newsocial.club (hereinafter “we”, “us”, “our” etc.) values the privacy of all of our users and has established this privacy policy (hereinafter the “Privacy Policy”) to show commitment to these rights and to safeguard your privacy. If you (hereinafter “you”, “yours”, etc.) use (i) newsocial.club website (hereinafter the “Website”) or (ii) newsocial.club apps, including mobile applications, downloadable products as well as pages operated by newsocial.club on social media sites and other platforms, (points (i) and (ii) collectively the “Services” provided under the Terms of Use Agreement (‘Terms’)), then we urge you to read this Privacy Policy and become fully informed about how it affects your personal privacy. Please refer to this Privacy Policy to find out how to CONTACT US if you have any questions about the contents herein.
TABLE OF CONTENTS
1. WHO WE ARE
2. WHEN YOU ACCEPT THIS PRIVACY POLICY
3. AGE RESTRICTION
4. WHAT DATA WE COLLECT AND HOW
INFORMATION YOU PROVIDE TO US
INFORMATION ABOUT HOW YOU USE OUR SERVICES
INFORMATION FROM YOUR CONTENT
YOUR COMMUNICATIONS WITH US AND OTHER USERS
PERSONAL DATA WE COLLECT AUTOMATICALLY
PERSONAL DATA WE COLLECT USING COOKIES AND SIMILAR TECHNOLOGIES
IF YOU FAIL TO PROVIDE PERSONAL DATA
5. HOW WE USE YOUR PERSONAL DATA
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
AGGREGATED DATA
AUTOMATED DECISION MAKING AND PROFILING
AI FUNCTIONS
MARKETING
CHANGE OF PURPOSE
6. DISCLOSURES OF YOUR PERSONAL DATA
OUR SERVICE PROVIDERS AND STAFF
PARTNERSHIPS, AFFILIATES AND AUDIT
TRANSFER OF BUSINESS
LEGAL DEFENSE
INTERNATIONAL TRANSFERS
7. HOW LONG WILL WE KEEP YOUR PERSONAL DATA
EXCEPTIONS
DATA DELETION REQUESTS
8. CHANGES TO YOUR PROFILE AND OPT-OUT FROM COMMUNICATION
HOW TO MAKE CHANGES IN YOUR PROFILE
HOW TO OPT-OUT FROM E-MAIL MESSAGES
9. YOUR LEGAL RIGHTS
IF YOU ARE IN EU
IF YOU ARE IN US
IF YOU ARE IN JAPAN
10. CONTACT US
11. MISCELLANEOUS
LINKS TO OTHER WEBSITES AND APPS
INTELLECTUAL PROPERTY
YOUR LIABILITY
WHO WE ARE
Our Services are operated by DilMil Inc. (the “Data Controller”). Please find more details in the CONTACT US section down below.
We have appointed a Data Protection Officer (“DPO”) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise YOUR LEGAL RIGHTS, please contact the DPO using the details set out in the CONTACT US section down below.
WHEN YOU ACCEPT THIS PRIVACY POLICY
By using our Services, you are accepting the conditions set out in this Privacy Policy.
AGE RESTRICTION
Persons under 18 years of age are not allowed to use our Website or any of our Services, as they are not targeted at persons under the age of 18. Any personal data we receive from users we believe to be aged 18 or under will be removed from our database.
If you believe that we have collected, used or disclosed personal data of a person under the age of 18 (or the age of majority in your jurisdiction), please contact our support team via the CONTACT US section down below so that we can take appropriate action.
WHAT DATA WE COLLECT AND HOW
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
INFORMATION YOU PROVIDE TO US
When you register, use or subscribe to our Services or take part in any interactive features of the Services (such as any communications with virtual companions, our promotions, quizzes, surveys, research or other services or features), we may collect a variety of information, including:
Contact Information such as your name, user ID, email address, phone number, and address (“Contact Data”).
Sensitive Information such as race, ethnicity, sexual preferences and experiences, political affiliation, religious affiliation, union memberships you may provide through the use of our Services (your “Sensitive Personal Data”).
Other information such as birth date, videos, password, demographic information, place of work or education, your personal interests and background, gender, age, dating age range preference, physical characteristics, personal description, life experiences, geographic location, your photos, videos and any information derived from them (collectively “Extended Data”), and any other information you share during the use of our Services, including in course of communication with virtual companions.
Information disclosed through communication with our support team. You may also provide us with other personal data through your participation in user-to-user communications, chats, or when you otherwise communicate with us regarding our Services;
Mandatory information 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.
INFORMATION ABOUT HOW YOU USE OUR SERVICES
We may collect information about your participation and actions during your use of our Services. This may include information such as the pages you view, how you browse our platform. It can also include the various functions and features that you use, the connections you make, other friends or contacts you invite to the Services and profile searches you perform, or your use of our applications.
INFORMATION FROM YOUR CONTENT
When you upload any content photos, videos or other information to our Services, we may collect information about the content, such as the time, date and place the photo or content was taken or uploaded (also known as metadata), and how you use them, who views them or with whom you share. We may also scan and analyze the photos, videos, and other content you provide to us using third party services for several purposes, including for anti-fraud purposes, for the assessment of whether the photos are consistent with our Terms, to help identify your interests and activities, such as if your photo includes pets, sports, or trips, and to help us provide better services for you.
YOUR COMMUNICATIONS WITH US AND OTHER USERS
We collect communications you send to us (such as email, phone, sms, push notifications, Whatsapp, Facebook, Wechat, QQ and any other messengers), comments that you post on the pages we have on a third-party service, such as our Instagram, Twitter, Whatsapp, Facebook and other pages, as well as messages that you send us directly through those services (“Communication Data”). We may also collect and analyze any comments, photos, messages or other content or communications you and other users share on our Services or send to each other.
PERSONAL DATA WE COLLECT AUTOMATICALLY
When you access our Services, we and our third party partners automatically record information from your device and its software, in particular, we collect:
data about your interaction with our Services and your communications with us. This is personal data we receive from devices (including mobile devices) you use when you access our Services. This personal data may include the following: device number, device ID or unique identifier, device type, unique device token, operating system, application crash-data, IP address, user agent, platform, Software Development Kit version, anonymous User ID, application version, device identifiers such as: IDFA (Identifier For Advertisers), Android ID (Android device), referrer url (Google Play Store), Google Advertiser ID, device model, manufacturer, OS version, in-app events, network status (WiFi/4G), login source, application use, age, gender, whether the profile is linked to Facebook/Google and their profile photo, notification status, internet navigation details (for example, how your mouse moves on a screen which tells us if you’re a bot or real person) registration date, credits bought, date of last payment and use of services (“Technical Data”);
Real location data, including physical location data from your mobile device including specific geographic locations through IP, GPS, Bluetooth, or WiFi signals (“Location Data”).
In some jurisdictions, we are obliged to obtain certain information from third parties. For example, we will receive so-called ‘age signals’ through API from third parties, like App Store or Google Play, about your age.
PERSONAL DATA WE COLLECT USING COOKIES AND SIMILAR TECHNOLOGIES
We use cookie technology on the Website as part of the statistical reporting. It contains personal data used by the Website to personalize your experience (e.g. rotating profiles on the newsocial.club home page) and to gather statistical data, such as which pages are visited, what is downloaded during your experience, the domain name and country of the internet provider that you have come from (e.g.‘aol’, or ‘umich.edu’), and addresses of those websites you have visited just before and after the Website. Nevertheless, we do not associate any of this personal data with you as an individual. Only an aggregate measure is taken. Cookie personal data allows us to follow your “clickstream” activity (i.e., how visitors navigate our Website as they move from page to page). It is important to note that cookies never capture your individual email address or any of your private personal data.
We also operate standard web server log files to assist in counting visitor numbers and analyzing our Service technical capability. This personal data is used to establish how many people use our Services, enable us to organize our Services for the best usability, make our Services suitable for your browser, and ensure that our Services are working at their full potential. Although we collect personal data on online traffic, we do not record personal data on particular visitors of our Services, which means that no personal data about you as an individual is retained or used. You are able to browse the Website without cookies by configuring your browser to reject all cookies, or to alert you when a cookie is sent. Since each browser is different, you should refer to the “Help” menu of your browser to learn how to change your cookie preferences.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where you do not provide the personal data detailed in this Privacy Policy, you may not be able to use our Services. Please note that providing incorrect, outdated, or false information may result in our services not functioning properly or at all. To ensure the best experience, we encourage you to provide accurate and up-to-date data.
HOW WE USE YOUR PERSONAL DATA
Generally, we may use your personal data based on the following legal grounds:
Where we need to perform the contract we are about to enter into or have entered into with you for the Services.
Where you have given consent for us to use your personal data and, where applicable, your Sensitive Personal Data to provide certain Services (you may withdraw your consent for some uses of the data at any time in your Profile or via CONTACT US section down below).
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
Unless specifically mentioned, we do not use your personal data for any other reason. We will never sell your personal data to a third party, and we will never give a third party access to your personal data, except as may be provided in our Terms, Refund and Cancellation Policy, this Privacy Policy or unless required to do so by law.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out in the table below a description of the ways we plan to use your personal data, and which of the legal grounds we rely on to do so. Please CONTACT US if you need details about the specific legal ground we are relying on to process your personal data where more than one legal ground has been set out in the table below.
Purpose/Activity | Type of personal data | Legal grounds for processing personal data |
To register you with our services | (a) Profile Data, such as name, age, sexual orientation, marital status, number of children, and location, date of birth and/or age, place of birth (if applies) (b) Contact Data such as email address, phone number, or Social Media User account, as limited by your privacy settings (c) Data from Social Media Sites (If you use Facebook or Google to log-in to the Services), including any interests or other data imported from your Social Media Sites (d) Technical Data, such as device ID or IP Address, including timestamps (e) Extended Data | (a) Performance of a contract with you (b) With your consent in the case of sensitive personal data. (c) Where we are required to verify age, we do it per our legal obligations. |
To provide the Services to you, including: (a) Maintaining a profile, answering questions, and providing information about yourself; (b) Analyzing your personal data to match you with other users; (c) Allowing you to communicate with other users; and (d) Enabling you to pay for the Services. | (a) Profile Data, such as name, age, sexual orientation, race, marital status, number of children, and location, date of birth, place of birth (if applies) (b) Contact Data such as email address, phone number, or social media user account (c) Transaction Data,such as name, address, transaction ID, timestamps, email address, currency, and routing number (d) Communications Data, including the content of messages, the name and ID of the recipients of the communications, the timestamp, IP address and/or Device ID of the parties to the messages (e) Photos, including various analytics and scoring results (f) Contact Data (g) Analytics Data (h) Technical Data (i) Extended Data | (a) Performance of a contract with you (b) With your consent (with regard to your Sensitive Personal Data) |
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or Privacy Policy (b) Communicating with you | (a) Profile Data (b) Transaction Data (c) Contact Data (d) Communications Data (e) Photos (f) Extended Data | (a) Performance of a contract with you (b) Necessary to comply with a legal obligation |
To administer and protect our business, our Services, contravention or unauthorized use of our Services and your personal data (including security, fraud, court proceedings, troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). For any legal proceedings these rights may be exercised by the Data controller and any of its affiliates, subsidiaries, directors, etc. | (a) Profile Data (b) Contact Data (c) Technical Data (d) Communications Data (e) Third party data provided to us by trusted partners, including proprietary scores, red flags, demographic information, usage data, and other information used to determine whether your account is being used improperly, accessed by an unauthorized third party, or represents a security or fraud risk to the Services or their users. (f) Extended Data (g) Any personal data related to the user in communication with support team or companion | (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, cybersecurity, to prevent fraud and in the context of a business reorganization or group restructuring exercise) (b) Necessary to comply with a legal obligation |
To deliver relevant content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | (a) Email address (b)Device ID (c) IP Address (d) Location (at country, state, city, or postal code level) (e) Gender (f) Age (g) Technical Data (h) Cookies, pixels, or advertising tags | (a) Necessary for our legitimate interests to deliver your Service-related content and communication as well as study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy (b) With your consent for targeted advertising and profiling to serve more accurate advertising content to you. |
To use data analytics to improve our Services and products, marketing, customer relationships and experiences | (a) Profile Data (b) Technical Data (c) Communications Data | Necessary for our legitimate interests, such as: to define types of customers for our products and services, to keep our Services updated and relevant, to develop our business and to inform our marketing strategy. |
To respond to requests from law enforcement, including banks, card processing companies and investigation authorities | (a) Profile Data (b) Transaction Data (c) Communications Data (d) Location Data (at country, state, city, or postal code level) (e) Technical Data (f) Extended Data (g) Any other information we are compelled to provide by law or by terms of use of the respective organization. | Necessary to comply with our legal obligations |
DATA DELETION REQUESTS
You may request deletion of your account and associated personal data in accordance with applicable law.
HOW TO MAKE CHANGES IN YOUR PROFILE
You can delete your account directly from your
Profile page by using the Delete My Account option available in your account settings.