PRIVACY POLICY

I. PRIVACY POLICY

OUTLINING GENERAL DEFINITIONS OF DATA PROTECTION

This Privacy Policy describes how your personal information is collected, used, and shared when you visit or make a purchase from themillionmatches.com (the “Site”). This Privacy Policy is based on the the Data Protection Act (‘DPA’) from 1998 and is in accordance with with the General Data Protection Regulation (‘the GDPR’) from 2018.

Data protection law governs the „processing“ of „personal data“.

„Personal data“ is broadly defined to mean: „...data which relate to a living individual who can be identified

– (a) from those data, or (b) from those data and other information which is in the possession of, or isvlikely to come into the possession of, the data controller, and includes any expression of opinion about the individual and any indication of the intentions of the data controller or any other person in respect of the individual.

If you reside or are otherwise located outside of the United States, please note that the information and data we collect will be processed and stored in the United States. Data protection and privacy laws, rules, and regulations in the United States may differ from those in the jurisdiction in which you are located, and may not have the same level of protection as the laws, rules and regulations in the country or territory in which you reside or are located. Your use of the Platforms and the providing of information to us constitutes your consent to the transfer to and processing of your personal information in the United States unless otherwise stated within this Policy.

WHAT PERSONAL INFORMATION DO WE COLLECT?

We may collect the following information about you:

Your name, age/date of birth, gender and other relevant demographic information;
your contact details: postal address including billing and delivery addresses, telephone numbers (including mobile numbers) and email address;
your social media handles;
purchases and orders made by you;
your online browsing activities on any of our websites including which items you store in
your online browsing activities on any of our websites including which items you store in
your shopping cart;
information about the device you use to browse our websites including the IP address and device type;
your communication and marketing preferences;
your interests, preferences, feedback, competition and survey responses;
your location;
your correspondence and communications with us; and other publicly available personal data, including any which you have shared via a public platform (such as Instagram, YouTube, Twitter or public Facebook page).

This list is not exhaustive and in specific instances, we may need to collect additional data for the purposes set out in this Notice. Some personal data is collected directly, for example when you set up an online account on our website or send an email to our Customer Support team. Other personal data is collected indirectly, for example when you browse our websites or undertake online shopping activity. We may also collect personal data from third parties who have your consent to pass your details to us, or from publicly available sources. We may anonymise and aggregate personal data for insight and research but this will not identify anyone. Our websites are not intended for children and we do not knowingly collect data relating to children.

HOW DO WE USE YOUR PERSONAL INFORMATION?

1. General:

The Million Matches (and trusted partners acting on our behalf) use your personal data:

to provide goods and services to you;
to make a tailored website available to you;
to manage any account(s) you hold with us;
to verify your identity;
for crime and fraud prevention, detection and related purposes;
with your agreement, to contact you about promotional offers, events, products and services which we think may interest you;
to show you promotional communications through online media as you browse the web; for analysis, insight and research purposes - to better understand your needs and ensure we are giving you what you want;
to identify and contact competition winners;
to enable us to manage customer service interactions with you; and
where we have a legal right or duty to use or disclose your information (for example in relation to an investigation by a public authority or in a legal dispute).

2. Marketing:

a. Promotional communications:

To ensure you are kept up to date with the The Million Matches experience, we use personal data for marketing purposes and may send you postal mail, texts and/or emails to update you on the latest offers and events. We may also show you online media communications through external social media platforms such as Facebook and Instagram and external digital advertisers such as Google.

You have the right to opt out of receiving promotional communications at any time, by:

informing us that you wish to change your marketing preferences by contacting our customer support team at contact@themillionmatches making use of the simple “unsubscribe” link in emails or the “STOP” number for texts; and/or

This may not stop service messages such as order updates.

Personalisation and Automated Decision Making

If you visit any of our websites, you may receive personalised banner advertisements whilst browsing websites of other companies. Any banner advertisements you see will relate to your browsing activity on our website from your computer or other devices.

These advertisements are provided by us via external market leading specialist providers using techniques such as pixels, web beacons , ad tags, mobile identifiers and ‘cookies’ placed on your computer or other devices (see further information on the use of cookies in our Cookie Policy ). You can remove or disable cookies at any time - see Cookie Policy for further information.

We may collect data directly from you, as well as analysing your browsing and purchasing activity online and your responses to marketing communications. The results of this analysis, together with other demographic data, allow us to ensure that we contact you with information on products, services, events and offers that are tailored and relevant to you. To do so, we use software and other technology for automated decision making. We may do this to decide what marketing communications are suitable for you and this activity is based on our legitimate interests to develop and improve our products and services.

Also to provide more personalised services and experiences, we may review data held by external social media platform providers about you, for example, details on your Twitter or Facebook profiles that you have chosen to make publicly accessible such as your name, date of birth. Some of our services enable you to sign-in via external social media platform providers such as Facebook. If you choose to sign-in via a third party app, you will be presented with a dialog box which will ask your permission to allow us to access your personal information (e.g. your full name, date of birth, email address and any other information you have made accessible).

We aim to update you about products and services which are of interest and relevance to you as an individual. To help us do this, we process data by profiling and segmenting, identifying what our customers like and ensuring messages we send them are relevant based on their demographics, interests, purchase behaviour, online web browsing activity and engagement with previous communications. We may also use your data to exclude you from communications which we feel are irrelevant to you. For example, we may exclude someone from resends of marketing emails when we know that person has already opened the original email sent.

Another example of how we may tailor our communications with you is that we may group individuals with similar interests using this data so we can send them product news or promotional offers that are relevant to that shared interest.

You have the right to opt out of any automated processing, including profiling, at any time by informing us that you wish to opt out of automated processing by contacting our customer support team at contact@themillionmatches.com

SHARING YOUR PERSONAL INFORMATION

Our service providers and suppliers

In order to make certain services available to you and to help us better understand your preferences, we have partnered with certain trusted third parties including logistics and marketing service providers. We may need to share your personal information with some of our service partners. We only allow our service providers to handle your personal information when they have confirmed that they apply appropriate data protection and security controls. We also impose contractual obligations on service providers relating to data protection and security, which mean they can only use your information to provide services to us and to you, and for no other purposes. We may provide outside companies with aggregated and anonymised information and analytics about our customers but that would never identify you and we will never sell or rent your personal information to other organisations for any purposes.

For example, we use Shopify to power our online store--you can read more about how Shopify uses your Personal Information here: https://www.shopify.com/legal/privacy. We also use Google Analytics to help us understand how our customers use the Site -- you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.

Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

Other third parties:

We may also share your data with:

other companies within our group;
to purchasers, investors, funders and advisers if we sell our business or assets or restructure whether by merger, re-organisation or otherwise;
our legal and other professional advisers, including our auditors;
credit reference agencies where necessary for card payments;
to comply with our legal obligations and the administration of justice;
for the prevention, detection, investigation of crime or prosecution of offenders; and for the protection of our employees and customers.

BEHAVIOURAL ADVERTISING:

We may disclose personal information to third parties that provide advertising and marketing services on our behalf and on behalf of our service providers, to the extent appropriate. The Platforms also enable third-party tracking mechanisms to collect your non-personal information for use in online behavioral advertising. For example, third parties may use the fact that you visited the Platforms to target online ads for our services to you on websites or services not owned or controlled by us. In addition, our third-party advertising networks might use information about your use of the Platforms to help target advertisements based on your online behaviour in general. Please see our “Cookies Policy” for more information on this subject. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt out of targeted advertising by using the links below:

Facebook: https://www.facebook.com/settings/?tab=ads
Google: https://www.google.com/settings/ads/anonymous
Instagram: you can hide an ad you don't like by tapping (iOS) or (Android) on the top right
Twitter: https://help.twitter.com/en/safety-and-security/privacy-controls-for-tailored-ads

DO NOT TRACK

Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.

YOUR RIGHTS:

You have the following rights:

the right to be informed about our processing or your personal data which is the aim of this Notice;

the right to ask us to update and correct any out-of-date or incorrect personal data that we hold about you;

the right to object to processing of your personal data and/ or to withdraw any consent you have given us and to opt out of any marketing communications that we may send you;

the right to prevent processing that is likely to cause damage or distress to you or anyone else;

the certain rights in relation to automated decision making including profiling;

the right to request that we erase your personal data in certain circumstances (the right to be forgotten) for example when the data are no longer necessary for the purpose for which we collected them;

the right to have your personal data provided to you by us in a structured, commonly used and machine-readable format and transmitted to another data controller. This is known as the right to data portability.

If you wish to exercise any of the above rights, you can always contact us either by email to contact@themillionmatches.com

If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below.

Additionally, if you are a European resident we note that we are processing your information in order to fulfill contracts we might have with you (for example if you make an order through the Site), or otherwise to pursue our legitimate business interests listed above. Additionally, please note that your information will be transferred outside of Europe, including to Canada and the United States.

DATA RETENTION:

When you place an order through the Site, we will maintain your Order Information for our records unless and until you ask us to delete this information.

We will not retain your data for longer than necessary for the purposes set out in this Notice. Different retention periods apply for different types of information, and our Data Retention Policy sets out the length of time we will usually retain personal data and where these default periods might be changed.

In summary, various laws, accounting and regulatory requirements applicable to us require us to retain certain records for specific amounts of time. In relation to your personal data, we will hold this only for so long as we require that personal data for legal or regulatory reasons or for legitimate organisational purposes. We will not keep your data for longer than is necessary for the purposes for which we collect them.