Privacy Policy

Privacy

OUR COMMITMENT TO YOU

At Aria, your privacy is a top priority. Your privacy is at the core of the way we design and build the services and products you know and love, so that you can fully trust them and focus on building meaningful connections.

We appreciate that you put your trust in us when you provide us with your information and we do not take this lightly.

Our commitment to privacy. We design all of our products and services with your privacy in mind. We involve experts from various fields, including legal, security, engineering, product design and others to make sure that our decisions are taken with the utmost respect for your privacy.

Our commitment to transparency. Because we use many of the same online services you do, we know that insufficient information and overly complicated language are common issues in privacy policies. We take the exact opposite approach: we’re doing our best to write our Privacy Policy and related documents in plain language. We actually want you to read our policies and understand our privacy practices!

Our commitment to security. We have teams dedicated to keeping your data safe and secure. We constantly update our security practices and invest in our security efforts to enhance the safety of your information.

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Welcome to Aria Privacy Policy. Thank you for taking the time to read it.

We appreciate that you trust us with your information and we intend to always keep that trust. This starts with making sure you understand the information we collect, why we collect it, how it is used and your choices regarding your information. This Policy describes our privacy practices in plain language, keeping legal and technical jargon to a minimum.

This Privacy Policy applies from January 24, 2023.

WHO WE ARE

The brand "Aria" is operated by RINGLE DATING LTD.

WHERE THIS PRIVACY POLICY APPLIES

This Privacy Policy applies to websites, apps, events and other services we operate under the brand Aria. For simplicity, we refer to all of these as our “services” in this Privacy Policy. To make it extra clear, we’ve added links to this Privacy Policy on all applicable services.

Some services may require their own unique privacy policy. If a service has its own privacy policy, then that policy -- not this Privacy Policy -- applies.

INFORMATION WE COLLECT

It goes without saying, we can’t help you develop meaningful connections without some information about you, such as basic profile details and the types of people you’d like to meet. We also collect information about your use of our services such as access logs, as well as information from third parties, If you want additional info, we go into more detail below.

Information you give us

You choose to give us certain information when using our services. This includes:

· When you create an account, you provide us with at least your login credentials and/or phone number, as well as some basic details necessary for the service to work, such as your gender and date of birth.

· When you complete your profile, you can share with us additional information, such as details on your personality, lifestyle, interests and other details about you, as well as content such as photos. To add certain content, like pictures, you may allow us to access your camera or photo album.

· When you participate in surveys, focus groups or market studies, you give us your insights into our products and services, responses to our questions and testimonials.

· When you choose to participate in our promotions, events or contests, we collect the information that you use to register or enter.

· If you contact us (for example, through our customer care team or on social media), we collect the information you give us during the interaction.

· If you share with us information about other people (for example, if you use contact details of a friend for a given feature), we process this information on your behalf in order to complete your request.

· Of course, we also process your chats with other users as well as the content you publish, as necessary for the operation of the services.

Information we receive from others

In addition to the information you may provide us directly, we receive information about you from others, including:

· Users

Users may provide information about you as they use our services, for instance as they interact with you or if they submit a report involving you.

· Other Partners

We may receive information about you from our partners, for instance where Aria ads are published on a partner’s service (in which case they may pass along details on a campaign’s success). Where legally allowed, we can also receive information about suspected or convicted bad actors from third parties as part of our efforts to ensure our users’ safety and security.

Information generated when you use our services

When you use our services, this generates technical data about which features you’ve used, how you’ve used them and the devices you use to access our services. See below for more details.

· Usage Information

Using the services generates data about your activity on our services, for instance how you use them (for example, when you logged in, features you’ve been using, actions taken, information shown to you, referring webpages address and ads that you interacted with) and your interactions with other users (for example, users you connect and interact with, when you exchanged with them, number of messages you send and receive).

· Device Information

We collect information from and about the device(s) you use to access our services, including hardware and software information such as IP address, device ID and type, apps settings and characteristics, app crashes, advertising IDs (which are randomly generated numbers that you can reset by going into your device’s settings).

· Other Information with your Consent

If you give us permission, we can collect your precise geolocation (latitude and longitude). 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 precise geolocation, we will not collect it. Similarly, if you consent, we may collect photos and videos (for instance, if you want to publish a photo or video or participate in streaming features on our services).

HOW WE USE INFORMATION

The main reason we use your information is to deliver and improve our services. Additionally, we use your information to help keep you safe, and to provide you with advertising that may be of interest to you. Read on for a more detailed explanation of the various reasons for which we use your information, together with practical examples.

1. To administer your account and provide our services to you

o Create and manage your account

o Provide you with customer support and respond to your requests

o Personalize pricing and complete your transactions

o Communicate with you about our services

o Administer sweepstakes, contests, discounts or other offers

2. To help you connect with other users

o Recommend you other users to meet

o Show users’ profiles to one another

3. To operate advertising and marketing campaigns

o Perform and measure the effectiveness of advertising campaigns on our services and marketing campaigns promoting Aria on and off our services

o Communicate with you about products or services that we believe may interest you

4. To improve our services and develop new ones

o Administer focus groups, market studies and surveys

o Review interactions with customer care teams to improve our quality of service

o Understand how users typically use the services to improve them (for instance, we may decide to change the look and feel or even substantially modify a given feature based on how users react to it)

o Develop new features and services (for example, we may decide to build a new interests-based feature further to requests received from users)

5. To prevent, detect and fight fraud and other illegal or unauthorized activities

o Find and address ongoing, suspected or alleged violations of our Terms of Use, notably through the review of reports and interactions between members

o Better understand and design countermeasures against violations of our Terms of Use

o Retain data related to violations of our Terms of Use to prevent against recurrences

o Enforce or exercise our rights, for example our Terms of Use

o Communicate to users what we’ve done as a result of their reports

6. To ensure legal compliance

o Comply with legal requirements

o Assist law enforcement

For information on how we process personal information through profiling and automated decision-making, please scroll to end of the page to FAQ section.

To process your information as described in this Privacy Policy, we rely on the following legal bases:

· Provide our service to you: The reason we process your information for purposes A and B above is to perform the contract that you have with us. For instance, as you go about using our service to build meaningful connections, we use your information to maintain your account and your profile, make it viewable to other users and recommend other users to you and to otherwise provide our free and paid features.

· Legitimate interests: We process your information for purposes C, D and E above, based on our legitimate interest. For instance, we analyze users’ behavior on our services to continuously improve our offerings, we suggest offers we think might interest you and promote our own services, we process information to help keep our users safe and we process data where necessary to enforce our rights, assist law enforcement and enable us to defend ourselves in the event of a legal action.

· Comply with applicable laws and regulations: We process your information for purpose F above where it is necessary for us to comply with applicable laws and regulations and evidence our compliance with applicable laws and regulations. For example, we retain traffic data and data about transactions in line with our accounting, tax and other statutory data retention obligations and to be able to respond to valid access requests from law enforcement. We also keep data evidencing consents users give us and decisions they may have taken to opt-out of a given feature or processing.

· Consent: If you choose to provide us with information that may be considered “special” or “sensitive” in certain jurisdictions, such as your sexual orientation, you’re consenting to our processing of that information in accordance with this Privacy Policy. From time to time, we may ask for your consent to collect specific information, such as your precise geolocation, or use your information for certain specific reasons. In some cases, you may withdraw your consent by adapting your settings (for instance in relation to the collection of precise geolocation) or by deleting your content (for instance where you entered information in your profile that may be considered “special” or “sensitive”). In any case, you may withdraw your consent at any time by contacting us at the address provided at the end of this Privacy Policy.

HOW WE SHARE INFORMATION

Since our goal is to help you make meaningful connections, the main sharing of users’ information is, of course, with other users. Read on for more details about how your information is shared with others.

· With other users

You share information with other users when you voluntarily disclose information on the service (including your public profile). Please be careful with your information and make sure that the content you share is stuff that you’re comfortable being visible.

If you choose to limit the audience for all or part of your profile or for certain content or information about you, then it will be visible according to your settings.

If someone submits a report involving you (such as a claim that you violated our Terms of Use or Community Guidelines), we may communicate to the reporter actions, if any, we took as a result of their report.

We may transfer your information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control.

· With law enforcement / when required by law

We may disclose your information if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government / law enforcement investigation or other legal requirements; (ii) to assist in the prevention or detection of crime (subject in each case to applicable law); or (iii) to protect the safety of any person.

· To enforce legal rights

We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our users, business partners or other interested parties; (iii) to enforce our agreements with you; or (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.

· With your consent or at your request

We may ask for your consent to share your information with third parties. In any such case, we will make it clear why we want to share the information.

We may use and share non-personal information (meaning information that, by itself, does not identify who you are such as device information, general demographics, general behavioral data, geolocation in de-identified form).

YOUR RIGHTS

We want you to be in control of your information, so we want to remind you of the following options and tools available to you:

· Access / Update tools in the service. Tools and account settings can help you access, rectify or remove information that you provided to us and that’s associated with your account directly within the service. If you have any questions on those tools and settings, please contact our customer care team for help mati@mndy.org

· Device permissions. Mobile platforms can have permission systems for specific types of device data and notifications, such as phone contacts, pictures, location services, push notifications and advertising identifiers. You can change your settings on your device to either consent or oppose the collection or processing of the corresponding information or the display of the corresponding notifications. Of course, if you do that, certain services may lose functionality.

· Uninstall. You can stop all information collection by an app by uninstalling it using the standard uninstall process for your device. Remember that uninstalling an app does NOT close your account. To close your account, please use the corresponding functionality on the service

· Account closure. You can close your account by using the corresponding functionality directly on the service.

We also want you to be aware of your privacy rights. Here are a few key points to remember:

· Reviewing your information. Applicable privacy laws may give you the right to review the personal information we keep about you (depending on the jurisdiction, this may be called right of access, right of portability, right to know or variations of those terms). You can exercise this right by putting in such a request mati@mndy.org

· Updating your information. If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, object to or restrict its processing, please contact us mati@mndy.org

For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer the above requests.

Keep in mind, we may reject requests, including if we are unable to authenticate you, if the request is unlawful or invalid, or if it may infringe on trade secrets or intellectual property or the privacy or other rights of someone else. If you wish to receive information relating to another user, such as a copy of any messages you received from them through our service, the other user will have to contact us to submit a separate request for their information. We may also ask them to provide proof of identity before we can answer the request.

Also, we may not be able to accommodate certain requests to object to or restrict the processing of personal information, notably where such requests would not allow us to provide our service to you anymore. For instance, we cannot provide our service if we do not have your date of birth and thus cannot ensure that you are 18 years of age or older.

HOW LONG WE RETAIN YOUR INFORMATION

We keep your personal information only as long as we need it for legitimate business purposes (as laid out in Privacy Policy) and as permitted by applicable law. If you decide to stop using our services, you can close your account and your profile will stop being visible to other users. Note that we will close your account automatically if you are inactive for a period of two years. After your account is closed, we will delete your personal information, as laid out below:

1. To protect the safety and security of our users, we implement a safety retention window of three months following account closure. During this period, we keep your information in the event that it might be necessary to investigate unlawful or harmful conducts. The retention of information during this safety retention window is based on our legitimate interest as well as that of potential third-party victims.

2. Once the safety retention window elapses, we delete your data and only keep limited information for specified purposes, as laid out below:

1. We maintain limited data to comply with legal data retention obligations: in particular, we keep transaction data to comply with tax and accounting legal requirements, credit card information, if any, for the duration the user may challenge the transaction and “traffic data” / logs for one year to comply with legal data retention obligations. We also keep records of consents users give us for five years to evidence our compliance with applicable law.

2. We maintain limited information on the basis of our legitimate interest: we keep customer care records and supporting data as well as imprecise location of download / purchase(s) to support our customer care decisions, enforce our rights and enable us to defend ourselves in the event of a claim, profile data in anticipation of potential litigation, for the establishment, exercise or defense of legal claims, and data necessary to prevent users who were banned or people who were found to be under the age of 18 from opening a new account, to ensure the safety and vital interests of our users.

3. Finally, we maintain information on the basis of our legitimate interest where there is an outstanding or potential issue, claim or dispute requiring us to keep information, in particular if we receive a valid legal subpoena or request asking us to preserve data (in which case we would need to keep the data to comply with our legal obligations) or if data would otherwise be necessary as part of legal proceedings.

CHILDREN’S PRIVACY

Our services are restricted to individuals who are 18 years of age or older. We do not permit individuals under the age of 18 on our platform. If you suspect that a user is under the age of 18, please use the reporting mechanism available on the service.

JOB CANDIDATES, CONTRACTORS AND VENDOR REPRESENTATIVES

We also process the personal information of our job candidates, contractors and vendor representatives, as part of our recruitment and talent management operations and our management of the services that contractors and vendors provide to us. If you are a job candidate, contractor or vendor representative of Aria , certain relevant terms of this Privacy Policy apply to our processing of your personal information, including the sections of this Privacy Policy that discuss the entity that is responsible for the processing of your personal information, transfers of personal information,rights you may have under applicable law and how to contact us.

If you are a job applicant, the personal information we process about you may vary depending on the job you seek but typically includes what you provide to us as part of your job application as well as professional qualifications, background and reference information that recruiters or other third parties share with us. We use this information to support the recruitment process, which may lead to an employment contract. For contractors and vendor representatives, we may process identification information and work-related information, as necessary to manage our relationship with you and your employer, which is necessary for the performance of the services agreement, and to establish, exercise or defend potential legal claims. We may share personal information with service providers that assist us with recruitment and technical data processing operations. We keep your personal information only as long as necessary for those purposes.

Because we’re always looking for new and innovative ways to help you build meaningful connections and strive to make sure explanations about our data practices remain up-to-date, this policy may change over time. We will notify you before any material changes take effect so that you have time to review the changes.

HOW TO CONTACT US

mati@mndy.org

FAQ

Profiling and automated decision-making at Aria

At Aria, your privacy is our top priority. It is at the core of the way we design and build the services and products you know and love, so that you can fully trust them and focus on building meaningful connections.

As part of our commitment to transparency in the way we process your information, we explain here what automated decision-making and profiling are, why it is at the very heart of our service (in fact, it’s probably the reason you love using our products!) and how you benefit from it.

What is automated decision-making and profiling?

Europe’s data protection framework, the General Data Protection Regulation (“GDPR”), provides the following definitions:

· Automated individual decision-making: making a decision about an individual solely by automated means (i.e., using computers and algorithms only, without any human involvement in the decision-making process);

· Profiling: evaluating certain things about an individual, including interests, preferences or behavior, through an automated processing of personal data (e.g., using computers and algorithms to determine someone’s interests based on his or her online behavior).

Does Aria rely on automated decision-making or profiling?

Automated decision-making and profiling are invisible features that are at the core of the services you know and love, upon which we constantly improve and without which we would be unable to help you find the relationship you’re looking for.

We use these features for the following reasons:

· To allow you to build meaningful connections with other users.

We use the information you and other users provide us (such as your profile), along with information we collect from your use of our service (like your location, should you allow us to collect it), to power our best-in-class matching algorithm and recommend the most compatible people to you, based on a number of criteria, including the attributes you told us (or we noticed) you like, common interests and location. Of course, we use the same process to recommend you to other users.

· Show you ads and offers that may be of interest to you.

We use information about you to show you useful and relevant ads on and off our service and measure the effectiveness of these ads. We also use information about you to deliver offers and discounts tailored to your profile.

· To promote safety and security.

We use automated decision-making and profiling as part of our moderation efforts, as well as to promote the safety and security of our users by making it easier to prevent illegal and unauthorized actions from happening and to swiftly and efficiently detect and fight those actions when they happen.

This processing may have a significant impact on users found to be carrying out illegal or unauthorized activities, including suspension and account closure, without prejudice to other legal actions we could take.