FindingYou S.à r.l. (“FindingYou”, “we”, “our”, or “us”), values the privacy of all of its Users (“you” or “your”) and the User privacy lies in the core design of how we provide our services. We strive to create FindingYou, a safe and regulated environment everyday so you can fully trust us and user our services to build meaningful connections. For the very same reason, we have incorporated this Privacy Policy to show commitment to these rights and to safeguard your privacy. Any terms used in this Privacy Policy shall derived their meaning and reference from the Terms of Use, unless specified otherwise.

We appreciate you trusting us and using our website and application (collectively, the “Platform”). However, as you do so we strongly urge you to read this Privacy Policy and become fully informed about how we collect Personal Information about you and how this collection affects your personal privacy. This will further strengthen your trust in us, our Platform and our Services.

Please refer to this Privacy Policy to find out how to contact us if you have any questions about the contents herein. By using our services you consent to the contents of this Privacy Policy.

Welcome to FindingYou’s Privacy Policy. Thank you for taking the time to read it.

We want to start 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 to the date of initial launch of app (version 1.0.0), on 14th June 2024

  1. Who We Are
  2. Where This Privacy Policy Applies
  3. Information We Collect
  4. Information we receive from Third-Parties
  5. How We Use Information
  6. How We Share Information
  7. Cross Border Data Transfers
  8. Your Rights
  9. Rights of EU users
  10. How We Protect Your Information
  11. How Long We Retain Your Information
  12. Children’s Privacy
  13. Use of Data for Third-Party Sign-In
  14. Data Deletion and Account Management
  15. Privacy Policy Changes
  16. Acceptance of this Privacy Policy
  17. How To Contact Us

1. Who We Are

The company that is responsible for your information under this Privacy Policy (the “data controller”) is:

FindingYou S.à r.l.,
36 Op Der heed,
Cents, L-1747,
Luxembourg

FindingYou S.à r.l. is the owner and proprietor of the Platform and collectively the services that we offer. We act as the data controller of Personal Information collected through the FindingYou Platform.

Our Data Processing Offer can be reached via email at contact_us@FindingYou.me

2. Where This Privacy Policy Applies

This Privacy Policy applies to the Platform which is operated by FindingYou.

3. Information We Collect

When you use or register on the Platform we only collect Personal Information that you provide of your own accord and consent. In order to use the services we offer you will need to register with us. By registering you will provide and share your Personal Information such as your basic profile details, your preferences in the types of people that you would like to meet, among others.

This information is required by us to set up your FindingYou account which is integral for you to access the Platform. Please note that your FindingYou profile will be visible to other members also. This part of your Personal Information is made available to the public to help connect you with other users of the Platform.

Please be advised that public Personal Information can show up when someone does a search on you or on another search engine. In some cases, people you share and communicate with may download or copy the content you provided to them or make it public. Use caution about the personal data you share with others.

Personal Information you provide us when you use our services or register for an account with us:

  • To create a FindingYou account, you provide us with your phone number, email and billing address, as well as some basic details necessary for the service to work, such as your gender, date of birth, and your preference limited to gender, age, location, and sexual orientation of our Users (pursuant to their consent granted to us) who you would like to match with using the Platform.
  • Other identifying personal data such as your gender, date/time/place of birth, and current location, when you register for an account with us. It is your voluntary decision whether to provide us with any such personal information, but if you refuse to provide such information we may not be able to register you to receive our services or the Platform;
  • Other content that you generate or that is connected to your account (Username, User ID, Profile Picture, photos and videos, interests, favorites);
  • When you complete your profile, you have the option to share your sexual orientation with us. Where you provide such elements to us, you consent to us using them for the purposes identified and as laid out in this Privacy Policy. You can also share additional information with us, such as details on your bio and your interests, as well as content such as photos and videos. To add certain content i.e. pictures or videos, you may allow us to access your camera or photo album.
  • Phone number and financial personal data (such as credit card number) if you use the relevant services such as a paid service that needs to be subscribed.
  • You may also provide us with other personal data through your participation in surveys, focus groups or market studies, user-to-user communications, chats, or when you otherwise communicate with us regarding our services or generally to share feedback and testimonials;
  • When you participate in our promotions, events or contests, we collect the information you used to register or enter such promotions, events or contests.
  • When you interact with our Customer Support we collect the information you provide us during the interaction. Please note that all our Customer Support calls are recorded for training and quality purposes.
  • We also process your conversations with other members as well as Your Content that you publish to operate and secure the services and make FindingYou the safe space that its community deserves.
  • Additional personal data we are required or authorized by applicable laws to collect and process in order to authenticate or identify you or to verify the personal data we have collected.

Personal Information we collect automatically when you use our Platform or register for a FindingYou Account with us:

When you use the Platform, 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.

  • Device Information: We collect data about your interaction with our Platform, services and your communications with us. We receive this Personal Information from devices (including mobile devices) you use when you access our services. This Personal Information could include the following: device number, device ID or unique identifier, device type, and unique device token, operating system and applications used, application crash data, IP address, User agent, platform, Software Development Kit version, anonymous User ID, time stamp Developer Key, application version, device identifiers such as: IDFA (Identifier For Advertisers), Android ID (Android device), referrer URL (Play Store), Google Advertiser ID, device model, manufacture, OS version, in-app events, and network status (WiFi/3G).
  • Login Information: Login source, application use, age, and gender. If your profile is linked to Facebook/Google when we shall gain access to the number of photos in your profile, interests, notification status, registration date, credits bought, date of last payment and use of services. You control the personal data you share with us through the respective social media you used for registering a FindingYou account through the privacy settings on the applicable social media site and the permissions you give us when you grant us access to the personal data retained by the respective social media site about you;
  • Usage Information: Using the Platform generates data about your activity on our Platform, for instance how you use them (e.g., 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 members (e.g., members you connect and interact with, and when you matched and exchanged messages with them).
  • Location Personal Data: including location personal data from your mobile device including specific geographic locations through IP, GPS, Bluetooth, or WIFI signals. 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, and our services that rely on precise geolocation may not be available to you;
  • Computer and Connection personal data: such as statistics on your page views, traffic to and from the websites, referral URL, ad data, IP address, browsing history, and your web log personal data;
  • ID + Photo Verification Data: If you choose to participate in our combined ID + Photo Verification feature, we collect your face geometry data, which may be considered biometric data in some jurisdictions, as well as a copy of your ID, to verify that you’re the real you.
  • Other information: We may collect other information with your permission, such as photos and videos (for instance, if you want to publish a photo or video). All this information shall only be connected pursuant to your consent only.
  • Information collected by cookies and similar technologies: We do not use any cookies on the Platform as of today.

4. Information we receive from Third-Parties

In addition to the automatically collected information and the information that you provide us directly, we receive information about you from others including:

  • Members: Members 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 obtain information about you from our partners when our ads are displayed on their services, and they may share details about the performance of these campaigns with us. Additionally, where permitted by law, we may receive information from third parties about individuals suspected or convicted of misconduct as part of our efforts to maintain the safety and security of our members.
  • We also collect information about your use of our services such as access logs, as well as information from third parties, like when you access our services through your social media account or when you upload information from your social media account to complete your profile.

5. How We Use Information

The main reason we use your information is to deliver and improve our services and to enable your access to the Platform. Additionally, we use your info 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 we use your information, together with practical examples.

To administer your account and provide our services/enable access to the Platform to you

  • Create and manage your account
  • Provide you with customer support and respond to your requests
  • Complete your transactions
  • Communicate with you about our services, including order management and billing

To help you connect with other Users

  • Analyze your profile, activity on the service, and preferences to recommend meaningful connections to you and recommend you to others;
  • Show users’ profiles to one another
  • Enable Users to search for and connect with other Users.

To ensure a consistent experience across your devices

  • Link the various devices you use so that you can enjoy a consistent experience of our services on all of them. We do this by linking devices and browser data, such as when you log into your account on different devices or by using partial or full IP addresses, browser versions and similar data about your devices to help identify and link them.

To provide new FindingYou services to you

  • Complete registration and display your profile on new FindingYou features and apps
  • Administer your account on these new features and apps

To serve you with relevant offers, and operate advertising and marketing campaigns

  • Administer sweepstakes, contests, discounts or other offers
  • Develop, display and track content and advertising tailored to your interests on our services and other sites
  • Communicate with you by email, phone, social media or mobile device about products or services that we think may interest you

To improve our services and develop new ones

  • Administer focus groups and surveys
  • Conduct research and analysis of users’ behavior to improve our services and content (for instance, we may decide to change the look and feel or even substantially modify a given feature based on users’ behavior)
  • Develop new features and services (for example, we may decide to build a new interests-based feature further to requests received from users).

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

  • Address ongoing or alleged misbehavior on and off-platform
  • Perform data analysis to better understand and design countermeasures against these activities
  • Retain data related to fraudulent activities to prevent against recurrences

To ensure legal compliance

  • Comply with legal requirements
  • Assist law enforcement
  • Enforce or exercise our rights, for example, our Terms

To comply with our Terms of Service and prevent, detect, and fight fraud and other illegal/unauthorized/unsolicited activities

  • Find and address ongoing, suspected, or alleged violations of our Terms of Service, particularly through the examination of member reports and interactions
  • To ensure that FindingYou remains a safe space for its community of Users
  • Better understand and develop counter-measures against the violations of our Terms of Service;
  • Retain data related to User reports and violations of the Terms of Service;
  • Enforce or exercise our rights, for example, such rights those are set in the Terms of Service; and
  • Verify and authenticate any complaints addressed by other Users or violations and generally follow up on them with a motive to resolve them.

To process your information as described above, we rely on the following legal bases

Provide our service to you: Most of the time, the reason we process your information 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, to make it viewable to other users and to recommend other users to you.

Legitimate interests: We may use your information where we have legitimate interests to do so. For instance, we analyze users’ behavior on our services to continuously improve our offerings, we suggest offers we think might interest you, and we process information for administrative, fraud detection and other legal purposes.

Consent: From time to time, we may ask for your consent to use your information for certain specific reasons. You may withdraw your consent at any time by contacting us at the address provided at the end of this Privacy Policy. 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.

Comply with applicable laws and regulations: We process your information 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 consent members give us and decisions they may have taken to opt out of a given feature or processing.

6. 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 registered on the Platform. Among others, we also share your Personal Information with third parties who help us to operate. Please note that all these third parties are bound by strict clauses of confidentiality and all Personal Information is shared with them on a “need to know” basis. Please review the details below;

With other members. 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 publicly viewable since neither you nor we can control what others do with your information once you share it. 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 you violated our Terms of Use), we may communicate to the reporter actions, if any, we took as a result of their report.

With our service providers and partners. We use third parties and vendors to help us operate and improve our services. These third parties assist us with various tasks, including data hosting and maintenance, analytics, customer care, marketing, advertising, payment processing and security operations.

We may also share information with partners who distribute and assist us in advertising our services. For instance, we may share limited information on you in hashed, non-human readable form to advertising partners.

We follow a strict vetting process prior to engaging any service provider or working with any partner. All of our service providers and partner vendors must agree to strict confidentiality obligations.

For corporate transactions. 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.

Sharing functionality. All members may share each other’s profiles in FindingYou with people outside of the Platform who are not registered users, using the sharing feature of the Platform.

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. We will share only the essential portion of your Personal Information required for investigation purposes and will keep the rest confidential.

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; and (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 Personal 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, geo-location in de-identified form), as well as personal information in hashed, non-human readable form, under any of the above circumstances. We may combine this information with additional non-personal information or personal information in hashed, non-human readable form collected from other sources. More information on our use of cookies and similar technologies can be found in our Cookie Policy.

7. Cross-Border Data Transfers

Sharing of information laid out in the above section sometimes involves cross-border data transfers to multiple jurisdictions both in and out of the European Economic Area (EEA). As an example, where the service allows for users to be located in the European Economic Area (“EEA”), their personal information is transferred to countries outside of the EEA. When we transfer personal information outside of the EEA, the United Kingdom, Switzerland or other countries which data protection laws have been deemed adequate by the European Commission or other competent governmental body, we use standard contract clauses (standard contractual clauses are commitments between companies transferring personal data, binding them to protect the privacy and security of your data) or other appropriate transfer mechanism.

8. Your Rights

We want you to be in control of your information, so we have provided you with the following tools that you can use:

Access / Update tools in the service. Tools and account settings can help you to access, rectify or delete 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. Our customer care can be reached via email listed in the “Contact Us” section of this Privacy Policy.

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

Deletion. You can delete your account by using the corresponding functionality directly on the service.

Uninstall. You can uninstall the app which will prevent any further information collection by the app using the standard uninstall process on your device. Remember that uninstalling an app does NOT close your account. To close your account, please use the corresponding functionality on the service.

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

Reviewing or Accessing 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 or variations of those terms). You can request a copy of your personal information by putting in such a request to us via our email listed in the “Contact Us” section of this Privacy Policy.

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 or object to its processing, please contact us via our email listed in the “Contact Us” section of this Privacy Policy.

Delete/Erase. You may request that we delete the personal information we keep about you. You can exercise your right to delete by sending us an email listed in the “Contact Us” section of this Privacy Policy.

Object/restrict. You may also have the right to object to or request that we restrict certain processing. To do so, please contact us via email listed in the “Contact Us” section of this Privacy Policy.

Accountability. In certain countries, including the European Union, you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how we process your personal information. The data protection authority you can lodge a complaint with notably may be that of your habitual residence, where you work or where we are established.

For your protection and the protection of all of our members, we may ask you to provide proof of identity before we can answer the above requests. Keep in mind, we may reject requests for certain reasons, including if the request is unlawful or if it may infringe on trade secrets or intellectual property or the privacy of another user or if we are unable to authenticate you. If you wish to receive information relating to another member, such as a copy of any messages you received from them through our service, the other member will have to contact us to provide their written consent before the information is released. We may also ask them to provide proof of identity before we can answer the request.

Additionally, we may not be able to fulfill certain requests to object to or limit the processing of personal information, especially if such requests would prevent us from delivering our service to you. For example, we cannot offer our service without your date of birth, as this information is necessary to verify that you are 18 years of age or older.

9. Rights of EU users

In addition to rights set out in the section V of this Privacy Policy, if you are located in the European Union, as a data subject (a person whose personal information is collected, stored and processed) you have several rights under GDPR. Chapter 3- Rights of the Data Subject shall govern Users’ rights under this Policy.

Right to know. You have the right to obtain confirmation if your personal information is being processed by us. If that is the case, you can access your personal information and the following information: (a) the purposes of the processing; (b) the categories of personal information; (c) to whom the personal information have been or will be disclosed; (d) the envisaged period for which the personal information will be stored, or the criteria used to determine that period. You can also request from us a copy of your Personal Information by sending us an email listed in the “Contact Us” section of this Privacy Policy.

If you would like to have a copy of your personal information from us, we will provide it based on (1) you will prove your identity, (2) it will not adversely affect the rights and freedoms of others.

Right to erasure and stop processing. You have the right to demand that we erase your personal information, and we shall erase it without undue delay where one of the following grounds applies: (a) this personal information is no longer necessary in relation to the purposes for which they were processed; (b) you withdraw consent if the processing was based on your consent, and where there is no other legal ground for the processing; (c) you object to the processing and there are no overriding legitimate grounds; (d) your personal information have been unlawfully processed; (e) your personal information have to be erased for compliance with a legal obligation.

Right to request portability. You have the right to receive your personal information which you provided us 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.

Right to object and withdraw consent. You have the right to withdraw your consent for processing of your personal information at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

Right to complaint. 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 information infringes GDPR.

10. How We Protect Your Information

Currently, FindingYou operates in Luxembourg and all the Personal Information is stored in secure servers. As we expand globally, we reserve our right to store User data in servers across different locations. Accordingly, we will update this Privacy Policy to reflect the new changes.

We work hard to protect you from unauthorized access to or alteration, disclosure or destruction of your personal information. We also ensure that the Personal Information is adequately protected by implementing valid legal mechanisms, such as EU-approved model clauses and stringent contractual requirements. As with all technology companies, although we take steps to secure your Personal Information, we do not promise, and you should not expect, that your Personal Information will always remain secure. Data transmission over the internet is not entirely safe and may remain subject to breaches, despite our best efforts. In any case of data breach or server hack we will notify our Users immediately and in no more than 24 hours and will report to appropriate regulatory agencies for further action.

We regularly monitor our systems for possible vulnerabilities and attacks and regularly review our information collection, storage and processing practices to update our physical, technical and organizational security measures.

We may suspend your use of all or part of the services without notice if we suspect or detect any breach of security. If you believe that your account or information is no longer secure, please notify us immediately via email at contact_us@FindingYou.me.

11. How Long We Retain Your Information

We keep your personal information only as long as we need it for legitimate business purposes and as permitted by applicable law. To protect the safety and security of our users on and off our services, we implement a safety retention window of three months following account deletion. During this period, account information will be retained although the account will of course not be visible on the services anymore.

In practice, we delete or anonymize your information upon deletion of your account (following the safety retention window) or after two years of continuous inactivity, unless:

  • we must keep it to comply with applicable law (for instance, some “traffic data” is kept for one year to comply with statutory data retention obligations);
  • we must keep it to evidence of our compliance with applicable law (for instance, records of consents to our Terms, Privacy Policy and other similar consents are kept for five years);
  • there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or
  • the information must be kept for our legitimate business interests, such as fraud prevention and enhancing users’ safety and security. For example, information may need to be kept to prevent a user who was banned for unsafe behavior or security incidents from opening a new account.

Keep in mind that even though our systems are designed to carry out data deletion processes according to the above guidelines, we cannot promise that all data will be deleted within a specific time frame due to technical constraints.

12. Children’s Privacy

Our services are restricted to users who are 18 years of age or older. We do not permit users under the age of 18 on the Platform and we do not knowingly collect personal information from anyone under the age of 18. If you suspect that a user is under the age of 18, please report them to us via email at contact_us@FindingYou.me.

13. Use of Data for Third-Party Sign-In

Use of Personal Information for Account Creation and Login
When you choose to sign up or log in to our system using third-party authentication services like Google, Facebook, or Apple, we request access to certain basic personal information to facilitate the account creation or login process. Specifically:

  1. Email Address:We collect your email address from the chosen service to:
  2. Create your account within our system.
  3. Identify you uniquely in our system.
  4. Facilitate communication related to your account, such as password recovery, account notifications, or service-related updates.
  5. Why Email is Necessary:An email address is a required identifier for creating and managing accounts securely. It enables us to provide a personalized and seamless experience, as well as ensure account integrity and access.
  6. Third-Party Data Handling:
  7. Google: When you use Google sign-in, we request access to your Google email.
  8. Facebook: If you sign in using Facebook, we request access to your primary email address.
  9. Apple: When using “Sign in with Apple,” you may choose to share your actual email or a relay email address provided by Apple.
  10. Data Security and Privacy:
  11. The email address collected is used strictly for the purposes outlined above.
  12. We do not share your email address with unauthorized third parties or use it for marketing purposes without your explicit consent.

By signing in through Google, Facebook, or Apple, you acknowledge and agree to our collection and use of your email address in accordance with this privacy policy.

14. Data Deletion & Account Management

We respect your right to control your personal data. If you no longer wish to use our services and want to delete your app data, we provide a simple and secure way to do so through your account.

  • How to Delete Your Data: navigate to the Account Settings  section in our website, and select the Delete My Account option and login. This process will permanently remove all associated data from our systems, as required by applicable data protection laws.
  • What Happens When You Delete Your Data:
  • All your personal data, including your email and account details, will be permanently deleted from our systems.

15. Privacy Policy Changes

Because we’re always looking for new and innovative ways to help you build meaningful connections, 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. Last Updated date will also remain available for Users’ reference on the top left corner of this Privacy Policy.

16. Acceptance of this Privacy Policy

Our services and your use of it, including any issue concerning privacy, is subject to this Privacy Policy and the related Terms & Conditions. When you use our services, you accept the conditions set out in this Privacy Policy and the related Terms of Use Agreement. You signify and guarantee that you will never generate any databases, websites, software, legal entities and services that compete with FindingYou. Such behaviour will be fully investigated, and necessary legal action will be carried out, including, without limitation, civil, criminal, and injunctive redress.

The acceptance of this Privacy Policy and applicable Terms of Use Agreement are considered as a pre-condition for the use of our Services.

17. How to Contact Us

If you have questions about this Privacy Policy, here’s how you can reach us:

By post:

FindingYou S.à r.l.,
36 Op Der Heed,
Cents, L-1747,
Luxembourg

By email: contact_us@FindingYou.me