Polityka prywatności

1. GENERAL PROVISIONS

The following definitions are used in this document:

“Company” or “We” or “Our” or “Us” means:

CASHMORE LIMITED
A limited liability company registered in Cyprus
Registration number: ΗΕ 474948
Registered address: Κυπράνορος, 13, EVI BUILDING, Floor 1, Flat 103C,
1061, Λευκωσία, Cyprus
Email: contact@exclusivedates.com
Website: https://www.exclusivedates.com

“GDPR” means Regulation (EU) 2016/679 (General Data Protection Regulation).

“Policy” means this Privacy Policy.

“Services” means the services provided by the Company through the Website and the mobile application.

“Website” or “Exclusive Dates” means the website https://www.exclusivedates.com/ and the mobile application through which the Services are provided.

“You” or “User” means a user of the Website over 18 years of age.

Purpose of this Policy:

This Policy was created to protect and ensure the security of the User’s information. After reading this Policy, the user will understand how we collect, use, and protect their personal data when using the Website and the Services.

Exclusive Dates values the privacy of its Users and works every day to ensure appropriate security for their sensitive data in accordance with the GDPR and/or other applicable laws and regulations.

By Personal Data or Data, we mean any information relating to an identified or identifiable living person, including information that may identify the user as an individual or may be linked to them indirectly, which we collect, store, use, process, disclose, share, and transfer when the user visits our Website and uses the Services provided through it.

This Policy does not apply to any websites, applications, or services that we do not own or control.

We reserve the right to modify or change this Policy at our sole discretion. If we make updates or material changes to this Policy, we will post them on the Website with a new effective date and notify Users electronically.

Data protection contact:

If you have any questions regarding this Policy or your data, please contact us at:

Email: contact@exclusivedates.com

Phone: [TO BE COMPLETED]

Postal address: Κυπράνορος, 13, EVI BUILDING, Floor 1, Flat 103C, 1061, Λευκωσία, Cyprus

Support hours: [TO BE COMPLETED]

Support languages: Polish, English

2. DATA CONTROLLER

The controller of Personal Data processed when using Exclusive Dates in accordance with this Policy is:

CASHMORE LIMITED
Limited liability company
Registration number: ΗΕ 474948
Address: Κυπράνορος, 13, EVI BUILDING, Floor 1, Flat 103C, 1061, Λευκωσία, Cyprus
Email: contact@exclusivedates.com

3. COLLECTION, PROCESSING AND USE OF USER DATA

When using the Website, the user may be asked to provide information that allows us to identify them as an individual to ensure security for the user and other users while using the Website.

Categories of personal data collected:

The Company acts as a data controller, and the Service collects, among others, the following Personal Data:

• Date of birth
• Email address
• First and last name and username
• User’s IP address
• User photos
• Geographical location
• Information about the user’s device (browser type, operating system type, device model)
• In-app activity data (logs, search history, preferences)
• Information provided when making payments on the Website
• Social media profile data (if the user links their accounts)

Legal bases for processing:

We process Personal Data on the following legal bases under Article 6 of the GDPR:

a) Consent (Art. 6(1)(a) GDPR):
Direct marketing (except where based on legitimate interest)
Optional app features requiring additional permissions

b) Performance of a contract (Art. 6(1)(b) GDPR):
Provision of dating services
Processing payments and subscriptions
User account management

c) Legitimate interests (Art. 6(1)(f) GDPR):
Ensuring platform security
Preventing fraud and abuse
Analytics and service improvement
Direct marketing (in a limited scope)

d) Legal obligation (Art. 6(1)(c) GDPR):
Retention of accounting records
Co-operation with law enforcement

Purposes of processing:

We collect personal data for the following purposes:

• Providing and improving our services
• Personalizing the user experience
• Processing payments and subscriptions
• Communicating with the user about their account and providing customer support
• Ensuring security on our website and in the app
• Conducting research and analysis to improve the User experience
• Preventing fraud and abuse
• Fulfilling legal obligations

User profiling:

We inform you that, as part of the services provided, we may use profiling, which includes:

• Analyzing user preferences to better match profiles
• Personalizing displayed content and ads
• Detecting potential fraud and fake profiles

The user has the right to object to profiling in accordance with Section 6 of this Policy.

4. DISCLOSURE OF PERSONAL DATA

The Company does not sell personal data. However, we may disclose certain data to the following categories of recipients:

• Payment method providers used on the Website (these companies may be located anywhere in the world)
• Hosting, maintenance, and security service providers used by Exclusive Dates to operate and maintain the Website
• Government authorities, including tax authorities and the police (based on applicable law)
• Analytics companies (for example, Google Analytics)
• Marketing companies that collect Personal Data from various online sources to conduct marketing research and deliver advertising services
• Cloud service providers for data storage and processing
• Technology partners supporting the functioning of the application

Transfers to third countries:

Some of our service providers may be located outside the European Economic Area (EEA). In such cases, we ensure an adequate level of data protection by:

• Using providers covered by a European Commission adequacy decision
• Applying European Commission–approved Standard Contractual Clauses
• Compliance certifications (e.g., Privacy Shield for U.S. companies, where applicable)

5. DATA STORAGE

Retention periods:

Exclusive Dates stores and processes the User’s Personal Data for the following periods:

• Active account data: For as long as the User’s account exists or as necessary to operate and provide the Services.
• After account closure:
  • Profile data: we will delete without undue delay, and no later than within 30 days
  • Accounting and payment data: 7 years (legal obligation)
  • Security logs: 2 years (legitimate interest)
  • Marketing data: until consent is withdrawn

Exceptions to deletion:

We may retain data longer if:

• The Company must retain the Data due to legal, tax, audit, or accounting obligations
• There is an unresolved issue related to the user’s account (outstanding credit, legal dispute)
• It is necessary to pursue legitimate business interests (fraud prevention, security)
• The data has been anonymized and no longer enables identification of the user

6. USER RIGHTS

Under the GDPR, the User has the following rights:

Right of access (Art. 15 GDPR):
To receive a copy of their personal data and information on processing purposes, data categories, and recipients.

Right to rectification (Art. 16 GDPR):
To correct inaccurate or incomplete personal data.

Right to erasure (Art. 17 GDPR):
The user may request deletion of their Personal Data if:

• The data is no longer needed for the purposes for which it was collected
• The user withdraws consent (where consent is the basis)
• There is no legitimate interest for further processing
• The data was processed unlawfully

Right to restriction of processing (Art. 18 GDPR):
For example, when data accuracy is contested or processing is unlawful and the user opposes deletion.

Right to data portability (Art. 20 GDPR):
To receive data in a structured, commonly used format and transmit it to another controller.

Right to object (Art. 21 GDPR):
The user may object to processing where:

• Processing is based on legitimate interests
• Direct marketing (absolute right to object)
• Profiling related to direct marketing

Right to withdraw consent:
Where processing is based on consent. Withdrawal does not affect the lawfulness of processing before withdrawal.

How to exercise your rights:

To exercise the above rights, please contact us:

Email: contact@exclusivedates.com

Response time: up to 30 days from receipt of the request.

Right to lodge a complaint:

The user has the right to lodge a complaint with a supervisory authority:

• In Cyprus: Office of the Commissioner for Personal Data Protection
• In Poland: President of the Personal Data Protection Office (for processing of Polish users’ data)

7. DATA SECURITY

We apply appropriate technical and organizational measures to safeguard Personal Data against:

• Accidental or unlawful destruction
• Loss, alteration, unauthorized disclosure, or access

Security measures include:

• Data encryption in transit (SSL/TLS)
• Encryption of sensitive data at rest
• Regular monitoring and security testing
• Access restriction on a “need-to-know” basis
• Employee training on data protection

8. ADDITIONAL PROVISIONS

Cookies:

Cookies are files containing a small amount of data that may include an anonymous unique identifier. Cookies are sent to the User’s browser from the Website and stored on the User’s hard drive.

We use cookies to:

• Remember you when logging into the website
• Remember display preferences
• Analyze website traffic (Google Analytics)
• Personalize content and ads

Cookie management: The User may instruct their browser at any time to refuse all cookies or to indicate when a cookie is being sent. However, if the User does not accept cookies, some parts of the Website may not function properly.

Policy regarding minors:

Our Website is strictly limited to Users who are 18 years of age or older. We do not knowingly collect or store Personal Data from users under 18.

If we learn that we have collected personal data relating to minors, we will promptly delete the relevant data and account. If you are a parent or legal guardian and you know that we may have collected and/or processed any data of minors, please contact us immediately.

Changes to the Policy:

We will inform Users of any material changes to this Policy by:

• Publishing an updated version on the website
• Sending a notice to the email address
• Displaying a notice on the website upon the next login

Acknowledgment:

By using our Website and/or Services, the User confirms that they have read and accepted the terms of this Policy. Continued use of Exclusive Dates constitutes consent to the processing of the user’s personal data in accordance with the provisions of this Policy.

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