Last Modified Date: June 21th 2022

Privacy Policy

INTRODUCTION

Welcome to Siingly, the dating app for people who don’t like dating apps. Siingly, LLC (“Siingly”,”we”, “our”, or “us”) respects your privacy and we are committed to protecting it through our compliance with this Privacy Policy (“Policy”).

This Policy describes our practices for collecting, using, maintaining, protecting, and disclosing your information through https://Siingly.com/ (our “Website”), our Siingly mobile application (“App”) and related applications and platforms (collectively with the Website and App, our “Service” or “Services”).

A core element of our mission is our commitment to protect your personal information and to be transparent about the data we collect about you, how it is used, and with whom it is shared.

Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our terms, please reconsider using Siingly. Your continued access or use of our Services means you agree to this Privacy Policy. This Policy may also change from time to time (seeChanges to Our Privacy Policy). Your continued access of our Services after we make changes means you accept those changes, so please check the Last Modified Date at the top of this Policy to ensure that you are viewing the most current version of this Policy.

CHILDREN’S PRIVACY

The Service is general audience and intended for users 18 and older. We do not knowingly collect Personal Information from anyone younger than age 18. By using Siingly you agree that you are at least 18 years old.

INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT
In order to help you find your perfect match, we generally collect several types of information from you and about users of our Services, such as basic contact information when you sign up for an account as well as your personal interests and hobbies. Other types of information we collect is information related to how you use our platform, which helps us improve our Services.

Information You Provide to Us or Received by Us on Your Behalf

The categories of information we collect are:

  • Registration information: The first step towards meeting your match is to put yourself out there by registering an account. To register an account on Siingly, you will have to fill out a registration form, where we ask you to complete a basic profile. In the course of registering an account on our Services, filling out a contact form, and using our Services, we may require or otherwise collect information that identifies you as a specific individual and can be used to contact or identify you (“Personal Information”). This includes asking for your:

    • Login credentials;
    • Username;
    • Gender;
    • Date of birth;
    • Sexual preference;
    • Photographs and video recordings of yourself (please note that you may be asked to allow us access to your camera or photo album in order to post pictures or videos);
    • Email address; and
    • Mobile phone number.

  • Profile Information: You may choose to provide additional information to complete your profile, such as your personal preferences, location, hobbies, interests, physical appearance, relationship status, lifestyle preferences, education and occupation. Some of the information you choose to provide us may be considered “special” or “sensitive” in certain jurisdictions, for example your racial or ethnic origins, sexual orientation and religious beliefs. By choosing to provide this information, you consent to our processing of that information.

  • Non-Identifying Information: We also may collect non-identifying or non-personal information, such as zip codes, demographic data, time zone, publicly available data, and general information regarding your use of the Service (“Non-Identifying Information”).

  • Customer Service: When you contact our customer care team, we may collect information about your request as well as monitor or record the interaction to track and respond to your inquiry and analyze and improve our Services.

  • Referral information. When you refer a person to Siingly we will ask for that person’s email address. We will use their email address solely, as applicable, to make the referral, and we will let your contact know that you requested the communication. By participating in a referral program, you confirm that the person has given you consent for Siingly to communicate (e.g., via email) with him or her. The person you referred may contact us at info@siingly.com to request that we remove this information from our database.

  • Payment Information: We may also collect your payment information, such as credit card, billing address, and other financial information necessary to purchase a subscription or otherwise use our Services. We do not retain Payment Information. Rather, Payment Information is processed via third-party platforms such as the iTunes and Google Play.

  • User Content: You may have the ability to interact with parts of our Services, such as the ability to provide public ratings or testimonials. Your feedback may be published or displayed on public areas of the Services, or transmitted to other users or third parties (collectively, “User Content“). Your User Content is posted on and transmitted to others at your own risk. Although you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Service with whom you may choose to share your User Content. Therefore, we cannot and do not guarantee that your User Content will not be viewed or accessed by unauthorized persons. Use precaution when posting any personal information online. Please review our Terms of Service for more information about our User Content Guidelines.

When you provide us with information in connection with a particular activity or otherwise sign up for or order our products and Services or provide your contact information to us, including your email address or telephone number in connection with that activity, product or service, you agree that such action constitutes a purchase or inquiry establishing a business relationship with us. You expressly consent to receiving communications from Siingly through the information you provided to us. For more information on how to access and control your communication preferences, please seeYOUR RIGHTS AND CHOICES REGARDING YOUR INFORMATION, below.

Information Collected Automatically

As you navigate through and interact with our Service, we and our third-party service providers, including analytics and third-party content providers, may automatically collect certain information from you whenever you access or interact with the Service.

  • Usage Information. Details of your visits and activity on our App and Website, including which links you clicked on, content response times, logs, and other similar communication data and statistics about your interactions.

  • Device Information. Information about your computer and internet connection, including your Internet Protocol address, operating system, browser type, advertising IDs (such as Google’s AAID and Apple’s IDFA, both of which are randomly generated numbers that you can reset by going into your device’ settings), time zones, identifiers associated with cookies or other technologies that may uniquely identify your device or browser (e.g., IMEI/UDID and MAC address), and information on your wireless and mobile network connection, like your service provider and signal strength.

  • Other information with your consent. If you give us permission, we can collect your precise geolocation (latitude and longitude) through your GPS, Bluetooth or Wi-Fi connections. The collection of your geolocation may occur in the background even when you aren’t using the services if the permission you gave us expressly permits such collection. If you decline permission for us to collect your geolocation, we will not collect it.

We may combine this automatically collected log information with other information we collect about you. We do this to deliver features of our Services to you, improve services we offer you, analytics, and site functionality.

Do Not Track Signal

Do Not Track (DNT) is a privacy preference that users can set in some web browsers, allowing users to opt out of tracking by websites and online services. We do not honor browser requests not to be tracked online (known as “Do Not Track”), but our cookie policy below describes how you can opt out of receiving cookies.

Information Received from Third Parties
We also may receive information about you from third parties. For example, we and our partners, affiliates and service providers may use a variety of other technologies (such as tags) that collect statistical data relating to your activity for security and fraud detection purposes. Other users may also provide information about you, such as information provided through our referral feature.

Social Media Platforms
When you connect with us through a social media platform we may, depending on your privacy settings, receive some information from your social media account, and what we collect depends on your privacy settings with that service.

You may register to join the Service directly via the Service or by logging into your account with a social media platform (“SMP”) via our Service (e.g., Facebook, Twitter, and other third-party services that let you sign in using your existing credentials with those services). If you choose to register via an SMP, or to later link your account with the Service to your account with an SMP, we will use the Personal Information you have provided to the SMP (such as your name, email address, and other information you make available via the SMP) to create your account. Note that the information we collect from and through a SMP may depend on the privacy settings you have set with the SMP and the permissions you grant to us in connection with linking your account with the Service to your account with an SMP. Other than what we may share with the SMP, as described below, the Personal Information a SMP has obtained about you is independent of our Service, and Siingly is not responsible for it.

HOW WE USE YOUR INFORMATION
We use information that we collect about you or that you provide to us, including any personal information:

  • To provide you with an Account and our Services.
  • To process payment for our Services.
  • To analyze and improve our Services.
  • To address your inquiries.
  • To share your profile and help you connect with other users on the Services.
  • To tailor content we display to you and offer we may present to you.
  • To communicate and promote to you products, services, offers, and events offered by Siingly.
  • To comply with legal requirements and assist law enforcement.
  • To conduct research to improve our Services and notify you about improvements and changes to our Services.
  • To serve you relevant offers and advertisements (e.g. administer sweepstakes or promotions, communicate advertisements and content that we think may interest you).
  • To investigate fraud and to enforce our Terms of Service.
  • To protect the property rights of Siingly or a third party.
  • To protect the safety of the public or any person.
  • To stop any activity we may consider to be, or to pose a risk of being, illegal, fraudulent, unethical or a legally actionable activity.
  • To identify Siingly users.
  • For the purposes disclosed at the time you provide your information, and
  • As otherwise permitted with your consent.

Legal Bases
Under applicable law, including the European General Data Protection Act (GDPR), we require certain legal bases to process your information. We rely on the following legal bases to process your information:

  • Contractual Necessity: To provide you with the Siingly Service and perform the contract that you have with us.
  • Legitimate Interests: It is in our legitimate interests to improve and analyze our Service, promote our products, prevent fraudulent transactions, maintain security of our Services, and provide functionality.
  • Consent: In instances where we ask for consent, you may way withdraw your consent at any time by contacting us. Please see theContact Us section or more information.

HOW WE DISCLOSE AND SHARE YOUR INFORMATION
Generally, we do not share your Personal Information with third-parties other than to provide you with our Services. Where we do share your information, we do so to help you find matches, to help operate and improve our Service, and when it is required by law. Specifically, we share your information:

  • With other users on Siingly:

    • Your Profile Information and any other information you publicly disclose on our Services, including your User Content, will be viewable and shared with other users of Siingly. Depending on your profile settings, you may have the option of adjusting the visibility of your profile.
    • When you send messages, including video messages, to other users of Siingly or to Siingly, the content of the messages will be visible to the recipient as well as your username and the date and time the message was sent. Please use caution when sharing information about yourself with third parties.

  • With our service providers and network partners:

    • We employ third party companies and individuals to provide Services on our behalf, to perform Service-related operations (e.g., without limitation, maintenance services, database management, web analytics, payment processing, fraud detection and improvement of Siingly’s features) or to assist us in analyzing how our Service is used. These third parties may have access to your Personal Information in order to perform these tasks on our behalf.

  • With our advertising partners:

    • We may also share information with partners who assist us in advertising our services. For example, we may share limited information in hashed, non-human readable form to our advertising partners. All such partners and service providers are subject to a strict vetting process and confidentiality obligations prior to engagement.

  • For corporate transactions:

    • Siingly may share information, including Personal Information, with any current or future subsidiaries or affiliates, primarily for business and operational purposes. We may sell, transfer, or otherwise share some or all of our assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets (including, in each case, as part of the due-diligence process with any potential acquiring entity) or in the event of bankruptcy.

  • When required by law:

    • Siingly will share information with government agencies as required by law in response to lawful requests by public authorities, including to meet national security or law enforcement requirements and, including without limitation, in connection with reporting earnings. We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), or, at the request of governmental authorities or other third parties conducting an investigation where we determine in our sole discretion the disclosure is necessary to (a) protect the property and rights of Siingly or a third party, (b) protect the safety of the public or any person, or (c) prevent or stop activity we may consider to be, or pose a risk of being, illegal, fraudulent, unethical or legally actionable activity. We may also use Device Identifiers to identify Siingly Users, and may do so in cooperation with third parties at our discretion.

  • With your consent:
    • You may submit Personal Information to us through a form on the Services, choose to share your location with other users, and consent to receive communication from us or our business affiliates and non-affiliates based on the information in the form.

We may also share non-personal information (information that, by itself, does not identify you) such as device information, general demographics, and geolocation in non-identified form, with our service providers and third-party advertisers to develop, analyze and deliver targeted advertising on our Services. This information may be combined with additional non-personal information or personal information in hashed, non-human readable form collected from other sources, such as cookies and similar technology.

YOUR RIGHTS AND CHOICES REGARDING YOUR INFORMATION
At Siingly, we strive to provide you with choices regarding the information you provide to us. We offer you several ways to exercise control over your information:

  • Account Settings: Registered Siingly users may review, access, rectify or delete account and profile information provided to Siingly as well as update their choices regarding the types of communications you receive from us through your online account settings.

  • E-Mail: You also may opt-out of receiving marketing emails from us by following the opt-out instructions provided in those emails. Please note that we reserve the right to send you certain communications relating to your account or use of the Service (for example, administrative and service announcements) via email and other means and these transactional account messages may be unaffected if you opt-out from receiving marketing communications.

  • Device Settings: You may control permissions for specific types of device data and notifications, including the ability to turn off geo-location tracking via your device settings. If you turn these features off, you may lose the full functionality of the Services.

  • Contact Us: You may contact us with more information on your rights and choices regarding your personal information at info@siingly.com.

European Residents
Under the GDPR, Siingly is a data controller. European residents may access, rectify or delete their personal information via their online account settings as described above. Additionally, European residents may contact the Privacy Officer at info@Siingly.com to access, correct, update or delete your personal information; object to our processing of this information, ask us to restrict our processing of your personal information, or request portability of your personal information.

Upon request, Siingly will provide you with information about whether we hold any of your personal information. You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information. If you submit a request to access all personal information you’ve submitted, we will respond to your request to access within 30 days or as otherwise required by law.

We will use commercially reasonable efforts to honor your requests for deletion; however, certain residual information may actively persist on the Service even if you close your account. In addition, the rights described above may be limited, for example, if fulfilling your request would reveal personal information about another person, or if you ask us to delete information we are required by law to keep or have compelling legitimate interests in keeping (such as for fraud prevention purposes). Your Personal Information may remain in our archives and information you update or delete, or information within a closed account, may persist internally for our administrative purposes, to the extent permitted by law. It is not always possible to completely remove or delete information from our databases. In addition, we typically will not remove information you posted publicly through or on the Service. Bear in mind that neither you nor Siingly can delete all copies of information that has been previously shared with others on the Service. If your information is deleted, then your account may become deactivated. If your account is deactivated or you ask to close your account, you will no longer be able to use the Services.

Please note that our Services require a minimum amount of Personal Information in order to function. European residents who do not provide Personal Information on the App (e.g., by not filling out a profile) may not be able to access the full functionality of features found on Siingly.

California Residents
If you are a California resident, the California Consumer Privacy Act (CCPA) provides you with additional privacy rights with respect to our collection, use and disclosure of your Personal Information, including:

  • The right to know what Personal information we have collected and how we have used and disclosed that Personal Information in the 12-month period preceding your request;

    • Please see the above section within this Policy titled INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT, to see the categories of Personal Information we have collected about you.
    • Please see the above sections within this Policy titled HOW WE USE YOUR INFORMATION and HOW WE DISCLOSE AND SHARE YOUR INFORMATION, to see applicable use and disclosures of your Personal Information.

  • The right to request deletion of your Personal Information, and;

    • Please see the above section within this Policy titled YOUR RIGHTS AND CHOICES REGARDING YOUR INFORMATION

  • The right to be free from discrimination related to the exercise of any of your privacy rights.

    • We do not discriminate against California residents who exercise their privacy rights.

  • The right to opt out of the sale of your personal information, and to request information about whether we have sold your personal information in the past 12 months.

For more information on how to exercise your rights, please contact us at info@Siingly.com. Please note that we may require you to verify your credentials, by matching your e-mail address, or other account information to the information in our systems, before you can submit a request to exercise any of these rights. If you authorize another person to act as your agent to submit requests on your behalf, then unless you provide the agent with power of attorney under the California Probate Code, we will ask the agent to provide us the written and signed authorization that you provided to the agent, we will confirm with you that you did provide the authorization, and we will verify your identity.

INTERNATIONAL JURISDICTIONS
Our Services are hosted and offered in the United States of America (US), and are subject to US federal, state, and local law. If you are accessing the Services from another country, please be advised that you may be transferring your personal information to us in the US, and you consent to that transfer, processing and storage of your personal information in accordance with this Privacy Notice. You also agree to abide by the applicable laws of applicable US federal, state, and local laws concerning your use of the Services and your agreements with us. Any persons accessing our Services from any jurisdiction with laws or regulations governing the use of the Internet, including the collection, use, or disclosure of personal information, different from those of the jurisdictions mentioned above may only use the Services in a manner lawful in their jurisdiction. If your use of the Services would be unlawful in your jurisdiction, you may not use our Services.

SECURITY
We use physical, technical and organizational measures designed to protect your information against unauthorized access, theft and loss. We restrict access to your personal information to those employees who need to know that information to service your account or perform their job functions.

Although we take precautions intended to help protect information that we process, no system or electronic data transmission is completely secure. Any transmission of your personal data is at your own risk and we expect that you will use appropriate security measures to protect your personal information.

You are responsible for maintaining the security of your account and the information in your account. We may suspend your use of all or part of the Services without notice if we suspect or detect any breach of security. You understand and agree that we may deliver electronic notifications about breaches of security to the email address on record on your account.

DATA RETENTION
Unless you request that we delete certain information (see Your Rights and Choices Regarding Your Information), We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

The criteria used to determine our retention periods include:

  • The length of time we have an ongoing relationship with you and provide services to you (for example, for as long as you have an account with us or keep using the Services);

  • Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them)

  • Whether retention is advisable; and considering our legal position (such as, for statutes of limitations, litigation or regulatory investigations).

LINKS TO OTHER SITES
Our Services may include links to third-party websites and services that are not operated by us. When you click these links, you will be directed away from our Services. A link to a third-party website or service does not mean that we endorse it or the quality or accuracy of information presented on it. If you decide to visit a third-party website or service, you are subject to its privacy practices and policies, not ours. This Privacy Policy does not apply to any personal information that you provide to these other websites and services.

CHANGES TO THIS POLICY
Siingly may update this Privacy Policy at any time and any changes will be effective upon posting. In the event that there are material changes to the way we treat your Personal Information, we will update the Last Modified date at the top of this Policy upon becoming effective. We may also notify you by email, in our discretion.

HOW TO CONTACT SIINGLY
If you have any questions about this Privacy Policy, please contact us at info@Siingly.com



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