Changes: To the maximum extent permitted by law, we reserve the right to make changes to this Policy at any given time. If you want to make sure that you are up to date with the latest changes, we advise you to frequently visit this page.
Children and privacy: We do not solicit or target persons under 18 years of age. We do not permit children under the age of 18 to become users, and we do not knowingly collect any information relating to children under the age of 18. By submitting information to us you represent that you are over the age of 18, and if you suspect any user is not at least 18, please follow the reporting options within your account to inform us.
We, Slow Dating Ltd (registered in England company number 04853880) (“us/we/our”) are the ‘data controller’, meaning that we are company that is responsible for the collection, processing and storage of your data when you use our services.
As a large organization, we have a number of subsidiary and sister companies within our business group, that operate some of our sites on our behalf or provide services to us to enable us to provide the Services to you. For data protection purposes, these companies are considered data processors subject to data processing agreements with us, and we remain the controller with responsibility for your data. For more details, please see Section 6B of this Policy.
We value our users’ privacy, and comply with all applicable data privacy laws of the jurisdiction in which we operate including the General Data Protection Regulation ((EU) 2016/679); the UK’s Data Protection Act 2018; the Privacy and Electronic Communications Directive 2002/58/EC (as updated by Directive 2009/136/EC) and the Privacy and Electronic Communications Regulations 2003 (SI 2003/2426) as amended, collectively the “Data Laws”. The specific law that will apply to you and your data may be determined by the location in which you live, or in which we are based. Any reference to ‘personal data’ within this Policy has the meaning ascribed to it by the GDPR (or the UK’s Applied GDPR).
2A. LAWFUL BASIS FOR PROCESSING DATA
In accordance with the GDPR and the UK’s Data Protection Act, we are required to inform you of the lawful basis for processing your Personal Data. Our lawful basis for processing Personal Data is for the purposes of performing a contract to provide the Services to you, or steps prior to entering into a contract. Where this is not appropriate, we obtain the relevant consents from you and consent is the lawful basis. Where neither contract nor consent is appropriate, legitimate interests is the lawful basis. Our purpose for processing is described in detail in Section 5.
Data Laws give users a number of rights regarding any personal data that you have provided to us which you are free to exercise at any time, however, we apply the same standards to all users as we want to ensure that you have open access to your data and control over its use.
(a) Right to access personal data we hold about you
You can request a copy of the personal data that we hold about you, and we aim to respond within 14 to 30 days. To obtain a copy of your data, simply email our data protection team at [email protected] attaching a photo or scan of your photo ID (passport or driving license) and a utility bill (to provide proof of your address). We need to make sure you are who you claim to be when requesting copies of data, and once we have verified your identity we will email or post a copy of your data to you. Your identification documents will be viewed for the purpose of verifying your identity prior to us making any personal data disclosures to you, and the identification documents will not be stored for any period of time longer than necessary to do this, nor will they be used for any purpose whatsoever other than facilitating your request for access.
(b) Right to amend/correct the data we hold on you
We want to make sure that data in our database is correct, so please contact us to make any amendments to our records by emailing [email protected]
(c) Opting out / restricting our processing
It is ok to change your mind about what personal data you allow us to use and keep and what you do not want us to use or keep. You can amend your settings through your account at any time, or contact [email protected] We must advise you, however, that opting out of some personal data processing/storage will result in a loss of functionality of the services and a reduced user experience.
(d) Right to “be forgotten” / right of erasure
You have the right to have all of your personal data erased when you stop using the services and close your account. We may need to keep a record of some data for security purposes (for example to assist law enforcement agencies with any criminal investigations) or for payment processing (to prove to banks that we have been authorised to take payments from you if you pay to use the services). There is more information about how long we keep data for below in Section 9 of this Policy. To request erasure of all of your personal data, please contact [email protected]
This section explains the types of data we collect about you, and when it may be collected. Please read this section carefully, together with Sections 5 and 6, which explain how we then use that data.
(a) We collect data when you book an event or create an account with us
We will collect your personal details (which may or may not be considered personal data within the meaning of the Data Laws) including but not limited to your real name, username, telephone, email address, date of birth, and any other information you submit when you create a profile and sign up to our Services;
You may choose to provide information which relates to your racial or ethnic origin, sexual orientation or religion, and this type of information may be defined as “sensitive” or “special” categories of personal data under applicable Data Laws. Therefore, by choosing to provide this type of information, you consent to our collection, storage, use of and processing of that information for the purposes of providing the services to you;
You may share photographs or video content – see Section 5H below – and any other information you choose to upload including but not limited to things such as text you’ve written about yourself describing your personality, likes, dislikes, lifestyle, profession and interests.
(b) We collect data when you communicate with us
If you contact customer support we will keep any information you provide to us including records of correspondence, and you should be aware that we monitor and may record telephone calls and written correspondence for training and security purposes.
If you provide feedback or testimonials to us, take part in any customer survey, or participate in events, promotions, product launches or competitions, we will keep any information you provide.
(c) We collect data when you visit or otherwise make use of the services
If you are just browsing our site, editing your profile, speaking to other users, making payments to upgrade your membership, or doing any other activity within our services, we will collect different data as you do it, some of which may be considered personal data:
Any information you upload to your profile at any time, including your photos and videos and all other personal and non-personal information described above;
Any messages you send or receive to us or other users through the services, chat logs (if offered) and logs of your signs in and on-site activities;
A record of all of your activity on our services;
Details of any transactions that you carry out, including any information we require to provide the products or services that you sign up or upgrade to, such as financial information that you provide to us or our payment service provider (usually in the form of payment card data) for the purposes of paying for any products, features or services offered by us;
Data from your other social network accounts if they are linked to our sites (more details below);
Your location according to the IP address assigned to your computer or device by your Internet Service Provider, and mobile location data (more details below);
Usage data about how you use our site. This is what we consider Anonymous Data, which we collect using Cookies (more details below).
Some of these activities are a bit more detailed, so please read below about the specifics of some of these data types and how we collect them from you.
(d) We collect information about you from other social networks that you use
Some of our services may have the ability to link your use of our services to other social networks you might have access to, if you choose to link them. If you have an account with another social network, e.g. Facebook, you can choose to share the data you have on our site with that network. To enhance your experience and create a personalised service, we may ask you to login to your Facebook account. By doing so you grant us access to your information stored on your Facebook profile, including, without limitation, your personal information, photographs, videos, interests and locations. When you login to the other network or install our app, we will receive basic information from you, including, but not limited, to your name, photos, gender, networks, user ID, friends list and any other information you make public (and your email address). If you have logged into other social networks and linked them to any of your profiles or accounts you hold with us, you grant permission for us to post updates, including location information, on your behalf.
(e) We collect information about your location when you use our services
We can collect location data from your computer and/or mobile device. When accessing the services from a mobile device, you will be given the option to allow location sharing with our application. If you do not wish to share your location data with us, please turn off this feature by following your mobile device instructions to do so. We can track your IP address if you are using a computer to access the services. If you are using a mobile device we use GPS with an accuracy range of 20 to 100 metres. Although location data is anonymous and cannot identify you, it can be shown to other users, so please exercise caution if you do not wish to publicise your location. If you choose to change or turn off location sharing, in order to provide you with a more localised service and localised matches, we will show you as being at a randomly generated location within the postal code area that you have provided. We also use your location data to research our own services, develop new products and improve our services, including using third parties to help us either provide the Services to you or develop new ones, and target advertising to suit your user experience. Your devices can give us lots of information about the device, including the brand, model, version of operating system, installed app details, email accounts, mobile carrier and so on. We may also connect your account with location data from Foursquare, and can show your Foursquare check ins on our map within some of our services.
(f) We collect information about your contacts, if you choose to share it with us
Some features of the Services may allow you to choose to share your user experience with people you know (“your Contacts”), or to invite them to join the Services. When given the option to do so, you can choose to upload your Contacts information; we will request their name and email address. If you give us your password to upload these Contacts through a web based email provider, we shall not store your password after you have uploaded your Contacts’ addresses. You may also choose to invite friends through your connected social networks. You assume all responsibility for ensuring that when you select a friend to be invited by email, application or SMS, that the person wants to receive that invite from you and has consented to receiving the communication.
In summary, we process data, including personal data and photographs, that we collect from you for the following legitimate purposes:
To administer your user account with us (including notifying you of any events or event status updates, tips, announcements, updates, special offers or services);
To process your activity on the services, including making payments;
To help us improve the structure, layout and usability of the Services;
To allow you to participate in any interactive features of the Services (including features that require a mobile phone number);
To help personalise your repeat visits to and usage of the Services;
To notify you of any compatible matches or any matches who are near your location;
To provide you with information on products or services or news and offers that you request from us;
To answer any questions you may raise or respond to any comments you may send to us;
To notify you about changes to our service or the functionality of the Site;
To carry out market analysis and research and to conduct marketing activities;
The following sections provide more detail on how we use your information, including personal data.
5A. Providing our products and services
We use the information we collect about you:
to fulfil your requests for our events, products, programs, and services;
to respond to your enquiries about our offerings;
to provide, personalize, and improve our offerings; and
to offer you other products, programs, or services from us and our affiliates, business partners, and selected third parties that we believe may be of interest to you.
We may also use information that we collect about you to
perform research and analysis about your use of, or interest in, our products, services, or content, or products, services, or content offered by others; or
develop and display content and advertising tailored to your interests on our Website and other websites, including providing our advertisements to you when you visit other websites.
We use the information we collect for our online forums and communities to provide an inter-active experience. We use this information to facilitate participation in these online forums and communities and, on one or more occasions, to offer you products, programs or services.
If you choose to submit content, we may publish your screen name and other information you have provided to us on our Website, the Internet, or elsewhere.
As our platform develops we may suggest content to you and if we do this, we will perform “profiling” on your data, which means our system analyses your data and works out what content to display to you. Profiling and associated automated decision-making is conducted on the lawful basis of being necessary to provide the Services to you, or, where not appropriate, your consent.
We use information about you to communicate with you, including:
to notify you when we make changes to our terms;
to otherwise enforce or exercise any rights in our terms;
to update you on the status of an event;
to confirm purchases you have made through our Website; or
to contact you about your account with us (including managing your account and providing you with customer support).
If offered, you may also choose to receive push notifications from us on your mobile device. Please note that any communications from other users are through our internal systems, which we use to match the message to you and generate an email notice without disclosing any information aside from your chosen screen name and the information contained in your profile.
5D. Mobile device data usage
5E. Use of non-personal information
We use aggregate information about our users and non-personal information that we collect to improve the design, functionality, and content of our Website and to allow us to personalize your experience with our Website and offerings. We use this information:
to provide, maintain, personalize, protect, improve, and develop our products, programs, and services and to operate our business;
to analyze usage and performance of our Website (including to perform ad tracking and website or mobile application analytics); and
for us and our affiliates, business partners, and selected third parties to offer you products, programs, or services.
5F. Safety and security
5G. Creation of duplicate profiles across our network of sites and services
When you sign up to any one of our Services we may send you an email shortly afterwards advising that we have created a duplicate profile on our Partner Sites to enhance your chance of finding a suitable match. When we email you about this you will have the option to decline this service, which costs nothing extra.
5H. Important notice about how we use your photographs
5J. How we use your information about your Contacts
If you choose to upload your Contact’s name and email address and/or mobile number you are allowing us to send an email or social network or mobile invitation on your behalf, inviting your Contact to join the Services. We will store your Contact’s name and email address solely for the purposes of inviting them to sign up to our Services and for associating your Contact with you and other people they may know. If your Contact does not want us to store their email address which you uploaded to our Services, they can ask us to remove it by contacting our support team. We will not store your Contact’s information after invitations (up to a maximum of 3) have been sent. Your Contacts will then only receive future emails from us if they choose to accept the invitation and join our Services, or if you use any of our tools to share experiences with your Contacts and you input their email address for us to use again.
6A. Legal disclosures
We may be required by law e.g. through potential or actual litigation, court order, public or governmental authorities, or rules and regulations within or out of your country of residence to disclose all or part of your information to third parties. We may also deem it necessary to make such a disclosure in the event of an issue of national security, law enforcement or other such similar situations as we deem necessary, including, for example, allegations of alleged infringement of copyright, trade marks or other third parties’ rights by users, or any criminal activity.
6B. Within our Partner Sites and our own business group
Within our corporate family of companies, we may be required to share your information to allow us to provide the services to you, as our companies support us in the context of being service providers, which may include, data hosting, server maintenance, customer support, data analytics, marketing, legal and financial services, payment processing and safety and security services.
6C. Change of ownership of the business
As we continue to develop our business, we might sell or buy assets or ownership. In such transactions, the information we have collected about you will generally be one of the transferred business assets. We may share information about you with a buyer or prospective buyer of our business, our professional advisers, such as our lawyers, where it is necessary for them to advise, other persons, if we are under a duty to disclose or share your information in order to comply with any legal obligation.
6D. Third Party Service Providers
We share your personal information with third party service providers in order to provide the Services to you, including third parties who assist us with information processing, credit and payment processing, fulfilment of your subscription order, managing and hosting data, and conducting consumer research or satisfaction surveys. These disclosures relate to providing our Services, improving our Services and delivering targeted advertising to you. We do not provide your contact details to third parties for direct marketing by them to you without your express consent. We do not store credit card details, nor do we share customer details with any third parties.
6E. Business partners
When you register or make purchases on our Website or click-through our advertisements offered on third-party websites or applications, we may share your personal information with the businesses with which we collaborate to offer you the applicable products, services, or any advertisements. When you elect to engage in a particular merchant’s offer or program, you authorize us to provide your email address and other information to that merchant. Offline we may also require to share your information with venues if they request it, with a legal or security basis for such a request.
6F. Advertisement servers
6G. Aggregated or non-personal information
We may share your non-personal information we collect under any of the above circumstances. We may also share it with other companies and third parties to develop and deliver targeted advertising on our Website and on websites or applications of third parties, and to analyze and report on advertising you see. We may combine non-personal information we collect with additional non-personal information collected from other sources.
(a) When we market to you directly about our products and services
We may share your information with our Partner Sites to develop and deliver to you targeted advertising of our Partner Sites and products and services, or to help us to prepare marketing reports. We may send you information about our Partner Sites’ products and services, news and offers, and selected third party products and services that we think may be of interest to you. We may do this by contacting you through the email address or mobile phone number that you have provided. Any communication received from us will clearly state that it is being sent by us. You have the option to opt-out of our marketing communications at any time (see below).
(b) When third parties market to you (Our “third party Partner Services”)
If you have consented to receive marketing communications from third parties, referred to as Partner Services, your data may be passed on to such third parties as we enter into data sharing agreements with, from time to time, for marketing and analytical reporting purposes. We cannot be held liable for the content of the third party’s communications or products/services they are promoting. If you have provided this consent, but change your mind, you can opt-out at any time (see below). Please be advised that you will also be required to contact the individual third parties who have been marketing to you if you wish to stop receiving their communications directly.
(c) Opting Out of Marketing
If you change your mind about the marketing consent you have granted to us, you can amend your preferences under the “My Account” section of your chosen Site or by emailing us at [email protected]
Generally speaking, we only store data for as long as it is necessary to provide products and Services to you and others, with information typically being held until you cancel your membership.
For data storage purposes however, our users are considered as either being:
(a) Active Users: this means you regularly log on to our Services and use the Services in any way;
(b) Inactive Users: this means that you have not cancelled your account, but you haven’t logged in for 9 months or conducted any activity on our Services in that time;
(c) Cancelled: this means that you have followed our cancellation process and actively cancelled your account.
(a) Active Users
If you are an Active User we will store your data until you cancel your account.
(b) Inactive Users
If you are an Inactive User, you should be aware that we will continue to store your data until you cancel your account, and also continue to market to you. Even if you have not logged on for a few months, we still hope you will return to use the Services regularly and we want your information to be there for your convenience, so you should be aware that you will still appear in our search results for other users, and your profile will remain visible. The responsibility to change your preferences or cancel your account lies with you.
(c) Cancelled Users
If you are a Cancelled User, we will delete all of your data nine months after the date of cancellation. It is important that we retain your data for this short period after cancellation to ensure that we can answer any payment or other account related queries, or provide information to third parties in line with our disclosure provisions outlined in this policy, e.g. assisting police investigations. Even after you remove information from your profile or delete your account, copies of this information may still be viewable and/or accessed on the Internet to the extent such information has been previously shared with others, copied or stored by other users, or to the extent such information has been shared with search engines. 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.
(d) Storage of activity data
Whilst we retain your Personal Data, Sensitive Personal Data and Anonymous Data as outlined at (a) to (c) above, there are some features of our Services that we store data in respect of, for different periods of time. For example, messages are only stored for thirty days, likes and other similar activities are stored for ten days. All other profile and activity information, including photographs, block lists, search histories etc., are stored until nine months after your account is cancelled.
(e) Banned and terminated users
If your account is ever terminated by us, you are detected as a potential or actual scammer, or a potential or otherwise threat to our business or our users, your email address will be retained on our internal blacklist for as long as we deem necessary to protect the business and its users.
We recommend and encourage you (and all our members) to think carefully about the information they disclose about themselves.
Do not put email addresses, URLs, instant messaging details, phone numbers, full names or addresses, credit card details, national identity numbers, drivers’ license details, and other sensitive information, which is open to abuse and misuse in your profile.
Please be careful about posting sensitive details about yourself on your profile such as your religious denomination and health details. While you may voluntarily provide this information to us when you create your profile, including your sexual preferences and ethnic background, there is no requirement to do so.
Please remember that photographs or any video clips that you post on the Website may reveal these kinds of sensitive personal data. Where you do upload and choose to tell us sensitive information about yourself, you are explicitly consenting to our processing your information and making this public to other users.
When you post information about yourself or use the messaging service, the amount of personal information you share is at your own risk. In addition, these postings may appear on other websites or in searches on the subject matter of your posting. If you post anything that is inconsistent with our terms, we reserve the right to terminate your account.
Cookies enable us:
To estimate our audience size and usage pattern;
To store information about your preferences, and so allow us to customise the Services according to your individual interests;
To speed up your searches;
To recognise you when you return to any website or application;
To provide anonymised statistical information: Non-personal data may be gathered on our behalf using cookies, log file data, and code that is embedded on our websites by specific third party partners to help these selected third parties to deliver relevant advertisements to you.
We use this cookie information to help improve the services we provide to you. When you visit the publicly available sections of the Services, a session ID cookie is placed on your computer for the duration of your visit only. We also place persistent cookies (also known as local storage devices) on members’ computers to make your login process faster and easier.
Controlling and deleting cookies
by using the opt-outs provided below;
by visiting www.youronlinechoices.eu ;
or through your browser, as explained below.
You can also block cookies by changing your browser settings so that cookies from this Site cannot be placed on your computer or mobile device. In order to do this, follow the instructions provided by your browser (usually located within the "Help", "Tools" or "Edit" facility). Disabling a cookie or category of cookie does not delete the cookie from your browser; you will need to do this yourself from within your browser.
What cookies are used for and why we use them on this Site
This table shows the cookie functions and why they are used, although our uses may change over time and it is therefore important that you revisit this page to understand any updates to these uses:
Analytics and Research
We use the information collected by Google Analytics to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from, and the pages they visited. You can opt-out of Google Analytics here.
Security and Site Integrity
Site Features and Services
We need to use certain cookies and local storage devices to ensure our members have the best possible experience, such as assisting with your navigation of our site, ensuring pages load up quickly, and responding to your requests more promptly.
Ad Serving & Behavioral Advertising
We sell space on our websites to advertisers. We use several services to help us and advertisers understand what adverts you might be interested in. These cookies hold information about the computer – they do not hold personal information about you (i.e. they are not linked to you as an individual), but they might hold a record of what other websites you have visited – so we may show you a car advert if you have previously visited a motoring website.
Advertisements on this Site and the other sites you visit are provided by other organizations. Our advertising partners will serve advertisements that they believe are most likely to be of interest to you, based on information about your visits to the Site and other websites. In order to do this, our advertising partner may need to place a cookie on your computer.
For more information about this type of online behavioral advertising, about cookies, and about how to turn this feature off, please visit www.youronlinechoices.eu and select your country.
These are some examples of the services we use and how you can control those cookies. This list is not exhaustive and is subject to change. Please visit www.youronlinechoices.com for active cookie management on your device. Please note that turning off advertising cookies won’t mean that you are not served any advertising, merely that it will not be tailored to your interests.
Our websites, apps and promotional materials, may, from time to time, contain links to and from the websites of our third party 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.
F.A.O. DATA PROTECTION OFFICER
In accordance with the applicable UK and EU Data Laws, the following representatives are authorised to receive written communications on our behalf from the relevant supervising authorities and any data subjects exercising their rights under the UK Data Protection Act 2018, or the European General Data Protection Regulation:
UK Representative (in accordance with the UK Data Protection Act 2018):
Due to our business being located within the UK we are not required to appoint a representative. Please contact the above Data Protection Officer for all enquiries
EU Representative (in accordance with the EU GDPR):
We do not process European resident data and therefore do not require a representative.
We hope that we will be able to resolve any complaint that you may have, however, if you are not happy with how we handle any complaint, depending on your place of residence, you may be able to raise a complaint at any time with your country’s national data protection authority.