Last updated: 29 OCTOBER 2020
PolyFinda supports polyamorous and other ethically non-monogamous people to connect with likeminded others online, in person or at events using a software application (“App”). PolyFinda is based in Victoria, Australia but offers its services to customers all over the world.
For the purposes of the GDPR, PolyFinda is both the “data controller” and a “data processor” of Personal Information and is responsible for how Personal Information is collected and used. This policy sets out how we collect, hold, protect, use or disclose your Personal Information when you access or use the PolyFinda website (“Website”), App, and other online products and services (collectively, the “Services”), contact our customer service team, engage with us on social media, and how you may access your Personal Information.
What information do we collect?
We collect and hold your Personal Information which may include your name, username, gender, date of birth, email address, telephone number, sexual orientation, relationship preferences, relationship status, photos, location and other information relating to you, your business or relevant to our supply of the Services to you.
We may also collect non-personally identifiable information about you (such as anonymous usage data, IP addresses and location, browser or platform type etc.)
Further examples of the information (including Personal Information) we collect are set out below.
How do we collect Personal Information?
We collect your Personal Information during the course of offering or providing the Services to you. This includes, without limitation, when you create an account on the App, participate in any interactive features of the Services, fill out a form, participate in a contest, promotion or event, or otherwise via customer enquiries and communications.
Generally, we collect your Personal Information directly from you or automatically through your use of our Services with your consent but we may also collect your Personal Information from other people or organisations if you have given your consent to them.
More detailed examples of the information we collect include:
Personal information you may give us when you use our Services or set up an account with us
- Identifying information such as your username, name, date of birth, address or email addresses when you use our Services, login or register for an account with us.
- Other content that you input or that is otherwise connected to your use of our Services or your account, including information you post on your account, or via the chat function with other users, as well as your photos and videos (for instance, if you want to publish a photo or video on the Services).
- You may also provide us other information through a web form, by updating or adding information to your account, through your communications with our support services teams, or when you otherwise communicate with us regarding our goods and services (including via our App).
Personal information we collect automatically when you use our Services or register for an account with us
We collect information about your interaction with our Services, your usage preferences, and your communications with us. This is information we receive from devices you use when you access our Services. This information could include the following:
- Location information (including location information from your mobile device (if applicable)).
- Computer and connection information such as statistics on your ad data and your IP address. We may also collection information about your page views, traffic to and from sites, referral URL, your browsing history, and your web log information, although we try to limit this where we can.
Personal information collected from other sources
- We supplement the personal information we collect directly from you with information collected from third parties. We try to minimise any sharing of personal data for commercial purposes but we may collect information from and share information with third party service providers, including marketing automation platforms, and email marketing service providers.
Sensitive Information collected from the App when you set up an account with us
- You may give us personal information which may be considered to be ‘sensitive information’, including your sexual orientation or practices, your relationship preferences and relationship status. By choosing to provide us with this information, you consent to our collection of that information.
Why do we need your Personal Information?
We only collect or hold your Personal Information for legitimate purposes, including to provide you with the Services, for the proper administration of the Services, to engage third party service providers (such as marketing automation platforms, and email marketing service providers) to assist us with providing you with our Services, and to comply with our legal obligations to you.
In particular, we need your Personal Information to:
- provide you with the Services we offer including creating an account, interacting with other users and engaging with our community via the App;
- maintain our business relationship with you by answering any questions or queries you may have about PolyFinda, our Services (including the App), communicating with you about the Services, creating and updating our database(s) and other records, providing sales and support services to you and otherwise responding to your enquiries;
- market and advertise to you including by sending you newsletters, special offers, and promotions, or otherwise contacting you about goods and services, or information we think may interest you.
- improve the quality and design of our services by storing, tracking, analysing and processing customer preferences and trends, as well as user activity on our Services to create new features, functionality and services in relation to the Services;
- comply with the law including by honouring any contractual obligations we may have with you; and
- exercise our legal rights including exercising rights we may have under law or a contract between us and you, or between us and a third party,
(together our “Required Purposes”)
If you do not provide us with your Personal Information, we may not be able to carry out all of the Required Purposes or fulfil our obligations arising under the Required Purposes.
Can you remain anonymous or use a pseudonym?
We will, if practicable, allow you to use a pseudonym or to not identify yourself (unless this is impractical or against the law). We also note that if you do not provide us with some or all of the Personal Information we request, we may not be able to provide you with the Services. This may also have an effect on whether we can begin or continue a relationship with you, and whether you can use or access our Services.
What disclosures do we make?
Generally speaking (and as described above under the heading “Why do we need your Personal Information”) we will disclose your Personal Information for our Required Purposes, including to other users on the Services, where you have made that information public. We may also disclose your Personal Information with your consent, or where we are authorised or required to do so by law, or to our related entities, partners or service providers (including hosting providers, security service providers, support service providers, marketing automation platforms, email marketing service providers) in order to assist us to provide the Services to you.
Some of our related entities, partners and service providers or the services they provide may be based outside of Australia (including in the United States). By providing us with your Personal Information, you acknowledge that your Personal Information may be used, stored and disclosed overseas, including in jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. To protect your Personal Information we take care to work with entities, partners and service providers who are based in countries that provide adequate levels of data protection, or we otherwise take steps to ensure that your Personal Information receives adequate levels of data protection in the jurisdictions in which it is processed in accordance with all applicable privacy laws (including the GDPR).
Personal Information of minors
We do not knowingly collect or solicit Personal Information from anyone under the age of 16 years of age or knowingly allow such persons to use the Services (including by registering an account on our App). If we become aware that we have collected personal information from a person under the age of 16 years without parental consent, we will take all reasonable steps to delete that information.
Do we use “cookies”?
When you use our Services, the server may attach a “cookie” to your device’s memory. A “cookie” assists us to store information about how you use our Services and allows us to make assumptions about what information may be of most interest to you. This information is generally not linked to your identity. We may use knowledge of your user experience to better understand what goods or services may be of interest to you and to collect statistical information.
Using other sites
Social Sharing Features
The Services may offer social sharing features and other integrated tools (such as the Facebook “Like” button), which let you share actions you take on our Services with other media, and vice versa. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.
Is your Personal Information confidential and secure?
We take all reasonable steps to keep your Personal Information secure and to ensure it is protected against misuse, loss, unauthorised access, modification or inappropriate disclosure. We may keep your Personal Information in both hard copy and electronic forms, but adopt appropriate technical and organisational security measures to protect it including by storing it in secure systems accessible only to authorised personnel.
We store the Personal Information we collect on you for as long as required for legitimate business purposes and otherwise in compliance with relevant privacy laws (including the GDPR and Australian privacy laws). Once an Account has been closed or deleted, we will stop storing your Personal Information and will delete any of your stored Personal Information.
We also urge you to take steps to keep your Personal Information safe, such as choosing a strong password and keeping it private, as well as logging out of your account on the App, and closing your web browser when you are finished using the Services on a shared or unsecured device.
Your choices and rights
We welcome your enquires and comments and encourage you to contact us to update your Personal Information if it changes. You may confirm if we are processing your Personal Information and request a copy of it. For your protection, however, we may require that you confirm your identity before we provide a copy of your Personal Information to you.
You may also update or correct your Personal Information by contacting us, or by amending your Personal Information on your account via our App.
In some instances, you may request that we delete your Personal Information. In accordance with and subject to relevant privacy laws (including the GDPR), you may object to certain Personal Information being processed and request that processing of your Personal Information be limited. You may also limit or manage our communications with you by “unsubscribing” from certain email, newsletter and marketing updates, and by deleting your account on our App.
If you choose to limit the Personal Information we process about you we may not be able to communicate with you or fulfil our Required Purposes outlined above. This may include limiting or ceasing your use of our Services, or otherwise ceasing to provide you with our Services.
Queries and complaints
If you have a question or want to make a complaint about how we handle your Personal Information please contact us using the details below. We will review any question, complaint or concern you may have and will respond to you after we have carefully considered it. We will, where reasonably possible, take steps to investigate and resolve complaints within 30 days. Please note, we may require further information from you in order to resolve any complaints. If we need more time, we will notify you about the reasons for the delay and seek to agree a longer period with you (if you do not agree, we may not be able to resolve your complaint).
We can be contacted at:
Polyamorous Pty Ltd
PO Box 5050, Kew, Australia 3101
email: [email protected]
For more information about privacy in Australia and protecting your privacy, please visit the OAIC website at www.oaic.gov.au.
For more information about the GDPR, please contact the European Data Protection Supervisor, the European Union’s independent data protection authority or visit their website at: https://edps.europa.eu/.
Last updated: 29 OCTOBER 2020