Privacy Policy
1. General Provisions
1.1. This Privacy Policy (hereinafter referred to as the Policy) has been developed in accordance with the provisions of the Electronic Commerce Law, Federal Decree Law № 45 of 2021 of the Protection of Personal Data of the United Arab Emirates (PDPL), (hereinafter referred to as the Personal Data Law) and other regulatory legal acts in the field of protection and processing of personal data operating in the United Arab Emirates.
1.2. The following terms are used in this Policy:
Findme Mobile Application (also the “Application”) is a mobile application available for download through the App Store and Google Play, in which this Policy is located;
Personal data operator – any action (operation) or set of actions (operations) with personal data performed with or without the use of automation tools. Processing of personal data includes, but is not limited to: collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction
Application Administration - employees authorized by the Company to manage the Application, who determine the composition of personal data of Application users, the purposes of collecting personal data, their processing and storage;
User account (also “Account”) – a personal account created by the user by registering in the Application
Content – materials posted on the Application, including, but not limited to, photos, videos, graphic materials, etc.
Application User - an individual, a user of the Application, a subject of personal data who voluntarily registered in the Application and provided the necessary personal data during registration;
Personal data – any information relating to a directly or indirectly identified or identifiable individual (subject of personal data);
Personal data authorized by the subject of personal data for distribution - personal data, access to which is provided by an unlimited number of persons by the subject of personal data by giving consent to the processing of personal data authorized by the subject of personal data for distribution in the manner prescribed by this Federal Law;
Processing of personal data – any action (operation) or set of actions (operations) performed using automation tools or without the use of such means with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data;
Automated processing of personal data – processing of personal data using computer technology;
1.3. This Privacy Policy (also the “Policy”) establishes the rules and conditions for the processing of personal data of Users of the Findme mobile application.
1.4. The Policy applies to relations between the Company and Users who are citizens of the Russian Federation or other CIS countries or who access the Application from the territory of the Russian Federation or CIS countries. This Policy applies to information that the Company collects during Users’ use of the Findme application, as well as during the Company’s execution of any agreements and contracts concluded with Users. This policy does not apply to other Applications or Sites and does not apply to Applications or Sites of third parties. The Administration of the Application is not responsible for Applications and Websites of third parties, which users can access via links available in the Application.
1.5. Creating an Account in the Application means the User's full agreement with all the terms of this Policy. In case of disagreement with the terms of the Policy, the User must refrain from using the Application. Consent to processing is given, including to automated, as well as processing of the User’s personal data carried out without the use of automation tools, namely: collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (provision, access), depersonalization, blocking, deletion, destruction.
2. Personal data collected by the Company
2.1. The categories of personal data processed by the Company depend on how the User interacts with the Application.
2.2. The functionality of the Application provides the User with the opportunity, in certain cases determined by the Company, to independently determine whether or not to indicate certain personal data. At the same time, the User must take into account that in the described cases, certain functionality of the Application may not be available to him due to his failure to provide certain personal data.
2.3. While using the Application, the Company may process data that includes information that the User has provided independently, as well as information collected automatically when using the Application.
2.4. Information provided by the User independently is necessary to create an Account and provide access to use the Application. Personal data provided by the User independently includes:
a) full name,
b) date of birth,
c) email address,
d) contact mobile phone number,
e) gender,
f) height,
g) weight,
h) information about the presence/absence of children,
i) information about education,
j) knowledge of foreign languages,
k) links to social media accounts,
l) preferences regarding alcohol and/or smoking and other habits.
The User also has the right to provide additional personal data to generate dating recommendations (compatibility with other Users) in the Application. The Administration of the Application can receive all personal data about users only from them themselves. Personal data of Application users is confidential information and cannot be used by the Administration of the Application or any other person for personal purposes.
2.5. Data that is transmitted automatically, depending on the software settings, includes data on:
a) Geolocation of the user’s device;
b) Device Information, which may include, but is not limited to, information about the computer and/or mobile device you use to access the Application, including hardware model, operating system and version, web browser used and other device identifiers;
c) Server log data, which may, among other things, include the User’s registration data, date and time of visits, pages/profiles viewed, date and time of use of the Application functionality, date and time of visit to the personal messages section, User’s IP address, time, carried out in the Application;
d) Information collected through tracking technologies. We and our service providers use a variety of technologies to collect information when a user interacts with the Application, including cookies and web beacons.
2.6. Cookies are data files that are stored on the User's device while using the Application, allowing the Company to collect information about the User's device identifiers, IP address, web browsers used to access the Application, pages or functions viewed, time spent on pages , application performance and the links the User clicks.
2.7. Web beacons are graphic images placed on a website or in an email that are used to monitor the behavior of a User visiting a website or sending an email. Web beacons may be used in combination with cookies. The Company's policy regarding cookies is specified in the Cookies Policy.
2.8. Users may provide information about other Users when using the Application, for example when filing a complaint.
2.9. The user can share personal data with the Company through his social network account.
2.10. If the User uses links to visit other websites, services, chat rooms or the Application, this Policy will not apply to use and activity on such websites. The user should review the privacy policies of other websites as the Company does not control them and is not responsible for any information provided or collected by such websites.
2.11. Personal data specified in the policy is collected only with the voluntary consent of the User and is processed solely to achieve the purposes clearly defined in this Policy.
3. Purposes of processing personal data of Users
3.1. The main purpose of collecting information about users is to provide the opportunity to use the Application and improve its quality.
3.2. Within the framework of the above purpose, the Company may process personal data itself and by third parties, including in order to:
a) Provide access to the application in accordance with the user agreement, including for creating and managing an account, selecting compatible profiles;
b) Improve the operation of the application, including improving the system for selecting compatible profiles, the quality of the support service, improving the existing functionality of the application, adding new ones;
c) Develop new Company Applications independently and by legal entities affiliated with the Company;
d) Provide personalized selections on the Application;
e) Conduct research and development to improve the functionality of the Application;
f) Conduct statistical and other research based on aggregated data sets;
g) Fulfill User requests, provide technical support to the User;
h) Communicate with the User, including sending notifications, requests and information regarding the use of the Application, fulfill agreements and contracts;
i) Identify and prevent violations of the User Agreement and this Policy, for example, by studying complaints received from Users, studying and developing measures to counter violation of the User Agreement and this Policy, analyzing and accumulating information about cases of violation of the User Agreement and this Policy;
j) Conduct marketing research, including optimizing the effectiveness of advertising campaigns: analyzing user data to improve targeting, optimize conversions and increase the effectiveness of advertising campaigns
k) Process personal data of users in accordance with current legislation on the protection of personal data
l) Ensure compliance with legislative and other regulatory legal acts of the United Arab Emirates, local regulations of the organization
3.3. The Administration of the Application provides users with free, free access to their personal data, including the right to receive copies of any record containing their personal data, except as required by law.
3.4. In order to fulfill the obligations provided for by the law of the United Arab Emirates on personal data, the Administration of the Application is taking the following measures: - saving personal data; - application of legal, organizational and technical measures to ensure the security of personal data; - implementation of internal control of compliance of the processing of personal data with the requirements of the law of the United Arab Emirates.
4. Processing, storage and transfer of personal data of users
4.1. The processing of personal data of Application users is carried out exclusively for the purposes specified in clause 3.1. and 3.2. of this Policy.
4.2. The processing of personal data in the Application is carried out both using automation tools and without the use of such tools.
4.3. Personal data of Application users is stored electronically in the personal data information system of the Application, as well as in archived copies of the Application databases.
4.4. The Company stores personal information of users in accordance with the applicable laws of the United Arab Emirates, this policy and the internal regulations of the Company.
4.5. Only employees of the Application Administration who are authorized to work with the personal data of Application users and who have signed a non-disclosure agreement regarding the personal data of Application users may have access to the processing of personal data of Application users.
4.6. The user's personal data is processed by the Company throughout the entire period of use by the user of the application and/or the validity of agreements and contracts with the user, taking into account the requirements of the applicable law of the United Arab Emirates.
4.7. The Administration of the Application may transfer personal data of Application users to third parties only if this is necessary for the purposes specified in clause 3.1. and 3.2.. of this Policy to authorized persons, while the Administration of the Application is obliged to enter into a confidentiality agreement with third parties, in which it is indicated that third parties have obligations to the Contractor and the Customer to maintain the confidentiality of the specified personal data and comply with other requirements for the protection of personal data provided for current laws of the United Arab Emirates.
4.8. The Administration of the Application provides personal data of users only to authorized persons and only to the extent necessary for them to perform their job duties, in accordance with this Policy and the laws of the United Arab Emirates.
4.9. The transfer of personal data to a government body, local government body, security and law enforcement agency, as well as other authorized body is permitted on the grounds provided for by the laws of the United Arab Emirates.
4.10. The transfer (provision, access) of personal data authorized by the user of the Application for distribution must be stopped at any time upon his request. The personal data specified in this requirement can only be processed by the Administration of the Application.
4.11. In order to improve the quality of service and ensure the possibility of legal protection, the Administration of the Application has the right to store log files about the actions performed by users while using the Application.
5. Transfer of personal data of Users to third parties
5.1. In some cases, in order to develop the Application, optimize its operation and offer new functionality of the Application, the Company and its affiliates have the right to transfer some personal data of Users to partners, service providers and/or other third parties.
5.2. The Company guarantees that in order to ensure the confidentiality of personal data and the security of their processing, this transfer will be carried out exclusively in compliance with all requirements of the applicable law of the United Arab Emirates.
5.3. The Company may transfer personal data to third parties (including partners, service providers, persons affiliated with the Company, etc.) located in other states, subject to the conditions specified in Federal Law No. 45 of 2021 on Personal Data Protection (PDPL). Prior to such transfer, the Company will always obtain confirmation that such countries provide adequate protection of personal data, and, thus, personal data will be protected no less reliably than it is provided in the United Arab Emirates. 5.4. In case of transfer of the user's personal data outside the United Arab Emirates, the Company ensures its legality, including, but not limited to, the existence of statutory grounds for such transfer and compliance with other requirements of applicable law. 5.5. The company has the right to partially share personal data with third parties if:
a) The Company has received written consent from the User for such actions;
b) The transfer is necessary for the performance of a specific agreement or contract to which the user is a party, including for the user's use of the application;
c) The transfer is subject to the laws of the United Arab Emirates;
d) Protection of life, health, and other vital interests of the subject of personal data or other persons if it is impossible to obtain consent in writing from the subject of personal data
e) In order to ensure the possibility of protecting the rights and legitimate interests of the Company or third parties, for example, in cases where the user violates the User Agreement of the application, this policy or other assumed obligations.
6. Requirements for premises where personal data is processed
6.1. The placement of equipment for personal data information systems, special equipment and the security of premises in which work with personal data is carried out, the organization of a security regime in these premises must ensure the safety of personal data carriers and information security means, and also exclude the possibility of uncontrolled entry or stay in these premises strangers.
6.2. Premises in which technical means of personal data information systems are located or personal data storage media are stored must comply with fire safety requirements established by the current laws of the United Arab Emirates.
6.3. The level of special equipment in the premises is determined by a specially created commission. Based on the results of determining the class and examining the premises to determine its compliance with this class, acts are drawn up.
6.4. In addition to the specified measures for special equipment and security of premises in which cryptographic means of information protection are installed or stored, additional requirements are implemented, determined by the methodological documents of the Federal Security Service of the United Arab Emirates.
7. Rights and obligations of the Company
7.1. The Company has the right to establish requirements for the composition of personal data of users, which must be provided to use the Application, while the Application Company is guided by this policy and the current laws of the United Arab Emirates.
7.2. The Application Company does not verify the accuracy of the personal data provided by Application users, believing that they act in good faith and keep information about their personal data up to date, and is not able to assess the legal capacity of Users. At the same time, the Application Company assumes that the User provides reliable and sufficient information and keeps this information up to date. The consequences of providing false or insufficient information are defined in the User Agreement.
7.3. The Company does not collect any payment information. The security of user payment data is ensured by the Company’s partners – payment services specified in the Application, Apple, Google. The User can familiarize himself with the terms of data processing on the official resources of these organizations.
7.4. The Company is not responsible for the voluntary transfer by Application users of their contact information, password or login to third parties.
7.5. The Company takes measures necessary and sufficient to ensure compliance with the obligations provided for by the laws of the United Arab Emirates on personal data and regulations adopted in accordance with it. The company independently determines the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations provided for by the Law on Personal Data and the regulatory legal acts adopted in accordance with it.
7.5.1. Such measures, in particular, include: - appointment of a person responsible for organizing the processing of personal data; - publication of documents defining the Annex’s policy regarding the processing of personal data, local acts on the processing of personal data, defining for each purpose of processing personal data the categories and list of processed personal data, categories of subjects whose personal data is processed, methods, terms of their processing and storage , the procedure for the destruction of personal data upon achieving the purposes of their processing or upon the occurrence of other legal grounds, as well as local acts establishing procedures aimed at preventing and identifying violations of the laws of the United Arab Emirates, eliminating the consequences of such violations. Such documents and local acts cannot contain provisions that limit the rights of users of the Application, as well as imposing on the administration of the Application powers and duties not provided for by the laws of the United Arab Emirates; - application of legal, organizational and technical measures to ensure the security of personal data; - implementation of internal control and (or) audit of compliance of the processing of personal data with the Law on Personal Data and regulations adopted in accordance with it, requirements for the protection of personal data, the Application policy regarding the processing of personal data, local acts of the Application; - assessment of the harm that may be caused to users of the Application in the event of a violation of the Law on Personal Data, the relationship between this harm and the measures taken by the Administration of the Application aimed at ensuring the fulfillment of the obligations provided for by the Law on Personal Data; - familiarization of the Company’s employees directly involved in the processing of personal data with the provisions of the laws of the United Arab Emirates on personal data, including requirements for the protection of personal data, documents defining the Application’s policy regarding the processing of personal data, local regulations on the processing of personal data, and (or) training of these employees.
7.6. Within the framework of applicable law, the Company has the right to receive from third parties information about suspected or confirmed cases of violation by individual users of the User Agreement, Policy or applicable law to ensure the safety of Users.
7.7. The Company takes necessary and sufficient organizational and technical measures to protect the User’s personal data from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other unlawful actions of third parties.
8. Rights of Application Users to protect their personal data
8.1. Users of the Application, in order to ensure the protection of their personal data stored in the Application, have the right to:
a) receive complete information about your personal data, their processing, storage and transmission;
b) determine their representatives to protect their personal data;
c) request the exclusion or correction of incorrect or incomplete personal data, as well as data processed in violation of this policy and the laws of the United Arab Emirates. If the Application Administration refuses to exclude or correct the personal data of Application users, users have the right to notify the Application Administration in writing of their disagreement with the appropriate justification.
8.2. If the Application user believes that the processing of his personal data is carried out in violation of the requirements of the legislation on personal data or otherwise violates their rights and freedoms, he has the right to withdraw his personal data and is obliged to stop using the Application.
9. Procedure for destruction and blocking of personal data
9.1. If unlawful processing of personal data is detected when an Application User applies, the Company blocks unlawfully processed personal data related to this user from the moment of such application for the period of verification.
9.2. If inaccurate personal data is identified when a user of the Application applies, the Administration of the Application blocks personal data related to this user from the moment of such application for the period of verification.
9.3. If it is confirmed that personal data is inaccurate, the Administration of the Application, based on the information provided by the user of the Application or other necessary documents, clarifies the personal data and makes a decision based on the updated data.
9.4. If the purpose of processing personal data is achieved, the Administration of the Application stops processing personal data and takes measures to destroy personal data within a period not exceeding 10 business days from the date the purpose of processing personal data is achieved.
9.5. If the user of the Application withdraws consent to the processing of his personal data, the administration of the Application stops processing it and, if the storage of personal data is no longer required for the purposes of processing personal data, destroys the personal data within a period not exceeding 10 business days from the date of receipt of the said revocation. In this case, the User Account is destroyed within the same period.
9.6. Documents containing personal data of the Application user and subject to electronic destruction are erased from information media or the media themselves on which the information is stored are physically destroyed.
9.7. The User can view, update or delete any personal information specified in the Account at any time. To do this, he can edit the information in his Account online or send an email to the address specified in the Application if he exceeds the limit established by the Company for independently changing or deleting data.
9.8. The user's rights provided for in this policy may be limited in accordance with legal requirements. In particular, such restrictions may provide for the Company’s obligation to retain information changed or deleted by the user for a period established by law, and to transfer such information in accordance with the legally established procedure to a government agency.
10. Responsibility for violation of the rules governing the processing and protection of personal data of users
10.1. Persons guilty of violating the rules governing the receipt, processing and protection of personal data of Application users are subject to disciplinary, material, civil, administrative and criminal liability in the manner prescribed by the current laws of the United Arab Emirates.
11. Changes to the privacy policy
11.1. This policy may be changed or terminated by the Application Administration unilaterally without prior notice to the Application user.
11.2. The new version of the policy comes into force from the moment it is posted in the Application, unless otherwise provided by the new version of the policy.
11.3. The Application user independently monitors changes to this policy and, if he disagrees with it in whole or in some part, is obliged to immediately stop working with the Application and send a request for the destruction of his personal data to the Administration of the Application.
12. Applicable law and feedback
12.1. The laws of the United Arab Emirates shall apply to this Policy and the relationship between the user and the Company arising in connection with the application of the Policy.
12.2. The user has the right to send all requests and notifications regarding the processing of personal data and/or any related issues by email specified in the Application
