Collection of information
Personal Information Collection
When you register for an Account or subscribe to any of our services we may collect a variety of information about you that, alone or in combination with other information, which may be used to identify you as an individual (“personal information”). The type of personal information we collect and process depends on how and why you interact with us.

Information collected and not limited to includes as follows:

• Your name;

• Gender;

• Date of birth;

• Ethnicity;

• Education;

• Height;

• Occupation;

• Contact information including email address and contact number;

• Location;

Once you register, you will be able to review and change this information at any time just by logging in to Affinité (other than your location (which, if you have given Affinité access to your location in your device settings, is automatically updated based on the location of your device). It is your responsibility to ensure that your account details are kept up to date. If your phone number changes, please ensure that you update this in your account.

The information we collect helps to enhance the App and verify our Users (robots are not welcome!). Registration Information such as your sexual preference, name and username may be visible to other Users who view your profile page.

Meanwhile, by providing us with your information, and photos, you agree that we may make them available to third-party or other users of our Services if considered appropriate as described in this Privacy Policy.

We use information that we collect from you or that you provided to us, including any personal information, to:

• Provide and develop our Services;

• Apply in and enhance our matching algorithm; 

• Establish and manage User Account, such as your “My Affinité Profile ”;

• Display the public fields of your profile to other users for matching purposes, including but not limited to users name, demographics, photos, and other profile content (e.g., compatibility profile);

• Provide customer support, troubleshoot issues, and respond to requests, questions, and comments;

• Process payment and transactions;

• Communicate with you about our Services, including order confirmation, subscription renewal processing, enquiry support, chats notification, new matches notification and service updates;

• Communicate with you regarding promotions, including but not limited to new product offerings, special discounts, event notifications, and special third-party offers;

• Conduct market and consumer research and trend analyses;

• Prevent, detect, identify, investigate, and respond to potential or actual claims, liabilities, prohibited behaviour, and criminal activity;

• Comply with and enforce legal requirements, agreements, and policies, and/or any Court orders; and

• For any other purpose incidental to and/or appropriate for the operation of our Services.

In addition to the uses outlined above, by accessing or using our services, you agree to allow us to anonymously use the information from you and your experiences to continue our research into relationship satisfaction and/or our business developments. The research, conducted by psychologists, data scientists and/or other appropriate professionals may be published in commercial commentary, media or otherwise. However, all of your responses will be kept anonymous, and no identifiable personal information will be disclosed.

Profile Information
All of our members are encouraged to think carefully before disclosing any personal information. We do not recommend putting in your profile email addresses, URLs, instant messaging, phone numbers, full names or addresses, credit card numbers, national identity numbers, driver’s license numbers, or any other sensitive information that could be misused and abused. When you post information about yourself or use the messaging function to communicate with other Users, the amount of personal information you share is at your own risk. Please see Section 4 below for more information on who can access what you post on Affinité . 

Personal Information
We will automatically collect personal information given to us by you when you decide to download and use our services. When you access or use our Services, we automatically collect information about how you access and use our Services. The information we collect includes but is not limited to your IP address, browser type, Internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and the number of clicks. If you use a mobile device to access or download any of our Services, we may also gather device information (such as your mobile device ID , model , and manufacturer ), operating system, and version information. While this information taken together could be considered personal information, we do not rely on this information to personally identify you. This information is aggregated for our business purposes, such as, without limitation, data analysis, service administration, and customer experience enhancement. We collect information from users so we can tailor their experience, show them content that they might be interested in, and/or display content in accordance with their preferences. We collect information to understand how users interact with our Services. We will retain the information and use it in accordance with the terms of this privacy statement.

Profile Verification Information &Moderation Practices
For safety and security and to ensure you have the best possible user experience, we require Users to verify their accounts by asking you carry out photo verification during the process of creating an Account. We want to make sure you are not a robot! And we also want to avoid Affinité fake accounts being created which can be used for malicious activities and cybercrime – Affinité network is a strictly verified members club and we don't want some people to spoil things for everyone. This verification is required by us for the prevention of fraud and we will scan each photo that you submit for verification. Once you had verified your photo the blue ‘verified’ badge will appear on your profile.

The app will use a combination of automated systems and a team of moderators to monitor and review user accounts and messages for content that indicates breaches of the app's Terms and Conditions of Use. This includes:

• Reviewing photos and any other information uploaded onto user profiles;

• If an account or message meets certain criteria that indicate a breach of the Terms and Conditions of Use, the relevant account will be subject to a warning and the user's access to the app may be restricted and/or blocked;

• Users who have their access restricted or blocked will be provided with information about the reason for the decision and the steps they can take to contest it;

• Affected users will be able to contact the app's moderation team to contest the decision;

• Take appropriate technical and organizational measures to ensure the security and confidentiality of user data processed for the purpose of moderation practices;

• Provide users with clear information about the data processing activities involved in the use of moderation practices, including the types of data used, the purposes for which data is processed, and the legal basis for processing;

• Users will have the right to access, rectify, or erase their personal data processed for the purpose of moderation practices, and to object to the processing of their personal data in certain circumstances;

• Ensure that any automated systems used for moderation practices are regularly tested and audited to ensure that they operate effectively, accurately and fairly;

• The app's moderation team will be trained in accordance with the app's policies and procedures for moderating user accounts and messages.

Quote from privacy concerning face data stated below:
After the user selects an image to upload to profile, we will use the Python library "google_mlkit_face_detection " to determine whether the selected image is clear of blurriness and clear of covering face and has at least one face and only one face. We do not collect any face data on the front end. If the selected image contains only one face, as detected by "google_mlkit_face_detection ", that image will be considered as a valid image, and we will upload it to our backend core service, then upload it into our object storage (blob storage).

Once the first step is completed users are required to complete verification of the images they had uploaded. Each image will be considered as comparison data when the user wants to do face verification. During the face verification process, we will also perform face detection on the selfie image (which is taken by the user's camera), considering that image as valid and containing only one face. Then, it will be stored in the object storage (blob storage), and another service on the private cloud will perform the face verification comparison between the selfie image and the profile images. We do not collect any face data up to this point, and based on our planning, we only store and provide the result of whether the user has passed the verification or not.

Image data is also part of “user data'' which includes personal details such as name, age, location, authentication information and image data. This data will only be retained for a duration of 3 months on our system after a user has deleted their profile  for verification purposes (comparison of uploaded image to real time image) and for the needs of image training (if and only when necessary).

Information about data privacy terms about the app's collection, use, disclosure, sharing, and retention of image data can be found in our privacy policy section.

Collection of Image Data
Affinité is committed to safeguarding personal information, including image data, by implementing strict security measures to prevent unauthorized access, disclosure, or misuse. Your privacy and trust are our top priorities.

Affinité collects image data from users during the account verification process to ensure the authenticity of user profiles. This includes the submission of photographs for identity verification from the user, given that the user has provided permission to access their photo album and, or camera. We employ facial recognition technology to compare the submitted photos with profile pictures to confirm that the user is genuine and to prevent fraudulent activities. This helps in creating a safe and trustworthy environment for all users.


How we use your information  
The face data collected is used solely for:

• Verifying users identities

• Enhancing user security

• Ensuring the authenticity of profiles on our platform

• Compliance, fraud prevention and safety

How we share your information

Disclosure and Sharing of Face Data

Affinité does not share or disclose face data to any third parties, except as necessary to:

1. Comply with legal obligations.

2. Protect the rights and safety of our users and the platform. Face data is not used for advertising or any other commercial purposes.

Sharing Photographs

We do not disclose user photographs to third parties, except for temporarily caching an encrypted version with our cloud providers for the editing features of the apps. We cannot share the cached photos and videos as we do not store the encryption keys. Photos you decide to upload and take pictures of are temporarily cached on the cloud servers and encrypted using a key stored locally on your mobile device. They may remain in the cloud for up to 24 to 48 hours.

Retention of data

Retention Policy

Image data is retained only as long as necessary for the verification purpose. Verification photos are stored securely and deleted:

1. After that they are no longer needed for verification.

2. Within 3 months of the user's last interaction with the platform, whichever occurs first.

After this retention period, the data is permanently and securely deleted from our systems. Affinité is committed to safeguarding your personal information, including image data, by implementing strict security measures to prevent unauthorized access, disclosure, or misuse. Your privacy and trust are our top priorities.”

Purchases Information

If you decide to purchase any of our services, we will process your payment information and retain this securely for the prevention of fraud and for audit/tax purposes. This information will be securely stored and encrypted. 

Affinité uses automated decisions to prevent fraudulent payment transactions from being processed as part of its anti-fraud procedures. In order to do this, our systems check payment transactions for behaviour that indicates breaches of our Terms and Conditions of Use. It is possible to automatically block relevant transactions that meet certain criteria that indicate the Terms and Conditions of Use have been breached and that the transaction is likely to be fraudulent. In the event of a blocked transaction, users are notified that their transaction cannot be processed and can contact Affinité to contest the decision.

Device and Photos Information

When you use the App, we may gather information about your device, including its unique identifier, model, and operation system, for various purposes outlined in this policy. Additionally, we also collect data concerning your photos, such as those users spend time on or those with optimal lighting etc.

Geolocation Information

We collect your geolocation information to provide location-based features such as matching you with nearby users. This information is collected only when you give us permission and can be turned off on your device or in app settings. If you have allowed Affinité access to your location in your device settings when you use your mobile, we will collect information about WiFi access points. We will also collect other location information about your longitude and latitude, and we may save your device's coordinates to offer you certain features. This information helps us identify your physical location and we use it to personalize the App and make it easier for you to interact with other Users, by enabling the general locality information to be displayed to Users seeing your profile and showing you the profiles of other Users who are near you.

If you have given Affinité access to your location, but wish to turn this off, you can do so by the following methods:
- iPhone app — settings, privacy, location services, Affinité
- Android — settings, location, Affinité, permissions, location

Usage of Your Personal Data

Our main goal is to ensure your experience on Affinité is fulfilling, secure, and tailored to your preferences, fostering meaningful connections. In order to deliver an enjoyable experience to you, we may use your Registration and other information to:

• Offer you our services and features;

• Contact you with information about the App (e.g., updates and new features);

• Personalise the App/Sites and the content we deliver to you;

• We may share information with our business partners to offer you certain products, services or promotions;

• Conduct research and analytics about how you use and interact with the App/Sites;

• To test new technologies and processes designed to enhance and improve the App/Sites;

• Resolve disputes, troubleshoot problems and to enforce our Terms &Conditions;

• Use information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our service, products and your experience;

• Investigate fraud, protect our legal rights, and to enforce our Terms &Conditions;

• Protect our Users and third parties from harm.

Disclosure Information

Access by others

Personal information, including sensitive information as elaborated above, provided in your profile will be accessible by other users. We shall not disclose your contact information and prohibit the inclusion of contact information in user profiles. However, we accept no liability if you disclose your contact information in your user profile which becomes accessible by other users.

Access by third-party service providers:

The privacy policy for Users on third-party service providers, specifically paid ads based in Hong Kong, must comply with the Hong Kong Personal Data (Privacy) Ordinance (PDPO). Under the PDPO, personal data must be collected, used, and handled in accordance with data protection principles, including the requirement to obtain user consent before collecting or using their personal data. The privacy policy should provide clear and specific information on how user data is collected, processed, and used for targeted advertising. It should also outline user rights, such as the right to access, correct, or delete personal data, and describe how users can make such requests. Finally, the privacy policy should explain how user data is secured and protected against unauthorized access, loss, or misuse.

Certain trusted third parties provide us with functions and services (“Service Providers”). It depends on which App, Site and service a User engages with whether Affinité shares personal data with third parties. For example, to provide our services to Users, we typically use the following suppliers:

• Billing services – to allow customers to purchase paid features of our App (for example, Google Play)

• Authentication services – to allow customers to authenticate their account

• Social media providers – to allow customers to create/connect their Affinité account with their account(s) on such platforms (for example Google)

• Each Service Provider we engage undergoes due diligence on their data protection and information security measures, and we only provide them with the personal data necessary for the service they provide. As part of our contractual arrangements, we require our suppliers to comply with extensive obligations, including strict data retention limits, to ensure that the data they share is non-attributable.

We may employ third-party companies and individuals due to the following reasons:

• To facilitate our Service;

• To provide the Service on our behalf;

• To perform Service-related services;

• To assist us in analyzing how our Service is used;

• To assist us in analyzing how to improve our Service; or

• For any other purpose incidental to and/or appropriate for the operation of our Services.

• These third parties have access to users’ Personal Information. The reason is to perform the tasks assigned to them on our behalf. However, they are obligated not to disclose or use the information for any other purpose.

  
  

Further, we use third-party services that may collect personal information used to identify you. Links to the privacy policy of third-party service providers used by the application are listed as follows: 

• Google Play Services

• Google Analytics for Firebase

• Apple Pay Services

What others may see about you

We highly value our users and have developed specific features to showcase their uniqueness to the world. Our App is designed to make it easier for you to connect with other Users and to interact with them.

Whenever you use the Affinité App, you should assume the contents you post or submit will be publicly accessible and viewable by both users and non-users alike. We want our Users to be careful about posting information that may eventually be made public.

We urge caution regarding the disclosure of sensitive information on your profile, such as religious affiliation and health details. While you have the option to include such sensitive information about yourself, there’s no obligatio to do so. Please keep in mind that uploaded photographs may also reveal personal information. By voluntarily providing sensitive information, including through profile tags, you explicitly consent to its processing and disclosure to other users.

If you log in to or access the App through your Google or Apple on a device that you share with others, remember to log out of the App and the relevant third-party account when you leave the device in order to prevent other users from accessing your Affinité account.

Retention and Storage of Your Personal Information
We retain your personal information for as long as necessary to fulfil the purpose(s) for which it was collected and to comply with applicable laws, and your consent (if any and only if applicable) to such purpose(s) remains valid after termination of your relationship with us. Except for information required for accounting, auditing, or record-keeping purposes, we will automatically delete your personal information after 3 months of inactivity (defined as consecutively 3 months without any successful login to your Account), unless we consider it appropriate and necessary to retain such information for a longer period.

Your personal information may be processed and stored outside of the jurisdiction or country in which you reside by us, an affiliate, or an unaffiliated service provider for the purposes set out in this Privacy Policy and, under the laws of these other jurisdictions, in certain circumstances, foreign courts, law enforcement agencies or regulatory agencies may be entitled to access your personal information.

We keep your personal information only as long as we need it for the legal basis relied upon and as permitted by applicable law. Please see “Profile Verification Information (Including Biometric Information)” in Section 1, above, to learn about our retention policy with respect to biometric information.

When your Account is deleted, we make sure it is no longer viewable in the App. For up to 28 days, it is still possible to restore your Account if it was accidentally deleted. After 28 days, we begin the process of deleting your personal information from our systems, unless:

1. We must keep it to comply with applicable law (for instance, if you make purchases within the App, some personal data may be kept for tax and accounting purposes);

2. We must keep it to evidence our compliance with applicable law (for example, if an account is blocked, we keep some account information and a record of the behaviour that led to the block - this information is retained for evidential purposes in case of queries or legal claims concerning the block);

3. 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 behaviour or security incidents from opening a new account).

Warning: Even after you remove information from your profile or delete your Account, copies of that information may still be viewable and/or accessed to the extent such information has been previously shared with others, or copied or stored by others. We cannot control this, nor do we accept any liability for this. If you have given third-party applications or websites access to your personal information, they may retain such information to the extent permitted under their terms of service or privacy policies.

Age Restrictions

Despite our desire for as many people as possible to enjoy Affinité , you must be 18 years old to use the app - sorry kids, you'll have to wait until you're 18!

Under no circumstances does Affinité knowingly collect information about children, minors, or anyone under the age of 18 or market to them. We ask that you do not submit information to us if you are under 18 years old. In the event that we become aware that a child, minor, or anyone under the age of 18 has registered with us and provided us with personal information, we will promptly terminate that person's account.

If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us via info@xn--affinit-hya.co so that we will be able to take the necessary actions.

Linking Accounts
Our Services may contain links to other sites. If you click on a third-party link, you will be directed to external sites which are not operated by us. We have no control over and assume no responsibility for the use, the contents, the practices, and policies (including privacy policies) of any third-party sites or services. We strongly advise you to read all applicable terms and conditions of any external websites before you decide whether to access such websites.

Security of Your Personal Data
Here at Affinité , we value your trust in providing us with your Personal Information and we are striving to use commercially acceptable means of protecting it against loss, misuse, and unauthorized access, or disclosure. We use reasonable security measures to safeguard the confidentiality of your personal information such as secured servers using firewalls, digital certificates, Security Socket Layer (SSL), an encryption technology during credit card transactions and administrative access to site data, as well as other proprietary security measures which are applied to all repositories and transfers of user information. Unfortunately, no website or Internet transmission is 100% secure, here are some helpful tips to keep your data secure: Unfortunately, no website or Internet transmission is 100% secure, so we cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur, but we can improve your security by following the following tips:

1. Please make sure you log out of your Account after use as you never know who may stumble onto your Account!

2. Please don’t share or allow someone else to have access to your Affinité account. 

3. If you ever think someone has had access to your Account, please follow the steps set out here. We cannot guarantee the security of your personal data while it is being transmitted to our site and any transmission is at your own risk.

Your rights
Privacy laws applicable in your country may give you the following rights:

1. Right to be informed: what personal data an organisation is processing and why (we provide this information to you in this Privacy Policy).

2. Right of access: you can request a copy of your data.

3. Right of rectification: if the data held is inaccurate, you have the right to have it corrected.

4. Right to erasure: you have the right to have your data deleted in certain circumstances.

5. Right to restrict processing: in limited circumstances, you have the right to request that processing is stopped but the data retained.

6. Right to data portability: you can request a copy of certain data in a machine-readable form that can be transferred to another provider.

7. Right to object: in certain circumstances (including where data is processed on the basis of legitimate interests or for the purposes of marketing) you may object to that processing.

8. Rights related to automated decision-making including profiling: there are several rights in this area where processing carried out on a solely automated basis results in a decision which has legal or significant effects for the individual. In these circumstances your rights include the right to ensure that there is human intervention in the decision-making process.

The particular rights which are applicable to you (which might include other rights not listed above) may vary depending on your country. You should make yourself aware of the rights you have under applicable privacy laws in your country.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time, so please review it from time to time. If we make material changes to this Privacy Policy, we will notify you here, or by other means, such as e-mail, at our discretion. Your continued use of any portion of our Services following the posting of the updated Privacy Policy will constitute your acceptance of the changes.

Contact Us

If you have any questions about this Privacy Policy, You can contact us at info@xn--affinit-hya.co.