Services").

2. Personal Information Collected

As further described below, we may collect personal information directly from you, from third-party sources, and automatically through your use of our Services.

Personal Information Collected Directly from You. While the personal information we collect varies depending upon your use of our Services and our interactions with you, in general, we may collect the following categories of personal information directly from you:

  • Contact Information. When you contact us, including if you send us a message or sign up to learn more about our Services, we may collect your name, email address, phone number, or other similar identifiers, as well as your message, the nature of your inquiry, and any other information you so choose to provide.
  • Account and Profile Information. When you sign up for an account in connection with our Services (e.g. for a Tagged account), we may collect your name, email address, phone number, address (e.g., zip code), username and password, date of birth, and gender, sexual orientation, profile image and photo, and billing address information, as well as any other information provided in connection with creating or maintaining your account, or that you otherwise submit to us through your account.

If you have chosen a login via third party providers such as Facebook or Apple or also SMS, you do not enter an email address or a password within the registration process. Users then access our Service using the email address they provided and the password they selected (login credentials), or alternatively, using the login credentials of the third party provider.

Registering via Facebook ("Facebook login")

We offer single sign-on via Facebook. This offers you the option of registering via your Facebook account. If you use the function, we receive and process the following authentication data from Facebook for the registration: Your email address, profile name, gender, date of birth, and profile picture stored there. Data is transferred in this respect.

When you log in to our website or app using Facebook, Facebook will also collect data from third-party scripts, process it for Facebook analytics purposes, or forward it to third parties. Facebook's Privacy Policy outlines the data that may be collected when you use the Facebook login. This includes data about your device, your use of our Service, the websites you have visited, and the ads you have viewed. Unfortunately, you technically cannot refuse this processing in connection with our Service. If you would not like Facebook to collect data about you related to your use of our online offering and to use it for its own purposes, you should not use the Facebook login.

You can disassociate your Tagged account from your Facebook account at any time on. In this case, we would need you to provide the aforementioned access data.

Further information about the purpose and scope of the collection and the further processing and use of your data by Facebook, as well as your rights and settings options for protecting your data, is available in Facebook's Privacy Policy: http://www.facebook.com/policy.php.

Registration/Login via Google

If you use an Android end device, we offer you the option of registering on or logging in to our Service via your Google account. If you do this, Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google") will provide us with the data required for registration or login (email address, name, Google Account ID, and Google Account profile picture).

We have no control over the scope of the data collected by Google using the Google login. If you would not like Google to collect data about you related to your use of our online offering and to use it for its own purposes, you should not use the Google login.

Further information about the purpose and scope of the collection and the further processing and use of your data by Google, as well as your rights and settings options for protecting your data, is available in Google's Privacy Policy: https://policies.google.com/privacy.

Registration/Login via Apple Sign-In

If you use an iOS end device, we offer you the option of registering on or logging in to our Service via Apple. If you choose to do so, Apple Inc., One Apple Park Way, Cupertino, California, USA, 95014 ("Apple") will provide us with the information you select and which is required for registration or login (e.g. Apple-generated email address, name).

We have no control over the scope of the data collected by Apple using the Apple login. If you would not like Apple to collect data about you related to your use of our online offering and to use it for its own purposes, you should not use the Apple login.

Further information about the purpose and scope of the collection and the further processing and use of your data by Apple, as well as your rights and settings options for protecting your data, is available in Apple's Privacy Policy: https://www.apple.com/legal/privacy/data/en/sign-in-with-apple/.

When registering/logging in via telephone authentication

When registering/logging in via telephone authentication we offer to authenticate by your mobile number, therefore you must provide us with your mobile phone number. We will then send you an SMS with a verification code that you must enter in the app to complete the registration process. When you want to log in, we will send you an SMS with a code that you can use to log into your account. In addition, a verification process will take place.

  • Purchases, Payments, and Rewards. When you make a purchase or payment through our Services (e.g., in connection with our Pets game feature), we may collect information such as payment type, payment card details, billing, purchasing information, and any other financial or commercial-related information necessary for facilitating our Services.
  • Communications and Interactions. When you email, call, or otherwise communicate or interact with us or with other EVINIE users, including if you sign up for our mailing lists, complete forms on our Sites or Mobile App, interact with our social media pages, post a review or testimonial, submit content in any online discussion groups, or otherwise enter information into public-facing comment fields, blogs, or community forums sponsored by or affiliated with EVINIE, we may collect, receive, and maintain records of your contact details, communications and interactions, your posts or submissions, and our responses, if applicable.
  • Promotional Information. If you agree to receive marketing communications from us, we may collect your name, email address, phone number, preferences, and if relevant, information about your account and profile, including the Services and features you use. If you participate in special activities, offers, programs, or promotions we offer, we may also collect certain contact details, your age, and any other information that may be required by law. If you win a promotion, we may also need to collect certain tax information and/or waivers and releases, depending on the prize.
  • Responses and Feedback. If you participate in surveys, questionnaires, or research activities or initiatives conducted by us, such as for user satisfaction or other similar purposes, we may collect your responses and feedback, and any other information you choose to provide.
  • Events and Registration Details. We may also collect personal information related to your participation in our events as well as other requests that you submit to us related to our Services. For example, if you register for or attend an event that we host or sponsor, we may collect information related to your registration for and participation in such event.
  • Preferences and Other Requests. We also may collect information about your preferences, including communications preferences, preferences related to your use of our Services, and any other preferences or requests you provide when interacting with us.

Generally, you are not obliged to provide us with your personal information. However, the use of certain Services or aspects of our Services may require the provision of personal information, e.g. the registration for a Tagged account. If this is the case, we will point this out to you. If you do not wish to provide us with the required information, you will unfortunately not be able to use the corresponding Service.

Personal Information Collected from Third Parties. We may also collect and receive certain personal information about you from third-party sources, such as from business partners especially when using app store providers for purchases, other EVINIE users, data analytics and marketing providers, operating systems and social media platforms especially when using the above described login functions, , In addition, we may collect the following information from third-party sources:

  • Social Media and Platform Registration Information. While using our Services, you may choose to share information or content, log into, or sign on to the Services through various social media platforms, social networking services, or other third-party features or integrated services. When you connect to our Services using your social media accounts or other similar integrated services and features, we may collect or receive personal information about you that you have provided to that social media account, service, or feature. For example, we may collect information from your account and profile, such as your name, email, user ID, profile picture, friend list, and other similar information available on your profile. You should check your privacy settings on each social media platform, feature, or integrated service to better understand how your personal information may be used, disclosed, or otherwise processed by these parties.
  • Referral Information. We may offer you the ability to invite friends or refer other users to access or use our Services. In doing so, we may collect and receive certain personal information about you, including from other current or prospective EVINIE users and customers who similarly engage in these activities.

Personal Information Collected Automatically. We and our third-party service providers may automatically collect or derive personal information about you related to your use of our Services, including through the use of cookies, pixel tags, and other similar technologies. The personal information we may automatically collect includes:

  • Device and Browsing Information. When you use our Services, we may collect browser type, domain name, page views, access times, date/time stamps, operating system, language, device type, unique ID, Internet service provider, referring and exiting URLs, clickstream data, operating system, language, and similar device and browsing information.
  • Activities and Usage. We also may collect activity information related to your use of the Services, such as information about the links clicked, searches, features used, items viewed, time spent within the Services, your interactions with us and others within the Services, and other similar activity and usage information.
  • Location Information. We also may collect or derive general location information about you, such as through your IP address.

For more information about our use of cookies and other similar technologies, please see Section 6. Cookies, Targeting, and Analytics below.

3. Purposes for Collection and Processing

Generally, we may collect, use, disclose and otherwise process the categories of personal information we collect for the following purposes:

  • Services and Support. To provide and operate our Services (e.g., Tagged or the Pets game feature), manage your account, communicate with you about your use of the Services, provide troubleshooting, technical support, or for similar support purposes, and to respond to your inquiries, fulfill your requests, facilitate payment processing, and to otherwise run our day-to-day operations. This includes making some of your personal information like your user ID, username, contact details like selected in your privacy settingsvisible to users of the respective Service or our other Services, and other applications we own and other applications and websites not owned by us with which we share our live platform. EVINIE relies on the legal basis "performance of a contract" (Art. 6 (1) (b) of the GDPR and UK GDPR and Art. 31 (2) (b) nDSG). As far as we process your personal information to make it visible to users of our other Services, and other applications we own and other applications and websites not owned by us with which we share our live platform, EVINIE relies on the basis "performance of a contract" (Art. 6 (1) (b) of the GDPR and UK GDPR and Art. 31 (2) (b) nDSG).

With respect to location data, EVINIE relies on your consent (Art. 6 (1) (a), Art. 7 GDPR).

With respect to sexual orientation, EVINIE relies on your explicit consent (Art. 6 (1) (a), Art. 7, Art. 9 (2) (a) GDPR/UK GDPR) or on the exception in Art. 9 (2) (e) GDPR/UK GDPR provided that you have publicly disclosed your sexual orientation (e.g., in a live stream).

  • Analytics and Improvement. To better understand how users access and use the Services, and for other research and analytical purposes, such as to evaluate and improve the Site, our Services, and business operations, including to develop our Services and its features, and for internal quality control and training purposes. EVINIE relies on the legal basis "legitimate interests" (Art. 6 (1) (f) GDPR/UK GDPR and Art. 31 (1) nDSG). In this regard, EVINIE pursues its interest in understanding how the service performs from a business perspective.

Communication. To respond to your questions, send you requested materials as well as information and materials regarding our Services and offerings. We may also use this information to send administrative information to you, for example, information regarding the Services and changes to our terms, conditions, and policies. EVINIE relies on the legal basis "performance of a contract" (Art. 6 (1) (b) GDPR/UK GDPR and Art. 31 (2) (a) nDSG) or - where no contract exists between the relevant user and EVINIE -- "legitimate interests" (Art. 6 (1) (f) GDPR/UK GDPR and Art. 31 (1) nDSG). Where EVINIE relies on "legitimate interests", EVINIE pursues its interests in providing support as well as to answer requests to ensure user satisfaction.

  • Customization and Personalization. To tailor content we may send or display on the Services, including to offer location customization and to otherwise personalize your experiences and offerings. EVINIE relies on the legal basis "performance of a contract" (Art. 6 (1) (b) of the GDPR and UK GDPR and Art. 31 (2) (b) nDSG.
  • Social Media and other Platform Communication. To enable you to share information or content, log into, or sign on to the Services through various social media platforms, social networking services, or other third-party features or integrated services. With respect to enabling you to log into or sign onto the Services, EVINIE relies on the legal basis "performance of a contract" (Art. 6 (1) (b) of the GDPR and UK GDPR and Art. 31 (2) (b) nDSG). Otherwise, EVINIE relies on the legal basis "legitimate interests" (Art. 6 (1) (f) GDPR/UK GDPR and Art. 31 (1) nDSG). In this regard, EVINIE pursues its interest in enabling users to initiate certain communications with social media platforms, social networking services, or other third-party features or integrated services if this is what they wish to do.
  • Marketing and Advertising. For marketing, advertising, and promotional purposes. For example, to send you promotional information about our Services, including newsletters, information about EVINIE events, webinars, presentations, sales, deals, discounts, and new offerings, as well as any other information that you sign up to receive. EVINIE relies on the legal basis "consent" Art. 6 (1) (a), Art. 7 GDPR and UK GDPR and Art. 31 (1) nDSG.

For the purposes of self-advertising / direct marketing through promotional emails and/or push messages, (user) surveys and individualized guides (exclusively EVINIE products). (The legal basis is EVINIE's legitimate interest in direct marketing for its own products, as well as Section 7 (3) of the German Act against Unfair Competition (UWG).

  • Research and Surveys. To administer surveys and questionnaires, such as for market research, user satisfaction, or other similar purposes. EVINIE relies on the legal basis "consent" Art. 6 (1) (a), Art. 7 GDPR and UK GDPR and Art. 31 (1) nDSG.
  • Insight Development and Data Enhancement. We may combine personal information collected through the Services with other information that we or third parties collect about you in other contexts. In most cases, the information that we may combine with the personal information collected through the Services for market research, such as demographic information, does not directly identify consumers. EVINIE relies on the legal basis "legitimate interests" (Art. 6 (1) (f) GDPR/UK GDPR and Art. 31 (1) nDSG). In this regard, EVINIE pursues its interest in understanding how the service performs from a business perspective.
  • Access and storage of information on the users end device. We may access or store information on your end device. EVINIE relies on the legal basis of "consent" Art. 5 (3) e-Privacy Directive and PECR Reg. 6(4) when this is not strictly necessary for the operation of our website as well as for the provision of telemedia services expressly requested by the user.
  • Planning and Managing Events. For event planning and other management-related purposes, such as event registration and attendance, connecting you with other event attendees and EVINIE users, and contacting you about relevant events, presentations, and our Services. We may also use personal information for purposes of facilitating special events, sweepstakes, contests, and promotions, which may have their own specific rules to participate. EVINIE relies on the legal basis "consent" Art. 6 (1) (a), Art. 7 GDPR and UK GDPR and Art. 31 (1) nDSG.
  • Security and Protection of Rights. To protect the Services and our business operations, our rights and those of our stakeholders and investors, to prevent and detect fraud, unauthorized activities and access, and other misuse of our Site, including where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third-party, or violations of our Terms and Conditions. EVINIE relies on the legal basis "legitimate interests" (Art. 6 (1) (f) GDPR/UK GDPR and Art. 31 (1) nDSG. The legitimate interest of EVINIE and the EVINIE users that the EVINIE service is not misused for contractual and / or illegal acts of third parties. Our legitimate interest is also the protection of our own systems of securing the IT of EVINIE and thus ultimately the protection of personal data of the users of EVINIE. With respect to sexual orientation, EVINIE additionally relies on the legal basis establishment, exercise or defence of legal claims (Art. 9 (2) (f) GDPR/UK GDPR).
  • Compliance and Legal Process. To comply with applicable legal or regulatory obligations, including statutory retention obligations or as part of a judicial proceeding, to respond to a subpoena, warrant, court order, or other legal process, or as part of an investigation or request, whether formal or informal, from law enforcement or a governmental authority. EVINIE relies on the legal basis of (i) "compliance with legal obligations" (Art. 6 (1) (c) GDPR/UK GDPR as well as Art. 31 (2) (a) nDSG) if this obligation stems from EU or EU Member State law, or (ii) "legitimate interest" (Art. 6 (1) (f) GDPR/UK GDPR as well as Art. 31(1) nDSG) if this obligation stems from other jurisdictions. Where legitimate interests are relevant, EVINIE pursues its interests in complying with the legal obligations to which EVINIE is subject. With respect to sexual orientation, EVINIE additionally relies on the legal basis establishment, exercise or defence of legal claims (Art. 9 (2) (f) GDPR/UK GDPR).
  • Auditing, Reporting, and Other Internal Operations. To conduct financial, tax and accounting audits, audits, and assessments of our operations, including our privacy, security, and financial controls, as well as for risk and compliance purposes. We may also use personal information to maintain appropriate business records and enforce our policies and procedures. EVINIE relies on the legal basis "legitimate interests" (Art. 6 (1) (f) GDPR/UK GDPR and Art. 31 (1) nDSG. The legitimate interest of EVINIE is to safeguard business operations and to regularly check whether reporting and compliance obligations are fulfilled.
  • General Business and Operational Support. To assess and implement mergers, acquisitions, reorganizations, bankruptcies, and other business transactions such as financings, and to administer our business, accounting, auditing, compliance, recordkeeping, and legal functions. EVINIE relies on the legal basis of "legitimate interest" (Art. 6(1)(f) DSGVO and Art. 31(1) nDSG). In this context, EVINIE has an interest in disclosing and otherwise processing information about its assets and activities to potential buyers or acquirers and their external advisors in order to facilitate the sale of those assets and/or activities.

The purposes pursued by us in connection with the use of cookies and similar technologies, particularly concerning targeting and analytics are described in Section 6. Cookies, Targeting, and Analytics.

When the legal basis for processing is your consent, you are entitled to withdraw your consent at any time. However, this withdrawal will not affect the lawfulness of any processing carried out on the basis of your consent before your withdrawal. If the legal basis is a legitimate interest, you are also entitled, in general, to object to the processing of your personal data, at any time, for reasons arising from your specific situation. Further, you have the right to object at any time to processing of your personal data for direct marketing purposes. Article 21 GDPR / UK GDPR applies in this respect.

You can object to our use of your email address for promotional purposes or personal guidance, upon registration or later at any time.

4. Disclosures of Personal Information

We may disclose the personal information we collect for the purposes described above, to provide you our Services, to respond to and fulfill your requests, as otherwise directed or consented to by you, and with the following recipients:

  • Brands, Affiliates, and Subsidiaries. We may disclose the personal information we collect with our brands, corporate affiliates, and subsidiaries.
  • Business Partners. In some circumstances, EVINIE may partner with other businesses to offer its Services, including to facilitate certain programs or special offerings, and we may disclose personal information to those business partners.
  • Vendors and Services Providers. We may disclose the personal information we collect to vendors and service providers who perform functions on our behalf, such as IT and website hosting, payment processors, marketing and marketing research providers, customer support, data storage, data analytics providers, auditors, consultants, advisors and agents, and legal counsel.
  • Other EVINIE Users. With other users of the Services in the context of specific features that are social in nature. For example, if you invite others to use our Services, or if you submit or make available information through our public-facing, interactive features, community forums, or discussion blogs, including when you post reviews or testimonials, certain personal information, may be available to, and searchable by, other users of the Services. For example, if you participate in Pets, other users of the Pets game feature will be able to see personal information such as your profile picture, gender, value, cash, assets, owned by and number of Pets.
  • Third-Party Marketing and Analytics Providers. We may also disclose your personal information, such as device and browsing, and activities and usage information, to third-party marketing and data analytics providers, and other companies who provide marketing, advertising, campaign management, or analytics services on our behalf. For a detailed overview of the specific recipients.

We may also disclose your personal information in the following circumstances:

  • In Support of Business Transfers. If we or our affiliates are or may be acquired by, merged with, or invested in by another company, or if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may disclose or transfer the personal information we have collected from you with or to the other company in accordance with applicable laws. We may also disclose certain personal information as necessary prior to the completion of such a transaction or other corporate transaction such as a financing or restructuring, to lenders, auditors, and third-party advisors, including attorneys and consultants.
  • Compliance and Legal Obligations. We may also disclose personal information to third parties to the extent required by applicable law and legal obligations. For example, we may disclose information in response to subpoenas, court orders, and other lawful requests by regulators, government entities, and law enforcement, including responding to national security or law enforcement disclosure requirements, or as otherwise required by law or legal process. In addition, and if applicable, we may disclose the names of sweepstakes and contests winners in accordance with applicable law.
  • Security and Protection of Rights. Where we believe doing so is necessary to protect the Services, our rights and property, or the rights, property, and safety of others. For example, we may disclose personal information to (i) prevent, detect, investigate, and respond to fraud, unauthorized activities and access, illegal activities, and misuse of the Services, (ii) situations involving potential threats to the health, safety, or legal rights of any person or third party, or (iii) enforce, detect, investigate, and take action in response to violations of our Terms and Conditions. We may also disclose personal information related to litigation and other legal claims or proceedings in which we are involved, as well as for our internal accounting, auditing, compliance, recordkeeping, and legal functions.
  • Other Disclosures. We may disclose personal information in other ways not described above that we notify you of or that we obtain your consent for, or that are otherwise authorized or required by law.

Notwithstanding anything else described in this Policy, we may use and disclose aggregated, deidentified, and other non-identifiable data related to our business and the Services for quality control, analytics, research, development, and other purposes. Where we use, disclose or process deidentified data (data that is no longer reasonably linked or linkable to an identified or identifiable natural person, household, or personal or household device) we will maintain and use the information in deidentified form and not to attempt to reidentify the information, except in order to determine whether our deidentification processes are reasonable and adequate pursuant to applicable privacy laws.

5. Transfers of personal data in the context of countries located outside the EEA/UK/CH

Recipients of personal data may be located outside the EEA/UK/Swiss. Where personal data is transferred to locations outside the EEA/UK/Swiss (which includes transfers from us in the USA as a controller in scope of GDPR / UK GDPR / nDSG to recipients in the USA or other countries outside the EEA/UK/Swiss, which are not in scope of GDPR/UK GDPR/nDSG), we will, as required by law, ensure that your privacy rights are adequately protected either because the European Commission has decided that the country to which personal data are transferred ensures an adequate level of protection (Art. 45 GDPR / UK GDPR) or the transfer is subject to appropriate safeguards (e.g. standard data protection clauses of the European Union agreed on with the recipient) (Art. 46 GDPR / UK GDPR) unless GDPR / UK GDPR provides for an exception (Art. 49 GDPR / UK GDPR). In addition to this, we intend to, where necessary, agree on additional measures with recipients to ensure an adequate level of data protection. See also Art. 16 f. nDSG regarding the disclosure of personal data outside of Switzerland.

If necessary, we also conclude a corresponding "UK Addendum" with our contractual partners in accordance with the requirements of the Information Commissioner's Office (ICO) and a corresponding "CH Addendum" in accordance with the requirements of the Swiss Federal Data Protection and Information Commissioner (FDPIC).

Copies of appropriate safeguards (to the extent we rely on such) and a list of recipients located outside the EEA/UK/Swiss can be requested under support@evinie.com  Please note that such copy may be redacted to the extent necessary to protect business secrets or other confidential information.

6. Cookies, Targeting, and Analytics

We and our third-party service providers use cookies, pixels, local storage objects, log files, and other tracking mechanisms to automatically collect browsing, activity, device, and other similar information within our Services. We use this information to analyze and understand how users access, use, and interact with our Services, to identify and resolve bugs and errors in our Services, to assess secure, protect, optimize and improve the performance of our Services, as well as for marketing and analytics purposes, and to personalize content in our Services. Depending on your location, most of this will only take place if you have provided your consent using our CMP which you can find in your app settings to manage your consent / preferences regarding cookies, targeted advertising, and other similar tracking mechanisms within our Services, please see Section 7. Your Privacy Choices below. Many of these choices are browser and device specific, which means that you may need to set the preference for each browser and device you use to access our Services. In addition, if you delete or block cookies, you may need to reapply these preferences to each browser and/or device.

Cookies. "Cookies" are small text files stored on a user's device (such as a computer or smartphone) by a website they visit. Cookies are created by the website's server and sent to the user's browser, where it is stored for future reference. Some cookies allow us to make it easier for you to navigate our Services, while others are used, for example, to enable a faster log-in process, support the security and performance of the Services, or allow us to track aggregate and statistical information about user activity within the Services.

Pixel Tags. Pixel tags (sometime called web beacons or clear GIFs) are tiny graphics with a unique identifier, similar in function to cookies. While cookies are stored locally on your device, pixel tags are embedded invisibly within web pages and online content. We may use these, in connection with our Services to, among other things, track the activities of users, and help us manage content and compile usage statistics. We may also use these in our emails to let us know when they have been opened or forwarded, so we can track response rates and gauge the effectiveness of our communications.

Log Files. We may collect certain activity information from log files. Log file information is automatically collected when you access our Sites. We record certain information from these log files, including web requests, IP address, browser type and version, language information, referring and exiting URLs, links clicked, pages viewed and other similar information.

Third-Party Analytics. We may use automated devices, applications, and tools, such as Google Analytics, which are operated by third-party companies, to evaluate usage of our Services. These third-party companies may use cookies, pixels, and other tracking technologies to collect usage data about our Services and provide us with reports and metrics that help us evaluate usage of our Services and enhance performance and user experiences. To learn more about Google's privacy practices, please review the Google Privacy Policy at https://www.google.com/policies/privacy/partners/. You can also download the Google Analytics Opt-out Browser Add-on to prevent your data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout. A list of the third parties engaged by us in this respect can be found in our CMP which you can find in your app settings.

Third-Party Advertising. We work with third-party ad networks, marketing partners, mobile ad networks, and others ("third-party ad companies") to personalize content and display advertising within our Services, as well as to manage our advertising on third-party websites. We and these third-party ad companies may use cookies, pixels tags, SDKs (software development kits), and other tools to collect browsing and activity information within our Services (as well as on third-party sites and services), as well as IP address, unique ID, cookie and advertising IDs, and other online identifiers. We and these third-party ad companies use this information to provide you more relevant ads and content within our Services and on third-party sites, and to evaluate the success of such ads and content. A list of the third-party ad companies can be found in our CMP which you can find in your app settings.

Cross-Device Use. We and our third-party service providers may use the information we collect about you (whether directly from our Sites or Mobile App, through your device(s), or from third party sources) to help us and our third-party service providers identify other devices you use (e.g., a mobile phone, tablet, other computer, etc.). We and our third-party service providers may also use the cross-device use and other information we learn about you to serve targeted advertising or personalize content within our Services.

Custom Lists and Matching. We may share or make available certain customer list information (such as your name, email address and other contact information) with third parties so that we can better target ads and content to you across third-party websites, platforms and services. In some cases, these third parties may help us to enhance our customer lists with additional demographic or other similar information so we can better target our advertising and marketing campaigns.

7. Your Privacy Choices

Managing Your Preferences. We make available several ways for you to manage your preferences and privacy choices, as described below:

  • Account and Profile. You can review and update some of the personal information we maintain about you by logging into your account and updating your account and profile information.
  • Marketing Communications. We may send periodic promotional emails, content, or other similar communications to you. You may opt-out of these communications by following the instructions provided to you in the communication. If you opt-out of receiving promotional content from us, we may still send you communications about your account or any services you have requested or received from us. Additionally, you can manage your communication preferences in your account and profile settings.
  • Push Notifications. You can manage the type of push notifications you receive from us by adjusting your mobile device settings or by modifying the settings within our Mobile App. These are messages that we send you in the course of fulfilling the contract, as well as promotional information.

Cookie and Tracking Preferences/Targeted Advertising/Analytics. We also make available several ways for you to manage your preferences regarding cookies, targeted advertising, analytics, and other similar tracking mechanisms within our Services. Many of these choices are browser and device specific, which means that you may need to set the preference for each browser and device you use to access our Services. In addition, if you delete or block cookies, you may need to reapply these preferences to each browser and/or device. Further, opting out of cookies and advertising does not mean that you will no longer receive advertising content from us, and you may continue to receive generic or "contextual" ads from us.

  • Consent Management Platform (CMP). To prevent cookies or other tracking mechanism which are not strictly necessary from tracking your activity on our Sites or in our Mobile App, you can use the consent management platform which is provided before the cookies and tracking mechanisms are used. Once a consent is given it can be withdrawn at any time with effect for the future. For more detailed information please review Section 15. Additional Privacy Information for Certain Jurisdictions, which includes additional information about privacy rights for residents of certain jurisdictions.
  • Cookie Settings. To prevent cookies from tracking your activity on our Sites or visits across multiple websites, you can set your browser to block certain cookies or notify you when a cookie is set. You can also delete cookies. The "Help" portion of the toolbar on most browsers will tell you how to prevent your device from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to delete cookies. Visitors to our Sites who disable cookies will be able to browse the Site, but some features may not function.
  • Browser Signals. To the extent required by applicable law, if our Sites detect that your browser is transmitting an opt-out preference signal, such as a "global privacy control" (or GPC) signal, we will apply that signal to opt that particular browser on your device out of targeting cookies on our Sites. If you come to our Sites from a different device or from a different browser on the same device, you will need to apply GPC for that browser and/or device as well.
  • Industry Ad Choice Programs. You can also control how participating third-party ad companies use the information that they collect about your visits to our Sites and those of third parties, in order to display more relevant targeted advertising to you. For more information and assistance related to web tracking mechanisms, visit www.YourOnlineChoices.com.

Residents of certain jurisdictions may have additional rights to their personal information, as set forth below in Section 15. Additional Privacy Information for Certain Jurisdictions.

8. Storage Period of Personal Information

We store your personal information for as long as it is necessary to pursue the purposes mentioned in Section 3 Purposes for Collection and Processing and Section 6 Cookies, Targeting, and Analytics or for as long as we have a legitimate interest in continued storage. In all other cases, we delete your personal information with the exception of information that we must continue to store in order to comply with statutory retention periods (e.g., resulting from tax or commercial law, such as concerning invoices). We restrict the processing of personal information that is only kept due to a retention obligation.

Information on the storage duration of cookies and other tracking mechanisms can be found in our CMP which you can find in your app settings.

9. External Links and Features

Our Services may contain links to third-party websites or features or provide certain third-party connections or integrated services. Any access to and use of such linked websites or features is not governed by this Policy, but instead is governed by the privacy policies of those third parties. We are not responsible for the information practices of such third parties, including their collection, use, and disclosure of your personal information. You should review the privacy policies and terms for any third parties before proceeding to those websites or using those features.

10. User Generated Content

We may offer public-facing interactive features, community forums, or discussion blogs in connection with our Services that enable you to share information about the Services, or other issues of interest (e.g., reviews, testimonials, and questions). You should be aware that any communications you submit or post to any such interactive features on the Services may be viewable and searchable by others, including EVINIE users and the public. By submitting or posting to such public-facing, interactive features you acknowledge that you have no expectation of privacy or confidentiality in the content you submit for such features, whether or not it contains personal information about you.

11. Security

We have implemented reasonable precautions aimed to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our best efforts, no data security measures can guarantee security.

12. Children's Privacy

Our Services are not designed for children, and we do not knowingly collect personal information from children under the age of eighteen (18). If we learn that personal information has been collected on the Services from persons under the age of 18, then we will take the appropriate steps to delete this information. If you are a parent or legal guardian and you believe we have collected your child's information in violation of applicable law, please contact us using the contact information below.

13. Changes to this Policy

This Policy is current as of the date set forth above. We may change, update, or modify this Policy from time to time, so please be sure to check back periodically. We will post any updates to this Policy here. If we make any changes to this Policy that materially affect our practices regarding our use of the personal information we have previously collected from you, we will endeavor to provide you with notice, such as by emailing you or by posting prominent notice on our Sites, in our Mobile App, or within the Services.

14. Contact Us

If you have any questions or concerns regarding this Policy or our privacy practices, you may email us at

15. Additional Privacy Information for Certain Jurisdictions

Residents of certain jurisdictions have additional rights under applicable privacy laws, as described in this section.

A. GDPR

If you are a resident of the European Union, you have the following rights under GDPR provided that the legal requirements therein are met:

Right of access - You may request information about the processing of your personal data and a copy of the personal data undergoing processing insofar as such copy does not adversely affect the rights and freedoms of others and no other exception applies.

Right to rectification - You may request correction of your personal data that is inaccurate and/or completion of such data which is incomplete.

Right to erasure - You may request deletion of your personal data, in particular where

  • the personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed,
  • you have withdrawn your consent on which the processing was based and there is no other legal basis for the processing,
  • you objected to the processing which is based on the legal basis "legitimate interests" and there are no overriding legitimate grounds for the processing or you objected to the processing for direct marketing purposes,
  • your personal data has been unlawfully processed or
  • your personal data has to be erased for compliance with a legal obligation to which we are subject.

The right to erasure, however, does not apply in particular where the processing of your personal data is necessary for compliance with a legal obligation or for the establishment, exercise or defence of legal claims.

Right to restriction of processing - You may request restriction of processing

  • for the period in which we verify the accuracy of your personal data if you contested the accuracy of the personal data,
  • where the processing is unlawful and you request restriction of processing instead of erasure of the data,
  • where we no longer need the personal data, but you require the data for the establishment, exercise, or defence of legal claims, or
  • if you objected to processing which is based on the legal basis "legitimate interests" until it has been verified whether our legitimate grounds override your interests, rights, and freedoms.

Right to data portability - You may request to receive your personal data, which you have provided to us, in a structured, commonly used machine-readable format and transmit those data to another controller without hindrance from us, where the processing is based on consent or the performance of a contract and the processing is carried out by automated means; in these cases, you may also request to have the personal data transmitted directly to another controller where this is technically feasible.

Furthermore, you have the following rights:

Right to withdraw consent - You may withdraw your consent at any time for the future where processing is based on your consent, without affecting the lawfulness of processing based on consent before its withdrawal.

Right to object -

You have the right to object, on grounds relating to your particular situation, at any time to processing of your personal data which is based on our or a third party's legitimate interest (Art. 6 (1) (f) GDPR). We then will no longer process your personal data for the purpose to which you have objected, unless we are able to demonstrate compelling legitimate grounds for the processing which override your interests, rights, and freedoms or for the establishment, exercise, or defense of legal claims.

Further, you have the right to object at any time to processing of your personal data for direct marketing purposes. Where you object to processing for direct marketing purposes, we will process your personal data no longer for such purposes.


Right to lodge a complaint - You may lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work, or place of an alleged infringement if you consider that the processing of your personal data infringes the GDPR.

B. UK GDPR

If you're located in the UK, under the UK GDPR and data protection laws, you have rights. Whether and to what extent the rights apply may depend upon the circumstances. To exercise any of these rights, please use the contact details provided below. The rights are:

Your right to be informed -- You have a right to receive concise, transparent, intelligible, and easily accessible information about your personal data and our use of it. This Policy is our way of informing you of that information but if you have any further questions or concerns, please use the contact information provided below.

Your right of access -- You have the right to ask us for copies of your personal data. This right always applies but there are some exemptions to its application, which means you may not always receive all the information you have requested. When you request your personal data, this is known as making a data subject access request (DSAR). We may need to ask you for identification documentation in order to verify your identity on receipt of a DSAR from you.

Your right to rectification -- You have the right to ask us to rectify personal data you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

Your right to erasure -- You have the right to ask us to erase your personal data in certain circumstances. We have the right to refuse to comply with a request for erasure if we are processing the personal data for one of the following reasons:

  • To exercise the right of freedom of expression and information.
  • To comply with a legal obligation.
  • To perform a task in the public interest or exercise official authority.
  • For archiving purposes in the public interest, scientific research, historical research or statistical purposes.
  • For the exercise or defence of legal claims.

Your right to restriction of processing -- You have the right to ask us to restrict the processing of your personal data in certain circumstances. In such case, we will still hold the data but will not process it any further. This right is an alternative to the right to erasure. If one of the following conditions applies, you may exercise the right to restrict processing:

  • The accuracy of the personal data is contested.
  • Processing of the personal data is unlawful.
  • We no longer need the personal data for processing, but the personal data is required for part of a legal process.
  • The right to object has been exercised and processing is restricted pending a decision on the status of the processing.

Your right to object to processing -- You have the right to object to processing in certain circumstances, including direct marketing. You can also object if the processing is on the basis of our legitimate interests (or those of a third party). We then will no longer process your personal data for the purpose to which you have objected, unless we are able to demonstrate compelling legitimate grounds for the processing which override your interests, rights, and freedoms or for the establishment, exercise, or defense of legal claims.

Your right to data portability -- This right is the right to receive your personal data in a structured, commonly used and machine-readable format but only applies if we are processing information based on your consent or for the performance of a contract and the processing is automated.

Right to withdraw consent - You may withdraw your consent at any time for the future where processing is based on your consent, without affecting the lawfulness of processing based on consent before its withdrawal.

Contact information

If you would like to exercise any of your rights or have any questions regarding our use of your personal data, please use the information under Contact Us . Please also ensure that when you do so, you provide sufficient information to enable us to clearly identify you.

Note that we have appointed a UK Representative for you to contact on our behalf pursuant to Art. 27 UK GDPR: eHarmony UK Ltd., 6-10 Great Portland Street, London W1W 8QL, Great-Britain

Transfers of personal information outside of the UK

For details on the protection and safeguards applied to your personal data when it is transferred outside of the United Kingdom, please see Section 5 Transfers of personal data in the context of countries located outside the EEA/UK/CH, above.

Right to lodge a complaint with a supervisory authority

You have the right to file a complaint with a data protection authority.

C. Swiss Data Protection Law

Your right of access -- You have the right to ask us for copies of your personal data. This right always applies but there are some exemptions to its application, which means you may not always receive all the information you have requested. When you request data, this is known as making a data subject access request (DSAR).

Your right to rectification -- You have the right to ask us to rectify personal data you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

Your right to erasure -- You have the right to ask us to erase your personal data in certain circumstances. We have the right to refuse to comply with a request for erasure if we are processing the personal data for one of the following reasons:

  • To exercise the right of freedom of expression and information.
  • To comply with a legal obligation.
  • To perform a task in the public interest or exercise official authority.
  • For archiving purposes in the public interest, scientific research, historical research or statistical purposes.
  • For the exercise or defence of legal claims.

Your right to restriction of processing -- You have the right to ask us to restrict the processing of your personal data in certain circumstances. In such case, we will still hold the data but will not process it any further. This right is an alternative to the right to erasure. If one of the following conditions applies, you may exercise the right to restrict processing:

  • The accuracy of the personal data is contested.
  • Processing of the personal data is unlawful.
  • We no longer need the personal data for processing, but the personal data is required for part of a legal process.
  • The right to object has been exercised and processing is restricted pending a decision on the status of the processing.

Your right to object to processing -- You have the right to object to processing in certain circumstances. You can also object if the processing is for a task carried out in the public interest, the exercise of official authority vested in you, or our legitimate interests (or those of a third party).

Your right to object to direct marketing - You can also object at any time to the processing of your personal data for advertising purposes ("advertising objection"). Please take into account that, for organizational reasons, there may be an overlap between your revocation and the use of your data in the context of an already ongoing campaign.

Your right to data portability -- This right only applies if we are processing information based on your consent or for the performance of a contract and the processing is automated.

If you would like to exercise any of your rights, please use the information under Contact Us. Please also ensure that when you do so, you provide sufficient information to enable us to clearly identify you.

Contact information

If you would like to exercise any of your rights or have any questions regarding our use of your personal data, please use the information under Contact Us . Please also ensure that when you do so, you provide sufficient information to enable us to clearly identify you.