Privacy Policy 2020-04-26

1. WELCOME

Last Updated on April 26, 2020. This Privacy Policy is effective immediately for users that sign up for Fantasy Match accounts on or after April 26, 2020 and will become effective on April 26, 2020 for users that already have accounts. To review our previous privacy policy, please click here.

Purpose of the Policy: This Policy describes how Fantasy Match (“us,” “we,” the “Company” or “Fantasy”) collects, uses, discloses and otherwise processes the personal data you provide by using the Fantasy Match app on iOS or the Fantasy Match website (collectively referred to as the “Service”).

Age Restriction: We require users of the Service to be at least 21 years of age. We do not intend for anyone under the age of 21 to use any of the features or services we offer from the Service and we do not knowingly collect personal data from anyone under the age of 21 – so, please, if you are under 21 do not use the Service. We understand and are committed to respecting the sensitive nature of people’s privacy online. If we find out or suspect you are under 21 years old – we retain the right to limit, pause, or cancel your use of the Service in the manner we may deem feet. If you suspect that a user is under the age of 21, please use the report profile mechanism available through the Service.

When you use the Service, you become a member of the Services and consent to our collection, use, and disclosure of information about you as described in this Privacy Policy.

 

2. PURPOSES OF PROCESSING

As used in this Policy, “personal data” means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.  Hence in our understanding and use personal data includes any information which, either alone or in combination with other information we hold about you, identifies you as an individual, including, for example, your name, and email address. We need certain personal data in order to provide you with access to our Service. To process your personal data as outlined below, we rely on the following legal bases:

Contractual Performance: The primary reason we process your personal data is to perform the contract that you have with us by downloading the Fantasy Match app on iOS or using the Fantasy Match website. For example, as you use our Service, we use your personal data to provide you an account, where your reactions to Cards will be saved, also, to make your public profile visible to other users.

Legitimate Interests: We may also use your personal data where we have legitimate interests to do so. For instance, we review users’ actions while using our Service to improve our Service and we process personal data for administrative, fraud detection and other legal purposes.

Consent: We may also ask for your consent to use your personal data for specific reasons. You may withdraw your consent at any time by contacting us as set out at the end of this Policy.

 

3. INFORMATION WE COLLECT AND HOW WE USE IT

In using the Service, you are required to complete the registration process.

By registering in the Service you warrant you have never committed a felony or indictable offense (or crime of similar severity), a sex crime, or any crime involving violence, and you are not required to register as a sex offender with any state, federal or local sex offender registry of any jurisdiction.

When you go through the registration process you are required to provide personal data to use the Service. This personal data can include but is not limited to: your name, gender, birth date, relationship status, sexuality, email, password, public photo, geolocation.

Some of the personal data you choose to provide us may be considered “special” or “sensitive” in certain jurisdictions, for example, public and secret photos, sexuality, mutual cards (“Sensitive Personal Data”). By choosing to provide us this personal data, you directly consent to our processing of these data. We may from time to time ask you additionally for your consent by sending you e-mail notification or by requesting it inside the Service.

We may collect and store information about you in connection with your use of the Service, including any information you transmit to or through the Service. We use and process that information to provide the Service’s functionality, fulfill your requests, improve the Service’s quality, engage in research and analysis relating to the Service, personalize your experience, track usage of the Service, market the Service, provide customer support, message you, back up our systems, allow for disaster recovery, enhance the security of the Service, and comply with legal obligations. Even when we do not retain such information, it still must be transmitted to our servers initially and stored long enough to process.

Please also note:

Information collected automatically: When you use the Service we may collect some personal data about you automatically. This personal data includes but is not limited to: app version and build number, attribution campaign and source, authentication state, push token, device OS and version, device model, latitude and longitude, signup date, payment date, and first subscription date, browser type, type of computer or mobile device, browser language, IP address, WiFi information such as SSID, mobile carrier, unique device identifier, advertising identifier, location (including geolocation, beacon-based location, and GPS location, but there is no continuous tracking of your location), and requested and referring URLs.

If you sign up/in through Facebook, this personal data also includes the date of birth, email, Facebook ID, first and last name, and gender.

This personal data allows us to provide the Service and diagnose bugs, as well as to detect fraud, send push notifications if you choose to opt into those communications.

We require all our users to allow their geolocation at least once to use the Service.

In order to be able to use “Flirt/Community” functionality you need to be in the city indicated as “active” in the Service. That is why while registering in the Service you will need at least once allow your geolocation, that we can be able to determine whether you are in the “active” city or not. Note that we do not make any discrimination of the Service users based on their location in an “active” city but there are merely technical obstacles limiting us in providing the Service to those users who are not in the “active” city.

If you want to use “Flirt/Community” functionality on an ongoing basis we may also receive from time to time and store your geolocation whenever the Service is running. You may be able to limit or disallow our use of location data through the device by adjusting the "Location" settings for our app settings; please note that in this case you limit or disallow us to provide certain Service functions.

Account Information: If you create an account, we may store and use the information you provide during that process. We may publicly display your name, age, sex (gender), sexuality, photos, relationship status, About and other content blocks (Answers) which you may fill, as part of your account profile. You are entitled to create an account of your own only and you are strictly forbidden to use any personal data of any other persons while creating your account. If you believe that someone has created an unauthorized account depicting you or your likeness, please use the report profile mechanism available through the Service.

You are entitled to create a Fantasy account of your own only and you are strictly forbidden to use any personal data of any other persons while creating your Fantasy account. If you believe that someone has created an unauthorized account depicting you or your likeness, please use the report profile mechanism available through the Service.

Public and Private profile: Some of the contributions to the Service is intended for public and private consumption and are therefore viewable for different Service users.

Public profile is the type of profile that is publicly seen by other registered Service users. Information about all the cards you have liked, disliked, blocked or reported is private and available only for you only.

Public profile includes:

(i) your name, gender, age, relationship status, sex (gender), sexuality, public photos, active city, city of your geolocation, other information in the profile which you might fill in (such as but not limited to: About, Experience, Looking for, Answers block with questions, etc);

(ii) a number of Cards that you liked. Nobody knows which exact cards you have liked, and which exact cards you have disliked;

(iii) a number of Decks you’ve got. Nobody knows the exact names of Decks you might have.

Private profile is that type of profile that is seen by a limited number of registered Service users with whom you have a Room in the Service.

IMPORTANT FACT ABOUT PRIVATE PROFILE! When you or other Services user accept or message back to a Room request a new Room will be created between you and Service user, and only mutual Cards of such Room participants will be shown, meaning those Cards that both Room participants have already liked before in the Service or other Rooms. While swiping through new cards in Rooms, both Room participants will be able to see new mutually liked cards. Be aware that you are in full control with whom you can have a Room, and it’s up to use to whether to accept or message back to a new Room request.

Private profile includes:

(i) your secret photos;

(ii) your mutually liked Cards with other participants in Play/Rooms;

(iii) your correspondence with other participants in Play/Rooms.

Contacts: You can invite others to join the Service by sending an invite link which Service will generate for you. The Service does not have access to your contact list.

Communications: When you sign up for the Service account or use certain features, you are opting to receive incoming notifications, likes, messages and other notifications from the Service and other members, and us. You cannot opt-out of receiving certain administrative, transactional, or legal messages from us. Please note that in case you opt-out you may miss some important notification from us and hence you relieve us from any liability related to such notification delivery or non-delivery.

We may also track your actions in response to the messages you receive from us or through the Service, such as whether you deleted or opened such messages. If you exchange messages with others through the Service, we may store them in order to process and deliver them, allow you to manage them, and we may review and disclose them in connection with investigations related to use of the Service, as well as our efforts to improve the Service. We may not deliver messages that we believe are objectionable, such as spam messages, fraudulent solicitations, or requests for paid services.

We may also store information that you provide through communications to us, including phone calls, letters, emails, and other electronic messages, or in person. Our calls with you may be monitored and recorded for quality purposes and with no additional notification.

Transactions: If you initiate a transaction through the Service, such as a purchase, we may collect and store information about it, as well as any other information you provide to us, in order to process a transaction, and inform you about it.

This information may be shared with third parties for the operating, processing and analytical purposes, and third parties may share such information with us, for informational purposes.

We do not store your credit card number, and any other personal information related to the payment. All payments are made and processed by Apple.

We hereby encourage you to keep your payment information in strict confidence and not to share it with any persons (including other Service members, your children and relatives) except for the purpose of making a purchase you independently have decided to make at your own discretion and will – so that we consider any purchase you make through the Service as made by you personally and willingly.

Activity: When you use the Service, we may collect personal data as you take actions within the Service, such as Cards you liked or disliked in Learn/Library or in Play/Rooms, members whom you send various new Room requests by sending likes, messages, link invites or other forms, whom you have interacted with and how you use the Service. This may include but is not limited to passing, liking, disliking, reading, commenting, messaging, blocking, reporting, search activity, or any other activity, the screens you view, the date and time of your visit. Collecting this information allows us to provide the Service and helps us improve the Service by refining our recommendation algorithm, diagnosing bugs or issues, developing new features, and monitoring for behavior that violates our Terms of Service. This information is also could be used for financial reporting in an aggregate form without disclosing your personal information.

Background information: we do not conduct criminal background, registered sex offenders, neither identity verification checks on registered users, their activities or otherwise inquire into the background of its users unless it is strictly stated in this Privacy Policy. That means we do not warrant any non-criminal background of any Service user, including a user you are communicating with through or due to the Service use.

 

4. COOKIES

We, and third parties with whom we partner, may use cookies, web beacons, tags, scripts, sdk’s (software development kits), local shared objects such as HTML5 and Flash (sometimes called "flash cookies"), advertising identifiers (including mobile identifiers such as Apple’s IDFA or Google’s Advertising ID) and similar technology (jointly "Cookies") in connection with your use of the Service, third party websites, and mobile applications.

Cookies may have unique identifiers and reside, among other places, on your computer or mobile device, in emails we send to you, and on our web pages. Cookies may transmit information about you and your use of the Service, such as your browser type, filter preferences, IP address, data relating to advertisements that have been displayed to you or that you have clicked on, and the date and time of your use. Cookies may be persistent or stored only during an individual session. We use Cookies once you enter the Service website (even in case you use it without registration), or when you open the iOS app.

The purposes for which we use Cookies in the Service include:

Purpose Explanation
Processes Intended to make the Service work in the way you expect. For example, we use a Cookie that tells us whether you have already signed up for an account.
Authentication, Security, and Compliance Intended to prevent fraud, protect your data from unauthorized parties, and comply with legal requirements. For example, we use Cookies to determine if you are logged in.
Preferences Intended to remember information about how you prefer the Service to behave and look. For example, we use a Cookie that tells us whether you have declined to allow us to send push notifications to your phone.
Notifications Intended to allow or prevent notices of information or options that we think could improve the use of the Service. For example, we use a Cookie to inform you whether or not to send you a notification about new Cards or Decks availability.
Advertising Intended to make advertising more relevant to users and more valuable to advertisers. For example, we may use Cookies to serve you interest-based ads, such as ads that are displayed to you based on your visits to other websites, or to tell us if you have recently clicked on an ad.
Analytics Intended to help us understand how you use the Service. For example, we use a Cookie that tells us how you interact with Cards and what Cards to show you next.

 

You can set some Cookie preferences through your device or browser settings, but doing so may affect the functionality of the Service. The method for disabling Cookies may vary by device and browser, but can usually be found in your device or browser preferences or security settings. For example, iOS and Android devices each have settings that are designed to limit forms of ad tracking. Please note that changing any of these settings does not prevent the display of certain advertisements to you.

 

5. AUTOMATED DECISION-MAKING AND PROFILING

To perform the contract that you have with us, we use automated decision-making and/or profiling in regard to your personal data, including Sensitive Personal Data, to show you relevant Cards, or to show you relevant accounts who are also registered members. We use automated decision-making and profiling to recommend cards and accounts to you based on your profile and your activity in the Service. We also use automated decision-making and profiling to moderate violators by flagging user profiles that may contain explicit content.

If you choose to opt-out of automated decision-making and profiling, we will not be able to provide our Service and you will be prompted to delete your account. We do not otherwise use your personal data for the purposes of automated decision-making. However, we may do so in order to fulfill obligations imposed by law, in which case we will inform you of any such processing and provide you with an opportunity to present your objections to the entity having provided appropriate requests.

 

6. HOW WE SHARE YOUR INFORMATION

We may share your personal data with other service providers and partners who help us operate the Service, as well as in the event of a business transaction and for law enforcement purposes.

IMPORTANT! The fact of sharing of your information does in no case mean selling, renting, releasing, disclosing, transferring or other communicating orally, in writing, by email or other means to any third party for monetary or other types of valuable consideration.

Third parties may receive information about you as follows:

Service Providers: We may share your personal data with third parties to provide you with the Service (such as analytics services or customer relationship management services). We vet all service providers before we provide them with your personal data and ensure we have appropriate contractual safeguards in place.

Aggregate or Anonymous Information: We may share information in the aggregate form with third parties for analytics, marketing or statistical purposes. For example, we may disclose the number of users that have been liked or disliked Cards. We may also disclose anonymized information about the use of the Service, for example, if you engage in a transaction in connection with the Service, we may publicly disclose information about the transaction without providing identifying information about you or otherwise disclosing your participation in the transaction.

Business Transfers: We may share information from or about you with our parent companies, subsidiaries, joint ventures, affiliates, or other companies under common control, in which case we will require them to honor this Privacy Policy. If the Service is involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, dissolution, bankruptcy or other change of control or ownership, we may transfer personal data in relation to that transaction with respect to that information as described in this Privacy Policy.

Investigations and Legal Disclosures: We may investigate and disclose information from or about you if we have a good faith belief that such investigation or disclosure:

(i) is reasonably necessary to comply with legal process and law enforcement instructions and orders, such as a search warrant, subpoena, statute, judicial proceeding, or other legal process or law enforcement requests served on us;

(ii) is helpful to prevent, investigate, or identify possible wrongdoing in connection with the Service;

(iii) protects our rights, reputation, property, or that of our users, affiliates, or the public.

If you report or otherwise complain to us about content through the Service, we may share the substance of your complaint with the contributor of that content in order to provide an opportunity for the contributor to respond.

Third-Party Accounts: If you sign up for, or log into the Service using a third-party service like Facebook, or link your Service account to your account with a third-party service like Facebook, Instagram or cell number, we may receive information about you from such third-party service. If you post content to a third party service through the Service, that third party service will also receive that content, which will be visible to anyone that has access to it through that third-party service.

 

7. CONTROLLING YOUR PERSONAL DATA AND YOUR RIGHTS

7.1. Tools you have to control your personal data.

Tools in the Service: The Service provides certain tools that allow you to access, rectify, delete  or even cancel external use of information that you provided through the Service and that’s associated with you. Other users may be able to identify you or associate you with your account if you include personal information in your profile.

Please also note that the digital content you see in Rooms, or messages you send or receive using the Service are only private to the extent that both you and the person you are communicating with keeping them private. For example, if you send a message to another user, that user may choose to publicly post it. Also, we may access and disclose such messages in the course of investigations relating to the use of the Service.

Device Permissions: Mobile operating systems have permission controls, such as for camera and location services. You can control these options through your device’s settings. Please note that changing these settings may result in lost functionality within the Service.

Other software permissions: other software or software development tools and kits (jointly “other software”), integrated into the Services or used alongside with the Service use, may have additional technical features or require additional settings of personal data use, such as screenshots and screencasts making prohibition from other devices using the Service.

 

7.2. Your privacy rights.

Opt-out. You may contact us anytime as set out at the end of this Policy to opt-out of:

  • (i) direct marketing communications;
  • (ii) automated decision-making and/or profiling;
  • (iii) any new processing of your personal data that we may carry out beyond the original purpose;
  • (iv) the transfer of your personal data including such transfer which is considered as personal data sale by the California Consumer Privacy Act.

Please note that your use of the Services may be ineffective upon opt-out or you may miss some important information or notification upon opt-out. And also any of our obligation on sending you notification under this privacy policy or terms of use of the Service shall be considered duly fulfilled immediately after the moment it must be sent irrespective of the fact it can not be sent due to your opting-out.

Reviewing your information: Applicable privacy laws may give you the right to review the personal data we maintain about you. To request information about your personal data to know more details about the categories or specific pieces of personal data we collect (including how we use and disclose this information), please contact us at [email protected], including the reason, and the details of your personal account, such as: ID, a registration email, name, age and some of your last profile activity. This process can take some time. To ensure the security of your data, we use this time to verify that the request was made by you.

Updating your information: If you think the information we hold about you is inaccurate or that we are not entitled to use it and would like to request that we rectify, delete or object to our processing of this personal data, please contact us as set out at the end of this Policy. You retain the whole responsibility for the accurateness and actuality of the information we hold about you.

Moving your information. Your data is portable – i.e. you have the flexibility to move your data to other service providers as you wish. To request this, please contact us at [email protected], including the reason, and the details of your personal account, such as registration email, name, age and some of your last profile activity. This process can take some time. To ensure the security of your data, we use this time to verify that the request was made by you. To request access to your personal data, please contact us as set out at the end of this Policy.

Accountability: Some countries, including appropriate States of the USA and those in the European Union, provide you with a right to file a complaint with the appropriate data protection authority if you have an issue with how we process your personal data.

For your protection, we may ask you to prove your identity before we answer any requests related to the above items. Note that we may request additional information from you to verify your identity and even reject a request for certain reasons, including if it is unlawful or if fulfilling the request will infringe a trade secret or other intellectual property or the privacy of another user.

IMPORTANT! In case of any rights exercising, prescribed by this Privacy Policy, you will not be discriminated against for exercising these rights. Technical impossibility to fulfill some obligation from our side due to the exercise of your rights shall not be considered as a breach or discrimination of your rights.

 

8. DATA RETENTION AND ACCOUNT DELETION

You can delete your account in the app by navigating to Profile > Settings > Delete account.

We will remove your public and private profile from the view of other registered users and/or dissociate it from your account, but we may retain some information about you for the purposes authorized under this Privacy Policy unless prohibited by law.

For example, we may retain information to prevent, investigate, or identify possible wrongdoing in connection with the Service or to comply with legal obligations. Please remember that even though our systems are designed to comply with the above retention periods, we cannot promise that 100% of the data will always be deleted due to technical constraints.

If you log out or uninstall the app without deleting your account, you can stop all the information collection by the app. Please note that in this case we will retain the data associated with your account. If you reinstall the app and sign in to the Service, we will be able to re-associate the data with your account.

 

9. CROSS-BORDER DATA TRANSFERS

The sharing of personal data as explained in this Policy may involve the transfer of personal data across borders, for instance from the USA to the European Economic Area and other jurisdictions, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world.

As an example, where the Service allows Service users to be located in the United States of America  (“USA”), their personal data is transferred to countries outside of the USA. We use standard contract clauses approved by suitable safeguards to permit data transfers from the USA to other countries or from one State of the USA to another State. Standard contractual clauses are commitments between companies transferring personal data are used, binding them to protect the privacy and security of your data.

 

10. SECURITY

The security of our platform and our Service users’ data is our top priority, and we’re taking every measure to ensure our customers remain secure.

We use various safeguards to protect the personal information submitted to us. This includes encryption in transit, data filtering, different network layers, as well as security audits. However, no method of transmission over the Internet or via a mobile device, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your personal information during transmission through the Internet or while stored on our capacities or otherwise in our care, we cannot guarantee its absolute security.

We may suspend your use of all or part of the Service without notice if we suspect or detect any breach of security. If you believe that your account or personal data is no longer secure, please notify us immediately at the contact information set out below.

 

11. SERVICE AREA BEYOND OUR CONTROL

Other users: The Service includes user-generated profiles and Rooms with interactive messaging services. Please remember that any information that is disclosed in these areas may be seen and copied by other users and you should exercise caution when deciding to disclose your personal data.

You remain the only liable for any your activities or posting any messages that may harm or abuse any third party in any manner; and from other side note that due to the specific nature of the Service some other users may post some content which can be abusing or unacceptable for you – we do not bear any liability for such content posting, but of course, you may contact us with the appropriate complaint for which we shall send you a proper answer with no warranty of your complaint settlement or solution.

Third-party websites: The Service may contain links to other websites. If you choose to visit other websites, we are not responsible for the privacy practices or content of those other websites, and it is your responsibility to review the privacy policies at those websites and apps to confirm that you understand and agree with their policies.

 

12. MODIFICATIONS TO THIS PRIVACY POLICY

We reserve the right, at any time, to add to, change, update, or modify this Policy.

The most current version of the Privacy Policy will govern our collection, use, and disclosure of information about you and will be located here. If we make material changes to this Privacy Policy, we will notify you by email or by posting a notice on the Service prior to the effective date of the changes. By continuing to access or use the Service after those changes become effective, you acknowledge the revised and agreed with this Privacy Policy.

 

13. HOW TO CONTACT US

You may contact for any purpose or with any questions concerning this Privacy Policy, including but not limited to your questions related to your rights under the California Consumer Protection Act.

We will verify your request using the information associated with your Service account, including your email address. Government identification may be required. Any Service users being a consumer of the Service can also designate an authorized agent to exercise these rights on their behalf.

Please write to us at the following address: [email protected] with the subject title "Privacy Policy", and our data protection officer will answer you within the reasonable shortest time.