This privacy policy (“Privacy Policy”) governs the data collection, processing, and usage made by Kliklak Dating Ltd. (“Company”, “we” or “us”). This Privacy Policy concerns the data we collect and process from individuals who have installed and are interacting with our mobile Kliklak Application and to be provided with our Services (respectively “App”, “users” or “you”);
This Privacy Policy constitutes an integral part of the Kliklak Terms and Conditions (“Terms”). Definitions used herein but not defined herein shall have the meaning ascribed to them in the Terms.
If you have any questions about this Privacy Policy, please contact us at: [email protected].
Amendments
We reserve the right to periodically amend or revise the Privacy Policy, which will immediately affect the implementation of the revised Privacy Policy on our App. The last revision date will be reflected in the “Last Modified” heading located at the top of the Privacy Policy. We will make a reasonable effort to notify you if we implement any changes that substantially change our privacy practices. We recommend that you periodically review this Privacy Policy to ensure that you understand our privacy practices and check for any amendments.
Who are we and Contacting Us
Kliklak Dating Ltd.
14 Shankar St., Herzliya, Israel
Email: [email protected]
Questions, comments, requests and complaints regarding this Privacy Policy and the information we hold are welcome and should be addressed to us by using the contact details above. All requests will be dealt with promptly and efficiently.
Data Controller / Data Processor for GDPR purposes
Under the European General Data Protection Regulation (” GDPR”), we are the Data Controller of our direct user’s Personal Data.
Collection of Non-Personal Data
Collection of Personal Data
During your use of the Website or the App, we will collect individually identifiable information, namely information that identifies an individual or may with reasonable effort be used to identify an individual (“Personal Data” or “Personal Information” as defined under applicable law). This may include online identifiers, name, emails, etc., subject to applicable law.
If we combine Personal Data with Non-Personal Data, we will treat the combined data as Personal Data.
processing of Personal Data – Purposes and Lawful Basis
We have included in the table below information about which data is processed, how we process and use your data and the lawful basis for which we do so subject to the GDPR.
Type of Data
Purpose of Processing
Lawful Basis
Registration Process:
If you wish to be provided with our Services you will be required to register with us (“Registration Process”). As part of the Registration Process you will be required to provide us with certain information such as your full name, email address, phone number and city-level basis geographic location. Also, we will ask you to provide additional data regarding the use of our App, like marital status, sexual orientation and interests, etc. please note that not all of that data is mandatory, and you can “skip” some of it.
Additionally, you will be required to create a username and password and when you do so you will need to represent and warrant that you are responsible for maintaining the confidentiality of your information and password. You further will represent and warrant that you will not provide us with inaccurate, misleading or false information.
As part of the registration process and usage, you may provide us, we may process certain unique identifiers designated to you by Google, Facebook, and Apple. If you choose to provide us with any of the above, we may also process other information related to your accounts.
We will use this data to designate your account and allow you to use the Services and the App supporting its operation.
Also, your email address may be used to send you needed information related to our App (e.g., sending you with a verification code, notify you regarding any updates to our App, special offers, etc.).
Our lawful basis under the GDPR for collecting this information is the performance of a contract (i.e., providing you the Services as per your request).
Verification Photo:
User’s Profile:
Following the compilation of the Registration Process, you will be asked to create your personal profile (“Profile”). As part of the creation of your Profile you may share with us additional information, such as details on your personality, lifestyle, interests, demographic data (i.e. Date of Birth, Height, Weight, Gender, etc.) and other details about you, as well as content such as photos and videos. To add certain content, like pictures or videos, you may allow us to access your camera or photo album. Some of the information you choose to provide us may be considered “special” or “sensitive” in certain jurisdictions, for example your racial or ethnic origins, sexual orientation and religious beliefs. By choosing to provide this information, you consent to our processing of that information.
We will use this data to designate your Profile and allow you to use the Services and the App.
Our lawful basis under the GDPR for collecting this information is the performance of a contract (i.e., providing you the Services as per your request).
In case we will collect in the future any payment data related to the use of the App, the lawful basis for such processing will be performance of a contract (i.e., providing you the Services as per your request), the necessity of processing for our legitimate interests and complying with our legal duties (e.g., bookkeeping and tax laws).
Contact us
If you voluntarily contact us in any manner, whether for support, to submit a request or for other inquiries, whether by sending us an email or through other means of communications, e.g., any online form available on the App, you may be asked to provide us with your contact information such as your full name, email address and country.
We will use this data and our contact history solely to respond to your inquiries and provide you with the support or information you have requested. We will retain our correspondence with you for as long as needed, subject to applicable law.
The lawful basis for processing your information will be the contract between you and us, meaning we will use the data for addressing your requests and inquiries.
After completing any such request, we will retain your information as part of our business records under our legitimate interest.
Some of our Services’ data might be processed under our legal obligation, such as safety requirements.
Chat
Our Services and App include user’s chat platform that users may use to interact with other users. We may collect and process you chats with other users as party of the operation of the Services
We will use this data to provide you with the chat function of the App.
Our lawful basis under the GDPR for collecting this information is the performance of a contract (i.e., providing you the Services as per your request).
Online identifiers and other Technical Data
When you interact with our App, we may collect certain online identifiers, including your IP address, Advertising ID, and IDFA.
We may also collect technical Non-Personal Data transmitted from your device (e.g., actions in the App, language used, type of operating system, type of device, etc.) and approximate geographical location (country).
We use this data for our legitimate interests of
(i) operating, providing, maintaining, protecting, managing, customizing, and improving the App and how we offer it;
(ii) enhancing your experience;
(iii) auditing and tracking usage statistics and traffic flow; and
(iv) protecting the security of the App, as well as our and thirdparties’ rights (subject to applicable law requirements);
Such processing is part of our legitimate interests as a commercial business.
Cookies & Pixal Usage
Our App includes tracking technologies such as cookies and pixels. These tracking technologies are used for the purpose of gathering some information automatically, by ourselves or by service providers on our behalf.
We may use various types of Cookies and Pixels:
- Essential – which are necessary for the site to work properly (usually appears under our name/cookie tag);
- Functional – designated to save your settings on the App – your language preference or other view preferences;
- Targeting – used to collect information from you to help us improve our products and services and serve you with targeted advertisements that we believe will be relevant to you (e.g., Google’s Cookies).
- Social networks – Social Plug-In Cookies (e.g., Facebook, Twitter, LinkedIn Cookies, or pixels, etc.) enable sharing your usage information with your social network’s accounts.
- Analytics – give us aggregated and statistical information to improve the App and further developing it e.g., Google analytics, Google Firebase Crashlytics, etc.
- Third-party services used by us – for example, an external service which allows us to screen short videos on our App (e.g., YouTube or Vimeo).
Please note that the data collected by the use of Cookies and Pixels may be linked to and combined with any other data, including Personal Data.
Also note, that Cookies and Pixels data is usually collected through third-party services, like Google, Facebook, etc. In those cases, your Personal Data might be transferred to those third parties, which might use it, as a “joint controller” or “Co-Controller” of the data, meaning that the data is also “owned” and processed by them under their terms and conditions. Under those terms and conditions and the direct accounts or subscriptions you have with those third parties, your Personal Data might be linked to other data collected by the relevant third party and processed in its systems, for its purposes, and under its management.
For example, suppose you have a Facebook account, the Personal Data collected through Facebook’s Cookies in Our App might be linked to other data Facebook collects and might be used by Facebook per the independent agreements between you and Facebook.
Sharing data with third parties
We do not share any Personal Data collected from you with third parties or any of our partners except in the following events:
- Legal Requirement:We will share your information in this situation only if we are required to do so to comply with any applicable law, regulation, legal process, or governmental request (e.g., to comply with a court injunction, comply with tax authorities, etc.);
- Policy Enforcement: We will share your information, solely to the extent needed to (i) enforce our policies and agreements; or (ii) to investigate any potential violations thereof, including without limitations, detect, prevent, or take action regarding illegal activities or other wrongdoings, suspected fraud or security issues;
- Company’s Rights: We will share your information to establish or exercise our rights, to prevent harm to our rights, property, or safety, and to defend ourselves against legal claims when necessary, subject to applicable law;
- Third Party Rights: We will share your information, solely to the extent needed to prevent harm to the rights of our users, yourself, or any third party’s rights, property, or safety;
- Business Purpose – we may disclose your personal information to a third party for a business purpose, as detailed above.
- Service Providers – we share your information with third parties that perform services on our behalf (e.g. customer service, tracking, servers, service functionality, marketing, and support, etc.) these third parties may be located in different jurisdictions.
- Corporate Transaction – we may share your information in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, our affiliated companies or acquiring company will assume the rights and obligations as described in this Privacy Policy;
- Authorized Disclosures – we may disclose your information to third parties when you consent to a particular disclosure. Please note that once we share your information with another company, that information becomes subject to the other company’s privacy practices.
- Other Users – we may disclose and share your information (including your Profile) in order to provide the Services to you and our users. Please be aware that the content you share through our App shall being publically viewable since neither you nor we can control what others do with your information once you share it.
Your Data Subjects' rights under Privacy Protection laws
Under EU law, EU residents and individuals have certain rights to apply to us to provide information or make amendments to how we process data relating to them. Those rights might include:
- right to access your Personal Data – you can ask us to confirm whether or not we have and use your Personal Data, and if so, you can ask for a copy of your data;
- right to correct your Personal Data – you can ask us to correct any of your Personal Data that is incorrect, after verifying the accuracy of the data first;
- right to erase your Personal Data – you can ask us to erase your Personal Data if you think we no longer need to use it for the purpose we collected it from you. You can also ask for such erasure in any case in which the process of your data was based on your consent, or where we have used it unlawfully, or where we are subject to a legal obligation to erase your Personal Data. any request for such erasure will be subject to our obligations under the law (e.g., our obligation to keep some records for tax or customs purposes);
- right to restrict our use in your Personal Data – you can ask us to restrict our use of your Personal Data in certain circumstances;
- right to object to how we use your Personal Data – you can object to any use of your Personal Data which we have justified by our legitimate interest if you believe your fundamental rights and freedoms to data protection outweigh our legitimate interest in using the information;
- you can always require us to refrain from using your data for direct marketing purposes;
- you can ask us to transfer your information to another organization or provide you with a copy of your Personal Data (Portability Right);
We may not always be able to do what you have asked. Also, not all those rights apply in every jurisdiction. Yet, we encourage you to contact us with any such request, and we will be happy to assist you.
You have the right to lodge a complaint at any time before the relevant supervisory authority for data protection issues. However, we will appreciate the chance to deal with your concerns before you approach the authorities, so please feel free to contact us in the first instance.
Though those rights principally apply under the GDPR towards EU residents, similar rights may apply in other jurisdictions, to some extent, in accordance with the relevant jurisdiction. Thus, if you are not an EU resident but still have any such request, we encourage you to contact us with any such inquiry and we will do our best to assist you, in accordance with the applicable law and our legitimate and lawful interests.
Data retention
Unless you instruct us otherwise and subject to applicable laws, we retain the information we collect for as long as needed to provide our services and to comply with our legal obligations, resolve disputes and enforce our agreements if applicable. We may keep some of your Personal Data as a user of our Services for more extended periods to protect our legal interests or under any safety or other legal requirements.
Security
We use physical, technical, and administrative security measures for the services that we believe comply with applicable laws and industry standards to prevent your information from being accessed without the proper authorization, improperly used or disclosed, unlawfully destructed or accidentally lost.
However, unfortunately, the transmission of information via the internet and online data processing cannot be 100% secure. As such, although we will do our best to protect your Personal Data, we cannot guarantee the security of data transmitted via the Website, App and any transmission of your data shall be done at your own risk.
Data Processing Location
We may store or process your Personal Data in a variety of countries, including the United States.
Any transfer of data that originates in the European Union (“EU“) to a country outside of the European Economic Area (EEA), shall be made in compliance with the provisions of chapter 5 of the GDPR, e.g.:
- transfer to a country that is recognized as providing an adequate level of legal protection;
- transfer under a proper agreement containing the Standard Contractual Clauses published and authorized by the relevant EU authorities;
- where we can be satisfied those alternative arrangements are in place to protect your privacy rights through the use of any other mechanism under the GDPR.
It is important to note that we are headquartered in Israel, a country that the European Data Protection Board considers offering an adequate level of Personal Data protection regulation.
Suppose you are a resident of a jurisdiction where the transferring of your Personal Data requires your consent, your consent to this Privacy Policy includes your express consent for such transfer of your data.
Chidren
Our App and Website are not directed, nor is it intended for use by children (the phrase “child” shall mean an individual that is under age defined by applicable law which concerning the European Economic Area (“EEA“) is under the age of 16 and with respect to the U.S.A, under the age of 13) and we do not knowingly process a child’s information. We will discard any information that we receive from a user who is considered a “child” immediately upon discovering that such a user shared information.
Please contact us if you have reason to believe that a child has shared any information with us.