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App Privacy Policy

OUR PRIVACY POLICY

We will always keep your data safe and secure. This policy explains what information we collect about you and how we use it.

This online dating digital application software (“dating app” hereinafter”) is owned and operated by Cloud9Love Limited (“Cloud9” hereinafter).

This Privacy Policy was posted on the 7th of November 2023. Therefore the policy takes effect for all our Customers and visitors from the 7th of November 2023.

This policy complies with General Data Protection Regulations of the UK and the Data Protection Act 2018 along with Scottish and Irish GDPR Regulations. We therefore ensure that we process your data securely and transparently.

In most cases, Cloud9 is a Data Processor, by acting on the Customer’s instructions in order to be able to use our dating app, website, events and any other connected service that we operate. This mainly includes our Customers creating and using their online profile on our dating app in order to form connections and meet potential dates on a safe digital dating platform.

The Customer generally speaking is identified as the Data Controller for GDPR purposes, who determines the purpose of the data and the means of the same.

Our privacy notice in accordance with GDPR legislation, outlines the type of personal data that we collect and hold about you as a Customer. This includes your full name, email address, location (i.e. town or city), date of birth, contact number, gender and pronouns.

We will never share your full name and date of birth on your profile and other users will simply see your first name, location and age, in this regard. Furthermore, we will never share your email address and contact number on your profile, under any circumstances.

This information is needed for the sole purpose of Customers being able to register a profile, use the dating app and introduce users to one another to build like-minded connections.

Our privacy notice also explains how we use this information, how long the information is kept for and any other relevant information about your data.

Definitions

The following definitions apply to our privacy policy:

“App” means the dating app, our website and connected services. The dating app is a digital software service.

Customer” means the user who has signed up by registering their profile in order to use the dating app.

  1. Data Controller details
  • Cloud9 Love Limit
  • Email address: admin@cloud9love.co.uk
  • Website: cloud9love.co.uk

 

  1. Data protection principles

In relation to personal data, we will:

  • Process it fairly, lawfully and in a clear, transparent way;
  • Collect personal data only for specific and legitimate reasons;
  • Only use it in the way that we have told you about;
  • Ensure it is correct and up to date;
  • Keep your data for only as long as we require it;
  • Process it in a way designed to ensure it will not be lost, destroyed or used for anything that you are not aware of.

3a. Types of data we collect

As you will appreciate in order to develop meaningful connections and rapports, we will be required to collect some personal data so that we can ensure you are matched to like minded users.

The types of data that we collect include:

  • Your name, location, email address, date of birth, phone number, gender and pronoun.

 

We collect personal information from you using any electronic devices (such as mobile phones, tablets and desktops) that you use when you:

  • Use any of our services.
  • Register for a profile.
  • Create and share your profile.
  • Subscribe to a paid membership whether via the dating app, on our website or at one of our events.
  • Engage in communications with other dating app users.
  • Update information for your account profile and/or when you communicate with us including our customer care team.
  • Contacting our customer care team.
  • Participate in customer surveys and market research for Cloud9.
  • We collect this information either because it is necessary so that we can perform our contract of providing our services to you, it is in our legitimate interests to do so and/or to meet our legal obligations.

3b. How we collect your data

We collect data about you only as supplied by you when you sign up to use our dating app, website and other connected services.

This will usually start from your registering and creating your profile on the dating app. Upon signing up, you can then use our services and connect with other users on our platform. We would be required to share the following data directly with other users on your profile, including the following details:

 

  • First Name;
  • Location;
  • Age;
  • Gender;
  • Love Language Test

 

The above will also include sharing a profile photo of yourself on your profile in order to show your true self for safety purposes and other users so that they can see who they are communicating with, connecting to or meeting.

 

IT systems

Personal data is held securely on our digital and/or email IT systems, which are password protected and access to the above information is solely restricted to Cloud9 and will require access to it to undertake our job duties and in order to provide our services.

The digital application services and our website are provided by Zudu.

Marketing correspondence

If you have subscribed to our newsletter via our dating app, website, events or other electronic platforms such as social media, we will send you newsletter updates by email to share any news and information on our services to keep you updated of what we are up to. This is the only time we will send you marketing messages and emails.

You can stop receiving marketing messages/emails from us at any time by emailing us directly at admin@cloud9love.co.uk or by clicking unsubscribe on our mailing platform.

Ways to opt out.

  • By clicking on the ‘unsubscribe’ link in any email.
  • By emailing us to opt out. Simply say opt out in the subject line or the body of an email that you send to us and we will remove your email from our mailing list.

We will never disclose your personal information to third parties for their own marketing purposes unless we are legally obliged to do so.

  1. 4. Why we collect your data
  • To fulfil and deliver our services ensuring we comply with relevant legal obligations to provide our services to you whether on our dating app, website, via events and/or through connected services.
  • To let you know of any special offers/news at the time. This is in our legitimate interests to do so to enhance our services and also to grow our business. We, of course, provide the option of opting out of receiving our marketing and updates communications.
  • To allow you to use our services fully.
  • To prevent and detect fraud against either you or us.
  1. Why we process your data

Cloud9 can process your data only for specific purposes due to GDPR and England and Wales, Scotland, and Ireland data protection laws:

  • So that we can perform a legal contract that we are a party to with you.
  • To ensure we can carry out legally required duties and/or
  • To ensure we can promote the legitimate interests of Cloud9 and Customers, where necessary.

 

All the processing carried out by us falls into one of the permitted reasons. We will need to collect your personal data in order to carry out the contract that we have entered into with you as a Customer for one of our services.

We also process data to ensure we can carry out activities that are in the legitimate interests of Cloud9.

  1. If you do not provide your data to us

Our main reason to process your data is so that we can carry out our contractual duties agreed with you as a Customer using our online services.

If, as a Customer, you do not provide us with the data to be able to carry out our contractual duties, we cannot perform our contractual obligations to provide our services to you.

If you are one of the parties to the said contract, we must process your data to comply with a legal obligation, as the Data Processor.

If you wish to delete your data, this can be done through the app via the left side ellipses > My Profile > right side ellipses > Delete Account.

  1. Sharing your data

Your data will only be shared with our internal colleagues/self-employed contractors or agents who are recruited to provide our services (if any) within Cloud9, in order for them to undertake their duties. We also will not share your data with bodies or third parties outside of the European Economic Area.

Sharing your information

We will never share or sell any of your data/personal information with any third party subject to the below specific exceptions.

Sendgrid https://www.twilio.com/en-us/legal/tos
Heroku https://devcenter.heroku.com/articles/security-privacy-compliance
Cloudinary https://cloudinary.com/privacy
MongoDB https://www.mongodb.com/legal/privacy-policy
Firebase https://firebase.google.com/support/privacy
Google Cloud Console

 

https://cloud.google.com/terms/cloud-privacy-notice

 

Exceptions

We may share your data with the following companies, as an essential part of being able to provide our services to you for these specific purposes only:

  • Payment service providers such as membership payments i.e. card payments for Customers. They only receive the data that they require to provide the relevant processing service and only for that purpose. For example, processing payments itself.
  • Professional service providers, such as our software host/web designer who may help us with our online software and website and/or technical concerns.

We may also be required to share some of your data with others for the below reasons:

  • If we are requested by the police or either a regulatory or government authority investigating illegal activities to provide such information concerning your activities while using our services, we shall be legally obliged to do so.
  1. Protecting your data

We acknowledge our obligation to ensure your data is protected against accidental loss or disclosure, destruction, and abuse. We have implemented safeguarding processes for this.

Cloud9 has taken the following steps to protect personal data of Customers, which it holds or to which it has access:

  1. It may appoint or employ individuals or contractors/agents with specific responsibilities for:
  • Processing and controlling of data.
  • The comprehensive reviewing and auditing of its data protection systems and procedures.
  • Overseeing the effectiveness and integrity of all the data that must be protected.
  1. It provides its employees/contractors/agents (if any) with information and training to make them aware of the importance of protecting personal data, to teach them how to do this, and to understand how to treat information confidentially.

iii. It can account for all personal data it holds, where it comes from, who it is shared with and also who it might be shared with.

  1. It carries out risk assessments to identify any vulnerability in its personal data handling and processing, and to take steps in reducing the risks of mishandling and potential breaches of data security.

The process includes an assessment of the impact of both the use and potential misuse of personal data.

  1. It recognises the importance of seeking individuals’ consent (where appropriate) for obtaining, recording, using, sharing, storing and retaining their personal data, and regularly reviews its procedures for doing so, including the audit trails that are needed and are followed for all consent decisions.

Cloud9 understands that consent given by potential and current Customers must be freely given, specific, informed and unambiguous.

Cloud9 seeks consent on a specific and individual basis on the dating app and our website. Customers have the absolute and unimpeded right to withdraw that consent at any time.

It has the appropriate safeguarding processes for detecting, reporting and investigating suspected or actual personal data breaches, including where these are caused by security breaches. It is aware of its duty to report breaches that cause significant harm to the affected individuals to the Information Commissioner’s Service and to the Customer, and is aware of the possible consequences.

To understand the implications of the transfer of personal data internationally. Where access to your data is required, the following apply:

The principle of legal privilege is always applicable. Therefore, those with access to such data will only have the minimum amount of access to a resource that is required for them to undertake their role.

Access to personal data is protected safely. Passwords that are used must meet the specified complexity requirements and must be kept confidential to the user and not shared with anyone else including our colleagues and contractors/agents (if any).

We regularly monitor our software system for possible vulnerabilities and attacks.

If we do share your data with third parties, we have a written agreement with them to ensure that your data is held securely and in line with GDPR requirements of England and Wales, Scotland and Ireland.

Third parties must implement appropriate technical and organisational measures to ensure the security of your data.

Protecting your information

As you know, the internet is not a 100% secure method for communication and so we are unable to guarantee the absolute security of any information you send to us (or we send to you) via the internet. We are not responsible for any damages which you, or others, may suffer as a result of the loss of confidentiality of such information. We take every reasonable precaution to protect your information. We cannot ensure or warrant the security of any information you transmit to us, and you do so at your own risk. We use our best endeavours to ensure it is secure on our systems, as outlined above.

Payments

We will never store or process your card details/card payment data ourselves; they are processed and may be stored by our third party service providers. We encrypt your payment card details when you submit your card details as a Customer and securely transfer this data to our third party payment provider to process a payment/provide a refund and/or to prevent and detect fraud against either you or us.

The security of our Customers’ financial transactions is extremely important to us and we are committed to protecting you as best as we can.

  1. How long do we keep your data?

Cloud9 keeps your data only for as long as it is necessary for us. You are entitled to exercise your right to erasure of this data by making a request verbally or in writing to us (phone call, post or email) though we recommend a written request to us by email.

Once we no longer need your data, we will take steps to delete it. Cloud9 conducts annual checks of personal data that we hold to ensure everything has been deleted at the end of its retention period.

  1. Automated decision making

No decision will be made about you solely on the basis of automated decision making (where a decision is taken about you using an electronic system without human involvement) which has a significant impact on you.

  1. Your rights in respect of your data

Data protection laws within England and Wales, Scotland and Ireland including GDPR rules provide you with specific rights in relation to the data we hold about you. These rights are set out as follows:

  • The right to be informed. This means that we must tell you how we use your data and this is the purpose of this privacy notice.
  • The right of access. You have the right to access the data that we hold on you. To do so, you should make a subject access request to Matthew Findlay by email at admin@cloud9love.c.uk . This information will be provided free of charge, unless a request is manifestly unfounded or excessive, particularly if it is repetitive. In such circumstances, Cloud9 may charge a reasonable fee to respond or may refuse the request.
  • The right for any inaccuracies to be corrected. If any data that we hold about you is incomplete or inaccurate, you are able to require us to correct it.
  • The right to have information deleted. If you would like us to stop processing your data, you have the right to ask us to securely delete or destroy it from our systems where you believe there is no reason for us to continue processing it.
  • The right to restrict the processing of the data. For example, if you believe the data we hold is incorrect, we will stop processing the data (while still holding it) until we have ensured that the data is correct.
  • The right to data portability. You may transfer the data that we hold on you for your own purposes.
  • The right to object to the inclusion of any information. You have the right to object to the way we use your data where we are using it for our legitimate interests.
  • The right to regulate any automated decision-making and profiling of personal data. You have a right not to be subject to automated decision making in a way that adversely affects your legal rights. Where you have provided consent to our use of your data, you also have the unrestricted right to withdraw that consent at any time.

Withdrawing your consent means that we will stop processing the data that you had previously given us consent to use. There will be no consequences for withdrawing your consent. However, in some cases, we may continue to use the data where so permitted by having a legitimate reason for doing so such as our legal obligations for providing our services.

If you wish to exercise any of the rights explained above, please contact us as soon as possible, via email at admin@cloud9love.co.uk.

  1. Amendments to our privacy policy

We reserve the right to amend our privacy policy, while of course ensuring it complies with relevant GDPR legislation and the laws of England and Wales, Scotland and Northern Ireland . We will ensure that our policy shows the most up to date information and may notify you of such changes by including the revised privacy policy on our dating app and our website or announcing the same for marketing purposes such as via social media platforms.

  1. If you wish to make a complaint

We hope that you will be happy with our services and using Cloud9. In the event you are unhappy with your information and access rights or wish to make a complaint to Cloud9, please contact us by email on admin@cloud9love.co.uk so that we can investigate your complaint as soon as possible. We will try our best to provide you with an amicable resolution, where possible within 7 days.

  1. Data Protection Officer

Our Data Protection Officer is Matthew Findlay who can be contacted at admin@cloud9love.co.uk.