Meetty Privacy Policy

Who we are

MEETTY - FZCO, a free zone company limited by guarantee, established and existing under the laws of the International Free Zone Authority, Dubai, United Arab Emirates, registration number DSO-FZCO-23973 ("we"), provide the MEETTY service (MEETTY mobile apps) (hereinafter referred to as MEETTY, App, Service).

This Policy describes what personal information and data ("Data") of a user of the Service ("you") we collect, use, process and store ("Process"), for what purposes and how we process your Data, what rights you have in relation to such Data Processing and how you can contact us about any matter relating to the Processing of your Data.

While you use the MEETTY mobile App or use our digital products and services available on it, we collect certain information about you. You may also use the App to share information with other users, including your friends and acquaintances ("Users"). We may also need to share your information on occasion.

In order for us to provide our services to you and for you to use our App and its features, all information you provide will be sent to Germany where our servers are located and where your information will be stored, and your information will also be used by us in the UAE where we are located, regardless of your country of residence. This Policy explains how we protect your personal data when it is transferred abroad, so please read it very carefully!

If you do not agree with anything described in this Policy, please do not start (or immediately stop) using MEETTY. As MEETTY evolves, we may revise this Privacy Policy from time to time. The most current version of the Policy will govern our use of your information and will always be available at meetty.com/terms-of-use.

If we make changes to this Policy that we believe to be material, we will notify you, for example, by email if it is linked to your Account, or by posting a notice on MEETTY. Please ensure that you agree to the updated Policy when attempting to use the App.

1. INFORMATION GATHERING

Registration information

When you download the App and create an account ("Account", "Account"), we may collect certain information about you ("Registration Information"), such as, but not limited to:

• First and Last Name;
• E-mail address (if the User specifies it);
• Cell phone number;
• Gender Identity;
• Date of Birth;
• Interests;
• Preferences (including sexual preferences, if deemed necessary) for choosing partners (e.g., age, hobbies, hair/eye color, etc.);
• Photos;
• Location; 
• Login data for the social media accounts that you have linked to your MEETTY account (e.g. your Facebook, TikTok accounts). For more information, see "Linking other accounts to MEETTY" in section 7 below; 
• Biotmetric information; 
• Other information about you that you deem appropriate in the "About Me" section.

Once registered, you will be able to view and change this information at any time by simply logging into MEETTY (except for location (which, if you have granted MEETTY access to your location in your device settings, is automatically updated based on your device's location)). It is your responsibility to ensure that your account information is up to date. If your phone number has changed, please make sure you update it in your account.

The information we collect helps us improve the application and review our users to maintain high quality standards for our Service and to comply with applicable laws and regulations. Registration information may be visible to other users who view your Account page. If you do not intend to share any information about yourself other than the information that is required to be able to use MEETTY, please do not do so.

For users residing in California, the data we may collect falls under the following categories of "personal information" as defined in the California Consumer Privacy Act (CCPA):

• A. Identifiers such as name and location;
• B. Personal information as defined in California's customer records law, such as contact (including email and phone number) and financial information;
• C. Characteristics of protected classifications under California or federal law (if you choose to provide them), such as age, gender identity, marital status, sexual orientation, race, ancestry, national origin, religion, and medical conditions;
• D. Commercial information such as transaction information and purchase history;
• E. Biometric information;
• F. Information about online or offline activity, such as browsing history and interactions with our Sites and App;
• G. Geolocation data, such as the location of the mobile device;
• H. Audio, electronic, visual and similar information such as photographs and videos;
• I. Professional or job-related information, such as work history and previous employer;
• J. Nonpublic education information; and
• K. Inferences drawn from any of the personal information listed above to create a profile or resume, such as an individual's preferences and characteristics.

User Information

We recommend and encourage you (and all of our users) to be careful about the information you share about yourself. We also discourage you from posting email addresses, URLs, instant messaging information, phone numbers, full names or addresses, credit card information, national identification numbers, driver's license information, and other sensitive information that could be subject to misuse and abuse.

When you post information about yourself or use the messaging feature to communicate with other users, the amount of personal information you provide is at your own risk. For more information about who can access the information you post on MEETTY, see section 4 below.

Information for profile verification (including biometric data)

For security purposes and to ensure the best user experience, we require users to verify their accounts and may ask for your phone number (if you register using your cell phone number) and ask you to be photo verified (using Regula's dedicated photo verification service) when uploading your photos. For more information about the software we use for photo verification purposes, please visit https://regulaforensics.com/solutions/use-cases/kyc-automation/.

We want to make sure that you are not a robot and are not using someone else's photos, thus misleading other users. We also want to avoid creating untrustworthy MEETTY accounts, scamming and misleading other MEETTY users about your identity, and fake accounts that can be used for malicious activities and cybercrime - they threaten MEETTY and ruin life for everyone. We may need this verification to prevent fraud. 

In order to validate profile photos, we may scan an individual and/or each photo you submit. Scanning includes the use of facial recognition technology (in our case Regula) so that we can compare the photo you provide with your profile photo to ensure that you are who you say you are. We do not add verification photos to your Account. We retain the photos so that we can verify you in the future and for record keeping purposes until we no longer need them for that purpose or for three years after your last interaction with us, whichever occurs first. Once the appropriate retention period has expired, we will take commercially reasonable steps to permanently and securely delete the scans from our systems.

Purchasing information

If you choose to purchase any of our services, your payment information will be processed and stored securely for fraud prevention and for audit/tax purposes by the payment processor through which you make your purchase, i.e. Apple Pay or Google Pay.

Geolocation information

If you have granted MEETTY access to your location in your device settings, when you use your cell phone, we will collect WiFi hotspot information and other longitude and latitude information about your location and may store the coordinates of your device to offer you certain features. This information helps us determine your physical location, and we use it to personalize the App and facilitate your interaction with other users by allowing us to display general location information to users who see your profile and by showing you profiles of other users who are near you.

If you have granted MEETTY access to your location but want to disable it, you can do so in the following ways:

1. iPhone app - settings, privacy, location services, MEETTY
2. Android - settings, location, MEETTY, permissions, location

Device information and photos

We may collect information about your device when you use the App, including unique device identifier, device model and operating system, for a number of purposes as set forth in this Policy. 

Information about your use of the Application

We collect information about your use of the Application. Information about your current use of the Application is also available to other users in the form of an indicator of your MEETTY profile (online/offline).

References

We may track how you interact with links available on MEETTY, including third-party services, redirect clicks or other means. We may share aggregate click statistics, such as how many times a particular link was clicked.

MEETTY success stories, surveys and other materials

From time to time we conduct surveys for research purposes and may contact you to see if you would like to participate. We may also contact you to see if you would like to leave feedback, make a recommendation or participate in marketing campaigns (for example, if you tell us that you have found a couple on the App, we may contact you to ask if you would like to be featured in a MEETTY advertisement). Such surveys and marketing campaigns are optional and further information will be provided at the time of contact. If you do not wish to be contacted to participate in a survey or marketing campaign, please contact our support team at help@meetty.com .

When you contact customer service

If you contact our support team via email at help@meetty.com , we will receive your email address and may track your IP address and the information you send us to help resolve your issue. We may keep a record of our communications with you, including any complaints received from you about other users (and from other users about you), for 6 years after your account is deleted.

Cookies and similar technologies

When you visit our App or use our App, we may collect your personal information automatically by using cookies or similar technologies. A cookie is a small file that may be placed on your device or browser that allows us to recognize and remember you.

You can customize the categories of cookies that you allow to be used on the Service. These categories may include:

- necessary Cookies, which are necessary to access certain web pages and are required for the proper operation of the Service;

- functional Cookies that allow the Service to identify and facilitate the use of your account because such Cookies help remember the information you have provided or the choices you have made on the Service;

Performance Cookies collect aggregate information about the use of the Service, and disabling them will not materially affect your use of the Service;

Tracking cookies that allow us to receive information about your activities on the website (e.g. Google Analytics) or for marketing/advertising (pixel or otherwise).

You can also disable cookies in your browser or related add-ons, delete them, or block some or all cookies.

For more information about how we use cookies and other tracking technologies, including how you can set and manage your preferences for such technologies, please see our Cookie Policy.

2. USE OF YOUR INFORMATION

Our primary goal is to make your experience with MEETTY a pleasant and rewarding one! For these purposes, we may use your registration and other information to:

• offer you our services and features;
• provide you with information about the Application (such as updates and new features);
• Personalize the app/sites and content we provide to you;
• Conduct research and analytics on how you use and interact with the Application/sites;
• to test new technologies and processes to improve and enhance the Application/sites;
• resolve disputes, troubleshoot problems and enforce our Terms and Conditions;
• investigate fraud, protect our legal rights and enforce our terms and conditions.
• send you information about promotions and offers we have available to you (e.g. to indicate the types of products/services/offers to be provided through direct marketing) via direct marketing or other communication methods - if you have subscribed to our communications or otherwise let us know that this is OK. We will not use your information in direct marketing emails unless you give us your consent during the account creation process or through Settings in the app (you may opt-out of marketing at any time through Settings in the app or through the opt-out mechanisms and links provided in each communication); and
• Protect our Users and third parties from harm.

Our selection algorithms

We have matching algorithms to predict your compatibility with other users and show you people we think are a good match for you. Our matching algorithms use the following data about you to predict your compatibility with other people and create profile recommendations: what you tell us about yourself in your profile, including standardized answers to questions offered on the App; information about your activity on our App; and your device coordinates, which are necessary to understand your proximity to other users. The legal basis for processing profile and proximity information is that this is necessary to provide our contractual services to you in accordance with Article 6(1)(b) GDPR. If we process information about your in-app activity, we do so on the basis of our legitimate interests under Article 6(1)(f) GDPR, namely our legitimate interest in creating more personalized and relevant recommendations about who you can date on our app. If you choose to include sensitive information in your profile, such as information about your beliefs, the processing of this information is based on your voluntary and explicit consent.

In addition to, but not limited to, the matching algorithms, we offer you (if you are interested, of course), at certain stages and conditions of your use of the Application, numerology compatibility algorithms for predicting your compatibility with other users, as well as for use by other users with respect to you, including the percentage of compatibility of users with each other, as well as a description of compatibility according to the principles and algorithms of numerology, depending on the date of birth and gender. 

Moderation practices

We use a combination of automated systems and a team of moderators to monitor and review accounts (including photos and any other information uploaded to user profiles) and messages for content indicating a violation of our MEETTY Terms of Use as set forth in our legal documents. If an account or message meets certain criteria indicating a likely violation of the Terms of Use, the account in question will be issued a warning and the user's access will be restricted and/or blocked. Affected users may contact MEETTY to contest the decision.

If you post information that contravenes our terms of use, we reserve the right to terminate or restrict access to your account at any stage of use.

Legal basis

Under EU and UK data protection laws, we are required to inform you of the lawful basis for using your data and we have set out these in the table below. If the lawful basis is consent, you can withdraw it at any time. If the lawful basis is legitimate interests, you have the right to object to our use of your data. We explain in the relevant sections of this Policy how you can withdraw consent or opt out of the use of certain data (if applicable).

3. DISCLOSURE OF INFORMATION

We do not disclose your registration information or personal information except in the limited circumstances described herein:

Aggregated Information - We may share aggregated information that includes your personal information (but does not directly identify you) along with other information, including log data, with third parties for industry analysis and demographic profiling.

ADDITIONAL DISCLOSURE INFORMATION

Service providers

We engage certain trusted third parties to perform functions and provide services ("Service Providers"). The Providers with whom MEETTY shares Users' personal data depends on various factors, such as which of MEETTY's features a User uses. For example, we typically use the following providers to provide services to Users:

• Billing Services - to allow customers to purchase paid features of our app (e.g. from Google Play).
• Authentication services - allow customers to authenticate their account (e.g. Google, Facebook, TikTok).
• Social media providers - so that users can create/connect their MEETTY account to their accounts on such platforms (e.g. Facebook, Instagram, Google, TikTok).
• IT services - some third-party software providers used in our operations may process personal user data (e.g., the Regula photo verification service).

We endeavor to carefully select the service providers we engage to ensure that they have adequate data protection and information security measures in place, and only provide them with personal data that is necessary to provide the services. 

Marketing service providers

We partner with marketing service providers (such as, but not limited to, Facebook) ("Marketing Service Providers") to help us promote and advertise our application and services on third-party websites and applications and to measure the effectiveness of our advertising campaigns. For example:

• exclude you from advertising campaigns aimed at finding new users if you already have a MEETTY account;
• show MEETTY ads to users who have visited the MEETTY app but have not yet created a MEETTY account;
• to create an audience for our advertisements from other potential users who have similar characteristics to you based on information about you available to the Marketing Service Providers (also known as Lookalike Audience); or
• include you in the "custom audience" that will receive MEETTY's advertising content (a custom audience is essentially a list of people who we believe are most likely to be interested in a particular advertisement).

We share a limited amount of your personal information with these marketing service providers, such as:

• An advertising identifier associated with your device (this is a random number assigned by your mobile device manufacturer (e.g., Apple or Google) to your device to help advertisers (including the manufacturer) know when an ad has been viewed or clicked in an app, and when the ad causes a "conversion" (e.g., downloading the advertised app))
• your approximate location (based on your IP address)
• age and gender
• Data about your visits to and actions taken on our websites or apps (for example, if you download our app, create an account on our app, or data about any purchases made on the website or app)
• hashed* version of your email address (to create "custom audiences").

*Hashing is a way of encrypting information into a combination of random numbers and letters - this code cannot be traced back to an email address. When hashed email addresses are sent to a marketing vendor, they are matched against their existing list of hashed user information, and our ads are served to those of our users who have been successfully matched to the vendor's data. Matched and mismatched hashes are then deleted by the provider.

In some cases, these third parties will use the data they collect for their own purposes, for example, they may combine your data with other data they have and use it to inform you about promotional services provided to other customers.

Facebook

If we transfer data to Facebook as a marketing service provider (including via the "Like" function), we are joint data controllers with Facebook Ireland for this processing. This means that MEETTY - FZCO is obliged to provide you with this notice, but you should contact Facebook if you wish to exercise your data protection rights. Further information, including how Facebook allows you to exercise your data protection rights and subsequently processes your information as an independent data controller, can be found in the Facebook Ireland Data Processing Policy. 

This data mentioned above may include actions you take on our App, such as your interactions with our App, or other information collected through cookies or similar technologies, including the Facebook pixel. This allows us to measure the effectiveness of our advertising, improve our marketing techniques and helps us deliver more relevant advertising to you and people like you (including on social media platforms such as Facebook).

4. WHAT OTHERS CAN SEE ABOUT YOU

Our app is designed to make it easier for you to meet and connect with other users and interact with them.

When using the MEETTY app, you should understand that anything you post or submit on the app may be available for public viewing by other users of the app. We want our users to be cautious about posting information that may eventually become public.

Please be careful when posting sensitive information about yourself in your profile, such as your religious affiliation and health information. You may also add sensitive information about yourself when you add answers to questions in the Application to your profile, such as your religion and political affiliations. While you may voluntarily provide us with this information when you create your profile, including your sexual preferences, it is not required that you do so. Remember that the photos you post on MEETTY may also contain information about you. If you upload photos and choose to give us confidential information about yourself, including by adding answers to questions and/or providing other information about yourself to your profile, you expressly consent to us processing that information and making it publicly available to other users.

Your MEETTY profile and other information you provide through the App, including certain information added to your profile through third party accounts (such as Facebook, Instagram or TikTok - see Section 7 of this Privacy Policy for more information on this), may be viewed and shared by Users with individuals who may or may not be users of the App. For example, a User may recommend you as a suitable match to their Facebook friend(s) by taking a screenshot of your profile picture and sharing it, regardless of whether such friend(s) is a MEETTY User.

Please note that in some countries (currently South Korea only) Users are provided with a feature that allows them to download a copy of their call history (in accordance with local laws), and MEETTY has no control over how Users may publish or use this information.

If you log into or access the App through a Facebook account or other third-party account on a device that you share with others, remember to log out of the App and the applicable third-party account when you leave your device so that other users cannot access your MEETTY account.

5. OUR AGE POLICY

While we want as many people as possible to enjoy our creations, you must be at least 18 years of age to use MEETTY, so creating an account with MEETTY for anyone under 18 is restricted by us to the methods available to us.

MEETTY does not knowingly collect information about children, minors or persons under the age of 18. If we become aware that a child, minor or person under the age of 18 has registered with us and provided us with personal information, we will take steps to terminate that person's registration.

6. SAFETY

We take all necessary security measures to protect your information from loss, misuse, unauthorized access or disclosure. We use reasonable security measures to ensure the privacy of your personal information.

Unfortunately, no website or data transmission over the Internet can be completely 100% secure, and even we can't guarantee that unauthorized access, hacking, data loss, or other breaches will never happen, but here are some helpful tips to keep your data safe:

1. Please log out of your account after use, because you never know who might stumble upon your account!
2. Please do not share your password, if you use the password to access your MEETTY account, with anyone else!
3. Change your password periodically if you use a password to access MEETTY.

If you believe someone has gained access to your password or Account, please let us know as soon as possible.

7. LINKING OTHER ACCOUNTS TO MEETTY

Using your social media data to log in to MEETTY

When you log into our application using your account on third-party social media and/or services such as Facebook, TikTok, and others available at the time of your login and used by you to log into MEETTY (a "Third Party Service"), you authorize, unless you opt out, the applicable Third Party Service to share your name, date of birth, city of residence, email address, and photos with us (if we provide a photo upload feature from a particular Third Party Service, and you upload photos from such Third Party Service to us). 

If you register or log in with your Apple ID or Google ID, you give Apple and Google permission to share your Apple/Google login, name and email address. This email address will be associated with your MEETTY account and will be used to access your MEETTY account.

We will then use this personal data to create your MEETTY account. If you delete the MEETTY app from your Facebook or other Third Party Services settings, or from your Apple ID/Google ID, we will no longer have access to this data. However, we will still have the personal data that we received when you first created your MEETTY account using your Facebook or other Third Party Service, Apple ID/Google ID (you must completely delete your MEETTY account for us to no longer have access to this data).

Linking social media accounts to your MEETTY account

You can link your MEETTY account to your Instagram, Facebook or TikTok accounts. This will allow you to share some information from these accounts directly with your MEETTY account (e.g. photos from Instagram).

We only receive the limited information that Instagram/Facebook/TikTok are authorized to share (as specified by Instagram/Facebook/TikTok and agreed to by you when you first connect your account on these platforms with your MEETTY account).

If you no longer want to link your MEETTY account to your Instagram/Facebook/TikTok account, go to your Instagram/Facebook/TikTok account settings and follow the instructions to remove permissions to access the MEETTY app. Please note that any information already added to your MEETTY account from these platforms will not be removed unless you remove it in your MEETTY account as well.

8. YOUR PRIVACY RIGHTS IN CALIFORNIA

Users who reside in California have the following rights (in addition to those listed in Section 10 below) under the California Consumer Privacy Act, and the right not to be unlawfully discriminated against for exercising their rights under that Act:

1. You have the right to request that we disclose certain information to you and explain how we have collected, used and shared your personal data in the last 12 months.
2. You have the right to request that we delete your personal information we have collected from you, subject to certain exceptions.

California's "Shine the Light" law, Civil Code section 1798.83, requires certain companies to respond to inquiries from California customers about how the company discloses personal information to third parties for direct marketing purposes. If you would like to learn about the rights you may have under California Civil Code Section 1798.83, you can email us at help@meetty.com.

From time to time, as part of a joint promotion with a third party, we may, if you participate in such a promotion, disclose your contact information to the third party so that they can promote their products or services to you. If this is a condition of participating in a promotion, we will always let you know before you take part in the promotion. Please follow the instructions provided to you by third parties to unsubscribe from their communications.

In addition, under California law, operators of online services are required to disclose how they respond to "do not track" signals or other similar mechanisms that provide consumers with choices regarding the collection of a consumer's personal information over time and through third-party online services, to the extent that the operator engages in such collection. We do not currently track our Users' personal information over time or on third-party online services. This law also requires operators of online services to disclose whether third parties may collect personal information about their Users' online activities over time and across different online services when Users use the operator's services. We do not knowingly permit third parties to collect personal information about an individual User's online activities over time and across various online services when using the Application.

9. YOUR RIGHTS

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

1. Right to be informed: what personal data the organization processes and why (we provide you with this information in this Privacy Policy).
2. Right of access: you can request a copy of your data.
3. Right of rectification: if the available data is inaccurate, you have the right to have it corrected.
4. Right to erasure: in certain circumstances you have the right to have your data erased.
5. Right to restrict processing: in limited circumstances, you have the right to request that processing ceases but to retain the data.
6. Data portability right: you can request a copy of certain data in a machine-readable form that can be transferred to another vendor.
7. Right to object: in certain circumstances (including where data is processed on the basis of legitimate interests or for marketing purposes) you may object to such processing.
8. Rights related to automated decision-making, including profiling: there are several rights in this area where processing carried out solely on an automated basis results in a decision that has legal or significant human consequences. In these circumstances, your rights include the right to ensure human intervention in the decision-making process.

The specific rights applicable to you (which may include other rights not listed above) may vary depending on your country. You should familiarize yourself with the rights you have under your country's privacy laws.

If you wish to exercise any of the rights listed above, please email us at help@meetty.com . You may also contact us by mail at the following address: Techno Hub 1, C-01, Silicon Oasis, Dubai, United Arab Emirates. For your protection and the protection of all our Users, we may need to request specific information from you to help us confirm your identity before we can respond to the above requests.

10. DATA LOCATION

We want you to be able to access MEETTY wherever you are. For data storage, we use servers located in Germany. The equipment is located in third-party data centers. Data collected by advertising partners and other service providers may also be stored outside the UK and the European Economic Area. We take steps to ensure adequate data protection by ensuring that robust contractual standards are implemented. If you would like more information about the nature of the protections we put in place, please email help@meetty.com .

11. DATA STORAGE AND DELETION

We only retain your personal information for as long as we need it for the legal basis (as set out in Section 2 above) and in accordance with applicable law. To learn about our biometric information retention policy, see "Profile Verification Information (including biometric information)" in Section 1 above.

When your account is deleted, we make sure it is no longer visible in the app. For 28 days, it is still possible to recover your account if it was inadvertently deleted by sending us a request to help@meetty.com with "Account Recovery @username". After 28 days, we will begin the process of removing your personal information from our systems unless:

1. we must retain them in accordance with applicable law (for example, if you shop on the App, some personal data may be retained for tax and accounting purposes);
2. we must retain it to confirm compliance with applicable law (e.g., if an account is blocked, we retain some account information and a record of the behavior that led to the blocking - this information is retained for evidentiary purposes in the event of inquiries or legal action regarding the blocking);
3. there is an unresolved issue, claim or dispute that requires us to retain relevant information until it is resolved; or
4. Information must be retained for our legitimate business interests, such as preventing fraud and improving user safety (for example, information may be required for a user who has been banned from opening a new account for unsafe behavior or security incidents).

Note: Even after you delete information from your profile or delete your Account, copies of that information may continue to be available for viewing and/or access to the extent that such information was previously shared, copied or stored by others. We have no control over this and accept no responsibility for it. If you have given third-party applications or websites access to your personal information, they may retain such information to the extent permitted by their terms of service or privacy policy.