(b) Contact
Our contact details (including privacy issues) are:
Email: team@cupidmedia.com
Post: CupidMedia.com, PO Box 795, Southport BC, QLD 4215, Australia
Privacy Issue: team@cupidmedia.com
If you are based in the European Union or the United Kingdom, SOL Networks Limited has been appointed as Cupid Media’s EEA representative for data protection matters. In addition to contacting us using our above contact information, SOL Networks Limited can be contacted in regard to matters related to the processing of your personal data at the following address:
Name: SOL Networks Limited
Address: 71 Tower Road, SLM 1609, Sliema, Malta
Privacy Issue: team@cupidmedia.com
2. Grounds for Collection
This Privacy Statement sets out our policies relating to the collection and use of your Personal Data while you use the Website. Words that are capitalized, such as “Personal Data” and “Special Category Personal Data”, are defined in clause 9 of this policy.
Where collect your Personal Data, we will do so on the following basis:
(a) Legitimate Business Purposes
Where we are not collecting and using your Personal Data for the purposes of entering into a contract with you, or to deliver to you our services, we may still collect and use your Personal Data where we consider:
(i) you will not be detrimentally impacted by our collection and use;
(ii) such collection and use is in accordance with what you would reasonably expect in the context of our use of your Personal Data; and
(iii) it is necessary to fulfill our legitimate interests.
This may include, for example, use of your Personal Data to improve our Website or the range of services that we offer to you.
(b) Legal compliance
There are certain situations in which we may be required to process your Personal Data in order to comply with the law, for example if we are subject to an order of the Court or a regulatory authority requiring such processing.
(c) Your consent
By accessing and using the Website you are consenting to the collection and use of your Personal Data in accordance with the terms of this Privacy Statement.
3. Anonymity
Due to the nature of the services provided by the Company it is impractical for us to deal with you without knowing your full name. When you register for our services you are required to identify yourself and use truthful and accurate information.
4. Collection of data
(a) All users
Whenever you (including non-member users) visit our Website, our servers automatically record information for statistical purposes about your usage of the Website such as:
(i) the type of browser used;
(ii) the referring URL;
(iii) the IP address;
(iv) the number and type of pages viewed;
(v) the date and time of visits; and
(vi) the exit URL.
This information we collect about you is not Personal Data and, in any event, remains anonymous. We do not link the anonymous information to any other Personal Data unless you have either registered as a member or logged on as a member at the time of use. Accordingly, if you have not identified yourself on the Website, we will not link a record of your usage of our Website to you personally.
(b) Cookies and other tracking technologies
To improve your experience on our Website, we may use cookies and other tracking technologies, such as pixel tags, web beacons, device IDs, or advertising IDs.
You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this, you may not be able to use the full functionality of our Website.
Our Website uses Google Analytics, a service which transmits website traffic data to Google servers in the United States. Google Analytics does not identify individual users or associate your IP address with any other data held by Google. We use reports provided by Google Analytics to help us understand website traffic and web page usage.
You can customize or opt out of Google Analytics for Display Advertising using the Ads Settings for your Google account.
Our Website uses cookies and other tracking technologies to support Google Analytics for:
(i) Google Marketing Platform integrations;
(ii) Demographic and Interest Reporting;
(iii) Display Advertising including Remarketing and Google Display Network Impression Reporting to advertise our services online;
(iv) optimizing and personalizing ad services based on your past visits to our Website; and
(v) reporting the use of ad services and interactions with ad impressions and how they are related to visits to our site.
Cookies and other tracking technologies may also be used to support analytics by other third parties.
(c) Third party interactions
We may allow third parties, including authorized service providers, advertising companies, data management platforms, and ad networks to serve advertisements on our Websites. We may also share your profile data with affiliated companied of Cupid Media for analytical purposes and optimisation of ad campaigns.
These companies may use tracking technologies (such as cookies, pixel tags, web beacons, device IDs, or advertising IDs) to collect information about users who view or interact with their advertisements. Any information that these third parties collect via cookies is completely anonymous and is non-identifiable. Examples of such third parties include: 360, Adobe, Akamai, Appnexus, Baidu, Bing, Cake, Chargeback.com, Criteo, Dating Group, Ecom Services, Facebook, Firebase, Google Ads, Google Ads Manager, Google Analytics, HotJar, Index Exchange, Naver, Olark, Oracle, Publift, Pubmatic, Pusher, RayGun, Rubicon Project, SDL, Sentient, Taboola, TikTok, Twitter, Urban Airship, Visa Inc. Yahoo, Yandex, Zero Bounce.
You may refuse the use of third party data collection by selecting the appropriate settings on your browser or by switching off your profile.
There are also a number of places on our Website where you may access third party websites that do not operate under this Privacy Statement and that we do not control. Such third party websites may collect your Personal Data. We recommend that you consult the privacy policy of all third party websites that you visit.
(e) Social media
The Company interfaces with social media sites such as Facebook, Twitter, YouTube, Instagram, Pinterest, Weibo, Tiktok and others. If you choose to “like” or “share” information from our Website through these services, you should review the privacy policy of the relevant service. If you are a member of a social media site, the interfaces may allow the social media site to connect your visits to this Website with other Personal Data.
5. Purposes of collecting, holding, using and disclosing Personal Data
(a) Collect from you only
Where it is reasonable or practical to do so we will only collect Personal Data about you from you directly.
(b) Purposes of collecting Personal Data
We will only collect Personal Data that is reasonably necessary for:
(i) our internal research and statistical purposes (including market segmentation and customer value analysis);
(ii) enabling us to forward to you other information or material which we believe may be of interest to you;
(iii) any other purpose specified in our Website Terms of Use available on our Website
We do not sell Personal Data to any third parties or provide Personal Data to third parties for any business purpose (unless specifically referred to in this Privacy Statement).
(c) Holding of Personal Data
We will use best practice processes and take all reasonable steps to protect Personal Data that we hold from:
(i) misuse, interference, and loss; and
(ii) unauthorized access, modification, or disclosure.
In the unlikely event that there is a serious data breach that is likely to result in a risk to your rights and freedoms, we will without undue delay notify the appropriate supervisory authority in your jurisdiction. Where there is a high risk that a serious data breach will impact upon your rights and freedoms, we will also notify you of that breach.
(d) Unsolicited information
If we collect Personal Data which we have not sought or requested about you, and if we determine we are legally permitted to collect that information, we will deal with that information in accordance with the terms of this Privacy Statement. In all other circumstances, we will destroy or de-identify the relevant Personal Data as soon as practicable, where it is lawful and reasonable to do so.
(e) Communication
We reserve the right to send electronic mail to you regarding recommended profile matches, notification alerts of activity such as interest alerts or message alerts, promotions or offers, changes or additions to our services, or any products and services of our affiliated businesses.
If you are a member of our Website you may manage your email preferences by using the settings on the “Notifications” page to customize what type of email communications you wish to receive.
6. Destruction of Personal Data
We will keep your Personal Data only for as long as we need it for legitimate business purposes and as required by applicable law. We will take reasonable steps to erase any Personal Data that we hold about you, where:
(i) we no longer need the Personal Data for the purposes for which it was collected and we are not otherwise entitled to retain such data; and
(ii) we are not required or obligated by law, regulation or court order to retain the information.
If certain information has been provided to third parties in accordance with this Privacy Statement, retention of that information will be subject to the policies of the relevant third party.
7. Your legal rights depending on the applicable jurisdiction:
(a) Rights of EU Users
If you are located in the European Union, as data subject (a person whose Personal Data is collected, stored and processed) you have several rights under General Data Protection Regulation (“GDPR”):
- You have the right to obtain confirmation if your Personal Data is being processed by us. If that is the case, you can access your Personal Data and the following information:
- the purposes of the processing;
- the categories of Personal Data;
- to whom the Personal Data have been or will be disclosed;
- the envisaged period for which the Personal Data will be stored, or the criteria used to determine that period.
If you would like to have a copy of your Personal Data from us, we will provide it only in case: (1) you will prove your identity, (2) it will not adversely affect the rights and freedoms of others.
- You have the right to demand that we erase your Personal Data, and we shall erase it without undue delay where one of the following grounds applies:
- this Personal Data is no longer necessary in relation to the purposes for which they were processed;
- you withdraw consent if the processing was based on your consent, and where there is no other legal ground for the processing;
- you object to the processing and there are no overriding legitimate grounds;
- your Personal Data has been unlawfully processed;
- your Personal Data has to be erased for compliance with a legal obligation.
- You have the right to receive your Personal Data which you provided us with in a structured, commonly used and machine-readable format and have the right to transmit those data to another company, where: (a) the processing is based on your consent or on a contract; and (b) the processing is carried out by automated means.
- You have the right to withdraw your consent for processing of your Personal Data at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
- You have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of your Personal Data infringes GDPR.
You can exercise the above rights by contacting us using the contact information contained in clause 1.1(b) of this Privacy Statement.
(a) Rights of Users from certain US States
If you are located in: California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah or Virginia, the local Data Privacy Acts give you the right to exercise the following rights:
- Right to know and access. You may submit a verifiable request for information regarding the:
- categories of Personal Data we collect, use or share;
- purposes for which categories of Personal Data are collected or used by us;
- categories of sources from which we collect Personal Data; and
- specific pieces of Personal Data we have collected about you.
- Right to correct. You may submit a verifiable request to rectify inaccuracies in your Personal Data, taking into account the nature of the Personal Data and the purposes of the processing of your Personal Data;
- Right to delete. You may submit a verifiable request to close your account and we will delete Personal Data about you that we have collected.
- Right to prohibit sale of your Personal Data. Please note that we do not sell your Personal Data.
- Right to object profiling and targeted advertising. You may submit a verifiable request to be opted-out from each of the above actions. Please note that these measures may negatively affect your customer experience with our Website and third party services.
In order to verify your identity when you make a request, you will be required to log in to your password-protected account or respond to an email verification request.
You can exercise the above rights by contacting us using the contact information contained in clause 1.1(b) of this Privacy Statement.
Please note that the Privacy Acts vary from state to state. If you are based in the US, please consult your local certified legal advisor for more detailed regulation.
8. Complaints
(a) Making a complaint
If you believe that we have used or disclosed your Personal Data in a manner which is contrary to this Privacy Statement or that otherwise breaches an applicable law, then you should email us at team@cupidmedia.com.
If you are based in the European Union and have a complaint or enquiry regarding your Personal Data, you may also contact our European representative using the contact information contained in clause 1(b) of this Privacy Statement.
You also have the right to lodge a complaint with the relevant supervisory authority in your jurisdiction. If you are unsure who your relevant supervisory authority may be, please contact us so that we may provide you with assistance.
(b) Our response
Within 30 days of receipt of your complaint we will notify you in writing as to what action we propose to take in relation to your complaint and will provide you with details of what further action you can take if you are not satisfied with our response.
9. Definitions
“Company” means Cupid Media Pty Ltd (ACN 104 844 564), a company registered in New South Wales, Australia, and shall also include any related body corporate or associate (as those terms are defined in the Corporations Act 2001 (Cth)) of Cupid Media Pty Ltd;
“Dating Group” means SOL Holdings Limited (No. HE342740, Cyprus) and any of its affiliated or related entities that it controls and which provide dating services to customers.
“General Data Protection Regulation” and “GDPR” mean Regulation (EU) 2016/679 of The European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC.
“International Organization” means an organization and its subordinate bodies governed by public international law, or any other body which is set up by, or on the basis of, an agreement between two or more countries.
“Personal Data” means any information relating to an identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person and includes Special Category Personal Data.
“Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
“Special Category Personal Data” means personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, your criminal record, genetic and biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning your sex life or sexual orientation.
“Related Website” means any other website owned, operated or controlled by Cupid Media Pty Ltd ACN 104 844 564 or a member of Dating Group.