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Dating Group Member Privacy Policy

Last updated on 15 March 2016

Proprietor

This website including any mobile website (together the “Website”) is operated and controlled by Venntro Media Group Ltd. (also trading as Global Personals and White Label Dating), a company registered under the laws of England, whose registered office is Minton Place, Victoria Street, Windsor, SL4 1EG, United Kingdom and our related entities (“we”, “us” and “our”).

This Privacy Policy (together with our Terms of Use and any other documents referred to in it) outlines the manner in which we manage privacy information (personal and sensitive information) obtained through or displayed on the Website or otherwise provided by users (“you”, “your”) of our dating and networking services (“Services”) via the Website. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By using the Website and receiving our Services, you are taken to have read and agreed to our Collection Statement and this Privacy Policy that provide the terms of our collection, storage, use and disclosure of your privacy information in accordance with this Privacy Policy and Australian privacy law.

We may from time to time review and amend this Privacy Policy to take into account changes in law, technology and our operations. We will post any changes to this Privacy Policy on the Website from time to time and, where appropriate, notify you by e-mail. Please periodically review this Privacy Policy before using the Website as continued use of the Website shall indicate your acceptance of any changes. All personal information held by us will be governed by the most recent Privacy Policy posted on the Website.

How we collect your privacy information and what type of information we collect

Unless it is unreasonable or impracticable to do so, our general policy is to collect information from you directly and not from third parties. When you subscribe or sign up to use the Website, we may collect a variety of information from you, which may include:

  • personal information required to subscribe or create a member profile, such as your name, phone number, postal address, email address, contact details, photographs, age, gender, nationality, interests, marital status, location and bank/credit card details;
  • personal information provided to us if you contact us, such as our records of that correspondence;
  • personal information provided to us if you choose to complete any surveys or questionnaires for us, enter a competition or promotion of ours or participate in forums, discussion boards or other social media functions on our Website;
  • personal information if you post or transmit information via the Website to other users;
  • information that may not be personal information, such as information detailing your visits to the Website including, but not limited to, traffic data, location data, weblogs and other communication data;
  • technical information, including but not limited to the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and sensitive information, such as information or opinion about an individual’s racial or ethnic origin, political opinions or membership of a political association. Our collection of your sensitive information is subject to you providing consent.

Collecting information from third parties:

  • While our general policy is to collect information from you directly and not from third parties, there are circumstances where it is unreasonable or impracticable to collect privacy information from you directly. An example of where it is unreasonable or impracticable to collect from you directly is where we receive services from third parties that require information sharing in order to receive a complete service. For example, we work closely with third parties, such as business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers and credit reference agencies, to improve our business performance. In most of these circumstances the privacy information will be de-identified. In other cases, however, it may be impracticable to de-identify the information and indirect collection of privacy information from a third party will be necessary.
  • You will have taken to receive notice about the various means by which we collect your privacy information when you read and consent to the Collection Statement.

Purposes for which we collect and deal with your information

The primary purpose for which we collect information about you is to provide you with Services you have requested in subscribing or signing up to use the Website. We also collect information about you to:

  • process your communications, your membership of and subscription to the Website and to enable your use of the Website and the Services;
  • provide you with an up to date, efficient and reliable Service;
  • help prevent fraudulent activity, including on your account (for example, if we collect your card details we will check these details with credit agencies and reserve the right to refuse to make available the Website and/or our Services if, for example, the card details provided are reported to be fraudulent or credit agencies report the activities as being fraudulent);
  • provide customer care services. For the avoidance of doubt, we will only store limited Credit Card or Debit Card information for the purpose of assisting with customer care enquiries;
  • open and run your account;
  • administer prize draws, competitions or promotions;
  • investigate any complaints about or made by you, or if we have reason to suspect that you are in breach of the Website terms of use or that you have otherwise engaged in any unlawful activity;
  • provide you with information, products or services that you request from us or which we feel may interest you (except where you have requested not to be contacted for such purposes);
  • generally run the Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • monitor and record telephone calls for training purposes and to improve the Service to you; and
  • comply with any law (including the Privacy Act 1988 (Cth) and the UK Data Protection Act 1998).

Primary uses that include disclosure of your information

Having obtained your consent via our Collection Statement to collect sensitive information, there are many necessary secondary uses related directly to the primary purposes that involve disclosure of your privacy information in accordance with this Privacy Policy. We may disclose your privacy information to third parties in the following circumstances:

  • where other entities or people (such as members) are authorised by you to receive information held by us;
  • where disclosure of information is for the purpose of contracting a third party service provider in an area related to our Services, such as data analysis, cleansing, processing credit card information, mail outs, debt collection, marketing, research and advertising;
  • where we have an information sharing arrangement with our agents, business partners, joint venture entities or partners;
  • where our Services are offered through and accessible via a number of other websites in addition to this Website (“Associated Websites”) and data you post to the Website for access by members of the Website may be searchable and available to users of the Website Services who access it via Associated Websites;
  • where entities that sponsor or promote our Services require information;
  • in the event that we sell, trade or licence any part of the business or assets of the business that include your personal information (excluding cookies);
  • if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order for the exercise or defence of a legal or equitable claim, such as enforcing our Terms of Use; or to protect the rights, property, or our safety, our customers, or others.

If you use our Services via an Associated Website, your personal information will be managed in accordance with the privacy policy of that website. We are not in control of, and cannot accept responsibility for, any Associated Website or third party website linked to the Website.

You agree that if we transfer ownership or management of the Website, our Services, the business and/or the assets (in whole or in part) to a third party, that we may also transfer your personal data or other personal data you have provided to us, including all sensitive personal data and any other information about you to such third party, provided such third party agrees to observe this policy.

Marketing Communications

By subscribing to the Services you agree that we may use your information (other than sensitive information) to contact you by electronic mail (e.g. by email and SMS) (“Marketing Communications”) about offers, events, competitions, items, and related activities that you may find useful as well as similar products and services offered by us or any of our related entities from time to time.

You may receive Marketing Communications from us or any of our trading names, for example White Label Dating, both during the term of your membership (whether full or basic) and after termination of your membership (or deletion of your account) unless you unsubscribe from receiving Marketing Communications as set out below.

We do not sell, trade or rent your personal information to other companies and partners, but if you give us your express consent, we may share data with other reputable companies both within and outside Australia who may have interesting offers and information for you. If you wish to receive Marketing Communications from selected third parties, or if you would like to receive Marketing Communications from us about our non-dating related products and services or other third party products and services, you can indicate your consent by ticking the relevant opt-in tick box during the registration process.

How to unsubscribe from receiving Marketing Communications?

If you have consented to receive Marketing Communications, you may always revoke that consent at any time by changing your settings on the Website or exercising the "unsubscribe" option in any Marketing Communications you get from us or from our marketing partners.

Cross border transfer or disclosure of information

In the event we engage in cross border transfer of information, such as routing or storing information on servers located overseas or transferring information to our office overseas, we will ensure that adequate security mechanisms are in place to protect your information. For example, we will ensure that this policy applies to our operations internationally.

We do not currently make cross border disclosures. However, in the event we disclose your personal information outside of Australia to related entities or partners, associated websites or third parties for storage, transfer or other purposes, we will, unless an exception applies, put in place mechanisms to ensure your personal information is under a standard of protection that complies with the Australian Privacy Principles. Mechanisms may include:

  • Verifying that the recipient to which the information is transferred overseas is subject to binding and enforceable laws that protect the information under a substantially similar standard as that imposed by the APPs; or
  • Entering into a contract or memorandum of understanding that requires the overseas recipients and any subcontractors to comply with the APPs in relation to the disclosed information.

Cookies

Our Website uses cookies to distinguish you from other users of our Website. Cookies are small pieces of removable data that are stored by the web-browser on your computer, mobile phone or other device that identifies your computer, mobile phone or other device when you visit the Website. We use cookies to improve the Website and the Services available to you.

For more information about the cookies we use and the purposes for which we use them, please see our Cookie Policy.

Third party links on the Website

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Maintaining the integrity, currency and safety of your privacy information

This section explains how Venntro Media Group Ltd. holds your privacy information, how you can access your privacy information, update your privacy information, complain about an alleged breach of the APPs or make any related enquiry.

Maintaining currency of your information

We rely on accurate and reliable information to deliver quality and effective services. If we are satisfied that any of the information we have about you is inaccurate, out-of-date, irrelevant, incomplete or misleading, or you request we correct any information, we will take steps as are reasonable in the circumstance to ensure the information held by us is accurate, up-to-date, complete, relevant and not misleading.

If we disclose your privacy information that is later corrected, we will, or else you may ask us to, notify the entity that received the incorrect information about that correction.

Should we refuse to correct the information, we will explain the reasons for refusal. We will also show you the complaint procedure if you wish to lodge a formal complaint about our refusal.

Restricting Access

We respect and are committed to protecting your privacy and that of other users, and wherever possible we require you to provide login information and identify yourself to access the Website.

We also make an effort to ensure that members of the Service are not connected with other members that may be inappropriate. To do this we may apply classifications to Associated Websites that provide access to the Service, including to the Website. These classifications may restrict the availability of:

  • communications between yourself and other members of the Service;
  • the details of other members of the Service to yourself; and
  • your details to other members of the Service.

Security of data stored and transmitted electronically

Transmission of data and information via the Website is not a secure or encrypted transmission method for sending your personal data, unless otherwise indicated on the Website. Accordingly, your attention is drawn to the fact that any information and personal data carried over the internet is not secure and any transmission is at your own risk. Information and personal data may be intercepted, lost, redirected, corrupted, changed and accessed by other people.

We take reasonable steps to protect the personal information we hold from misuse and loss, and from unauthorised access, modification or disclosure. For example, we set strict security standards to prevent any unauthorised access to your personal information once we have received it and wherever possible we will use adequate security software and working procedures to ensure the security of your personal information. To prevent unauthorised access, maintain accuracy, and ensure proper use of personal information, we have employed physical, electronic, and managerial processes to safeguard and secure the information we collect online.

Accessing your information or lodging a complaint

Accessing and correcting information

You are entitled at any time, upon request, to access your privacy information held by us. We will respond within a reasonable time after the request is made and give access to the information in the manner requested by you, unless it is impracticable to do so. We are entitled to charge you a reasonable administrative fee for giving you access to the information requested.

Should you be refused access to your information, we will explain the reasons for refusal - any exceptions under the Privacy Act or other legal basis relied upon as the basis for such refusal – and, if you wish to lodge a formal complaint about our refusal, explain the complaint procedure.

Lodging a complaint

Should you wish to complain about a potential breach of this Privacy Policy or the Australian Privacy Principles please contact our Privacy Officer.

The Privacy Officer will make good faith efforts to rectify the issue and respond within a reasonable period after the complaint is made.

Contact details:

Privacy Officer
Venntro Media Group Ltd.
Minton Place
Victoria Street
Windsor
SL4 1EG
United Kingdom
Ph: +44 (0) 1753 271 280
Email: dataprotection@venntro.com.

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