Privacy Policy (International)

Effective Date: April 12, 2018

Praecellens Limited ("we" or "us"), a company located in Cyprus, is firmly committed to your privacy. This Privacy Policy sets out our practices related to the collection, use and sharing of information you provide us when you visit our websites, mobile websites and mobile applications (collectively, the "Platform") and use the services thereon (the "Services"). To help us meet our commitment to you, we have appointed a Privacy Officer to oversee our privacy practices and our compliance with this Privacy Policy. If you have any questions or concerns regarding our policies and practices related to your information, or would like to contact our Privacy Officer, please see the “Contact Us / Complaints” section below.

Below is a high level summary of this Privacy Policy. Please read this Privacy Policy carefully in its entirety before using the Platform and do not solely rely on the high level summary provided below.

Collection: We collect different types of information from you in connection with your access to the Platform and use of the Services. In particular, we collect information which can be attributed to you individually (for example, your email address and demographic information) as well as information which cannot (for example, anonymous usage data). For more information about the types of personally identifiably information we collect click here.
Usage: We use the information we collect from you for a number of different purposes including to facilitate your use of the Services. For more information about how we use the information we collect from you click here.
Disclosure: We disclose the information we collect from you in a number of different circumstances including to our service providers to perform certain functions on our behalf in connection with our provision of the Services. Some of the recipients who we disclose your information to may be located in jurisdictions outside Canada. For more information about who we disclose the information we collect from you to click here.
Security: We take the protection of your personal information seriously. For more information about how we protect your information please click here.
Contact Us / Complaints: If you have any questions or concerns regarding our policies and practices related to your information, contact us.

By accessing the Platform or using any of our Services you accept this Privacy Policy and agree to the terms, conditions and notices contained or referenced herein. Your use of our Platform or Services, and any dispute over privacy, is subject to this Privacy Policy and our Terms of Service (https://www.ashleymadison.com/app/public/tandc.p).

Please note that, to the extent required by applicable law, we will obtain your express consent for the collection, use and disclosure of your Personal Information (as defined below).

What types of information do we collect?

We collect the following types of information directly from you, from third parties (where appropriate consents are in place) or automatically through your use of our Services:

Personal Data, which is any information about an individual person, who can be identified from or in connection with that information; and
Anonymous Data, which is information that is stripped of any identifiable features, meaning no one would be able to use it to identify a specific individual (for example, anonymous information related to your use of the Services).

What information will we ask you for?

When you create a profile on our Platform you will be asked to provide information about you which we need to enable us to provide you the Services including contact information (e.g. your email address), demographic information (e.g. your city of residence, zip/postal code, age, sexual orientation, gender and ethnicity), and personal characteristics (height, weight and body type). To the extent permitted by applicable law, we may supplement this with information about your IP address, or your location, when you use the Services.

While creating your profile, you may choose how much Personal Data you share with us. You will be asked to create a username and offered the chance to upload a photograph and provide a personal description. You are encouraged to create a pseudonymous profile and are not required to include information in your profile that would allow you to be directly identified. If you want to remain anonymous, please be careful about what you choose to share, especially if you upload photographs or choose a username which could allow you to be easily identified.

When you make a purchase off our Platform you will be asked for certain Personal Data for billing purposes including your name, address and details of your chosen payment method in order for us to be able to process your transaction.

With your permission, we will also collect your location information from your mobile device to help you identify other Platform members in your area. You may turn off this feature through the location settings on your mobile device. We also collect your general geographic location from your browser access to help you identify members in your area and to help us quickly and efficiently respond to inquiries and requests.

If you choose to activate 2-factor authentication for your account, we may ask for your phone number. This phone number will be shared with a third party service provider Nexmo. Nexmo service is not part of the Service, and is subject to separate terms and conditions, including different policies with respect to the collection, use and disclosure of your personal information. We do not have control over Nexmo. You will need to make your own independent judgment regarding your interaction with them. Please note that if you decide to delete your Ashley Madison account, we will delete your phone number from our records but Nexmo may not. If you decide to activate 2-factor authentication through an Authenticator App of your choice, please note that use of such app is subject to separate Terms and Conditions and Privacy Practices which we do not control. Please review them and make independent judgement if you want to proceed with such app.

If you contact our customer support team we may ask you to provide your user name and email address for the purposes of resolving any queries or issues which you may have with the services.

We do not actively collect the information which you include in messages sent between users on the site but this information is available to us and may be monitored for fraud. You should only include personal information about yourself in these messages unless you have the consent of any other individual to include their information. We will presume that where you include the personal information of any other individual in such messages that you have their consent to do so.

Some of the information described above and required to be able to provide the Service to you may be considered “sensitive information” under the applicable laws of your jurisdiction of residence. We will only process this information where we have obtained your explicit consent to do so. Please be aware that sensitive information refers to information related to your private life, or that may create a risk for you, or that may give rise to discrimination against you, including but not limited to race, ethnicity, health status, genetic information as well as religious, philosophical and moral beliefs, socioeconomic status, memberships in social and human rights organizations, political views or sexual preference and your physical location.

Cookie Policy

We use cookies, clear GIFs, third-party analytics and other tracking mechanisms to track your use of our Platform and the Services. Such tracking mechanisms may automatically collect information such as: your IP address, domain name, browser type and operating system; web pages you view; links you click; how you move through the Platform and the length of time you visit our Platform and use the Services; and the referring URL, or the webpage that led you to our Platform. We may combine this information with other Personal Data we collect from you.

Do-Not-Track. Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies or opting out of ad networks).

Cookies. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. We might use cookies to uniquely identify you, in order to help us to process your transactions and requests, to track aggregate and statistical information about user activity, and to display advertising both on our Platform and on third-party sites. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. If you disable cookies some features of our Platform may not function. Further information may be found at www.allaboutcookies.org.

Clear GIFs. Clear GIFs (a.k.a. web beacons, web bugs or pixel tags) are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, though, clear GIFs are embedded invisibly on web pages, not stored on your hard drive. We might use clear GIFs to track the activities of our visitors and app users, help us manage content, and compile statistics about usage. We and our third party service providers also might use clear GIFs in HTML e-mails to our customers, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded. These can be blocked either by using a third party application such as Ghostery, or, in the case of emails, by changing your settings to prevent images from being downloaded (where your email client supports this functionality).

Third-Party Analytics. We also use automated devices and applications, such as Google Analytics (to opt out, go here), and AppsFlyer (to opt out, go here) to evaluate usage of our Platform and the Services we provide. We use these tools to gather information about users to help us improve our services, performance and user experiences. These analytics providers may use cookies and other technologies to perform their services, and may combine the information that they collect about you on our Platform with other information that they have collected. This Privacy Policy does not cover such third parties’ use of the data: for further information please see the relevant party's privacy policy. For a list of additional Third Party analytics providers we may use, please go here (http://www.rubylife.com/analytics_providers).

Google Analytics. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. This website uses Google Analytics with the expansion '_anonymizeIp()'; therefore, only abbreviated IP addresses will be further processed, so that a direct connection to the individual user is eliminated. Your IP address will be shortened beforehand by Google (i.e. the last octet of the IP address will be anonymized) within member states of the European Union or in other signatory states of the Treaty on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google Server in the USA and shortened there. Google will use this information on behalf of the website operator for the purpose of evaluating your use of the website, compiling reports on website activity, and providing other services to website operators relating to website activity and Internet usage. Google will not associate the IP address transmitted under Google Analytics by your browser with other data held by Google. You may prevent the use of Google Analytics by disabling cookies in the browser's set up screen. You may prevent the storage of cookies by selecting the appropriate settings on your browser software; however, we must advise you that in this case, you might not be able to use all functions of this website to the full extent. You may prevent Google from recording the data generated by the cookie and pertaining to your use of the website (including your IP address), or processing these data by downloading and installing the following browser plug-in available through Google at the following link: http://tools.google.com/dlpage/gaoptout?hl=en.

Third-Party Ad Networks. We may use third parties such as network advertisers to serve advertisements on our Platform and on third-party websites or other media, and to evaluate the success of our advertising campaigns. This enables us and these third parties to target advertisements to you for products and services in which you might be interested. Third-party ad network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs and other tracking technologies to measure the effectiveness of their ads and to personalize advertising content to you. These third-party cookies and other technologies are governed by each third party’s specific privacy policy, not this one. We may provide these third-party advertisers with information about users (e.g., IP address and demographic information), but we do not share details such as your name or contact information. You may be able to avoid targeted ads by certain ad networks by blocking cookies (see your browser’s “Help” menu for information on how to do this); however, our Platform may not work if you block or disable all cookies. For a list of networks advertisers we may use, please go here (http://www.rubylife.com/network_partners).

Google's Privacy Notice is located at http://www.google.com/analytics/learn/privacy.html.

Third-Party Links. Our Platform and services may contain links to third-party websites. For example, when you leave our Platform, you may be directed to a third-party website, which may collect your IP address and other Personal Data. Such third party may be located outside your jurisdiction of residence, including the United States. We do not supply any Personal Data to these third parties. Any access to and use of such linked websites, and any Personal Data collected in connection therewith, is not governed by this Privacy Policy, but instead is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites and we encourage you to read the relevant third party's privacy policy to understand their use of your personal information.

User Generated Content

You may post content on the Platform, including your comments, pictures, and any other information that you would like to be available to other users of our Services. We cannot prevent the content you post or share on our Platform or Services from being used in a manner that may violate this Privacy Policy, the law, or your personal privacy, or from being shared or shared by other users.

Other Information Collectors

Except as otherwise expressly described in this Privacy Policy, this document only addresses the use and sharing of the information we collect from you. To the extent that you share your information to other parties, whether they are on our Platform (including links to third party sites) or on other sites throughout the Internet, different rules may apply to their use or sharing of the information you share to them. To the extent that we use third party advertisers or have third party e-commerce partners, they adhere to their own privacy policies. Since we do not control the privacy policies of any third parties, you should investigate their policies before you share your Personal Data to them.

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How will we use the information we collect?

We use the information we collect, including Personal Data, for the following purposes:

To provide you with the Services, including:

to provide you with access to a forum focused on open-minded and discreet relationships, where members can search for and connect with other like-minded individuals;
to allow users to find other users’ profiles based on preferences or user location;
to allow you to create a profile which will appear on your chosen website(s);
to promote your profile to other users of the Services and to allow other users to search for profiles of individuals likely to be of interest to them;
to maintain and improve our Platform including improving the content and functionality of our Platform or customize the layout of our pages for each individual member;
to tailor the content and information that we may send or display to you, to offer location customization, and personalized help and instructions, and to otherwise personalize your experiences while using the Platform;
to process your payments and to help resolve payment disputes;
to manage your account and provide you with customer support;
to offer a more secure access to your account; and
to save your user account, registration and profile data and other information (so you do not have to re-enter it each time you visit or use the Services);

We may also use such information where it is in our legitimate interests to do so in the course of maintaining the platform and improving the user experience, including:

to conduct surveys and market research in order to improve the Services;
to communicate with you in connection with the Services including, subject to our obligations regarding email communications in your respective jurisdiction, for the purposes of informing you of changes or additions to the Service, or of any our products and services we believe may be of interest to you (please see our section on Marketing below for further information);
to detect and combat fraud, and better understand how to protect your information;
to deliver targeted advertising and promotional offers to you that are of the highest relevance to your demographic profile;
to protect our own rights and interests, such as to resolve any disputes, enforce our Terms of Service, or to respond to legal process; and
to track your return visits to, and use of, the Services.

When you register on a site we will ask your consent to display your profile on other, similar website which we think may be of interest to you. We will not however share your profile on any website other than the one you registered on without your consent.

We use personal information that you provide in your user profile combined with certain algorithms and machine based learning to improve our website search function and to present profiles to you which are more likely to be of interest. We use demographic data of individuals with whom you interact in order to present profiles of other users which you are likely to be interested in.

We also use Anonymous Data. For example, we may collect and analyze aggregated, de-identified, statistical information to help improve operation of the Services and manage user activity across the Platform.

Will we use your Personal Data for Marketing purposes?

We may:

send you information about our Platform and our Services, and about products and services provided by partners who we work with in the field of entertainment, leisure and personal relationships (where provided in conjunction with our own marketing) where we legitimately believe this may be of interest to you; and
where you have specifically indicated that you would like to receive it, we may send you information from other ruby Corp. Group entities (and/or third parties);

Deliveries may be carried out by any available means, including email, SMS, MMS and other electronic channels.

We may also use information collected from your use of the Services, whether using cookies or using data analytics, as well as market research and any personal preferences you have communicated to us to tailor the advertising and communications that you receive.

If you change your mind, you can always choose to unsubscribe from receiving these marketing communications. You can do this by clicking the "unsubscribe" link on any of our emails, via "Manage Profile" or by contacting us (https://www.ashleymadison.com/app/public/contact.p).

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How will we share the information we collect?

We may share Personal Data in the following circumstances for any or more of the purposes described above:

Within the ruby Corp. Group of Companies. Praecellens Limited is a subsidiary of ruby Corp. (established in Canada). Many of the services we offer are provided in conjunction with ruby Corp. and / or its affiliates. We will share your Personal Data with other group companies as necessary to allow us to provide those services. For further information about our group entities please click here (https://www.rubylife.com/#about). Spanish users please note that "Group" is understood in the sense of article 42 of the Spanish Code of Commerce.
Promotion of your Profile – We may share your nickname or username (not your actual name) and your photo to promote your profile to other users of the Services, who may be located in any country in the world where our Services are offered. By providing us your Personal Data and using the Services, you consent to the transfer of your Personal Data to countries outside of your jurisdiction of residence consistent with the terms of this Privacy Policy.
Other Platform Members/Users – Your username, profile information and any information that you post to the Platform, including, without limitation, reviews, comments, and text will be available to, and searchable by, other users of the Platform and Services.
Other Dating Sites - If you’re a registered user of establishedmen.com, and have provided us with your consent, your profile will also be available on, and visible to users of, arrangementfinders.com.
Financial Information - In some circumstances we may require certain additional information, including but not limited to your credit card billing information. We use this financial information, including your name, address, and other information to bill you for use of our Service and products. By making a purchase, or engaging in any other kind of activity or transaction that uses financial information on the Platform, you acknowledge that we will provide your financial information to our service providers and to such third parties as we determine necessary to support and process your activities and transactions, as well as to your credit card issuer for their purposes. These third parties may include the credit card companies, data processing companies and banking institutions used to process and support your transaction or activity.
Trusted Third-Parties - We may share your information to our service providers to perform certain functions on our behalf in connection with the provision of the Services. Such third party include providers of cloud hosting services which we use to support certain elements of our business. These parties will only process your personal data under our instructions. For details of these third parties, please click here (https://www.rubylife.com/trusted_partners).
Legal Request - We may share your information to respond to law enforcement requests; or where required by applicable laws, court orders, or government regulations; or to protect against misuse or unauthorized use of our Platform; or to protect the personal safety or property of our users or the public (among other things, this means that if you provide false information or attempt to pose as someone else, information about you may be shared as part of any investigation into your actions). Please keep in mind that the laws, authorities and third parties referred to above may include the laws of the European Union or other territories where ruby Corp. Group entities are based from time to time.
Sale or Merger - We may share your information in connection with the sale, assignment, bankruptcy proceeding or other transfer of the business or a portion of the business of our Platform, including a corporate merger, consolidation, restructuring, sale of assets or other corporate change of our direct or indirect parent companies that affects us. In connection with the due diligence review involving such a potential transaction, we also may share information (including Personal Data) with potential acquirers, merger partners or investors, and their agents (including professionals) where such individuals agree to use Personal Data under the same conditions as identified in this Privacy Policy.
Affiliate Entities - We may share our data, including your Personal Data, with our parent, subsidiary and other affiliated companies, including companies operating in different countries (each an "Affiliate") that are committed to serving your online needs and related services. Except where otherwise prohibited by applicable law, our Affiliates may use this data to communicate with you about their products and services. Our Affiliates will follow privacy practices no less protective of all users than our practices described in this document, to the extent allowed by applicable law. It is possible that we or one or more of our Affiliates, or any combination of such, could merge with or be acquired by another business entity.

We may share Anonymous Data in a number of circumstances including to third party advertisers.

By providing us with your personal information, you expressly acknowledge that we transfer your Personal Data to third parties as set forth herein for the purposes set forth in the “How will we use the information we collect” section.

Data Transfers

You understand that by using the Services, your Personal Data will be transferred to recipients located in jurisdictions outside your jurisdiction of residence, and that your profile will be accessible by users all over the world. If you are concerned about this, you can stop using our Services at any time.

These recipients include ruby Corp. (which is established in Canada) and many of our service providers who are based in other countries. As a result, your Personal Data will be used, stored and/or accessed in countries outside your jurisdiction of residence, including without limitation Canada and Cyprus. Some of these jurisdictions do not have an equivalent level of data protection laws as those in your country. Whenever we transfer your data outside of the EEA or your country, appropriate safeguards will be put in place to ensure an adequate level of protection, in compliance with applicable data protection laws.

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Security

We take the protection of your Personal Data seriously. We protect Personal Data against loss and theft as well as unauthorized access, disclosure, copying, use, and modification using security safeguards, including physical, organization and technological measures, commensurate with the sensitivity of your Personal Data. Employees who have access to your information are made aware of the importance of keeping it confidential.

Where we use service providers who might have access to your Personal Data, we require them to have privacy and security standards that are comparable to ours. We use contracts and other measures with our service providers to maintain the confidentiality and security of your Personal Data and to prevent it from being used for any other purpose.

Please be aware that no data security measures can guarantee 100% security. You should also take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity, except where this is imputable to us.

How long do we keep the Personal Data we collect?

We keep your Personal Data for as long as we need your Personal Data for the purposes for which it was collected or as otherwise permitted by applicable law after which we delete or anonymize your Personal Data rendering it unable to identify you.

Access and Updates

You have the right to (i) opt-out of certain communications and (ii) access, modify, update, or cancel/ erase certain Personal Data held by us. You can also exercise your rights of access, rectification or cancel/ erasure by contacting us using the Contact Form. You can also request an electronic copy of your personal data be sent to you, or to another organization should you wish.

Please note that you can hide certain information visible to public users of the Platform at any time by going to the 'Manage Profile' or ‘Account Settings' sections on your profile.

Where we rely on consent to process your personal data, you may withdraw your consent to our use of your Personal Data at any time.

You may also object, for legitimate reasons, to the processing of your Personal Data. To exercise your rights, please use the Contact Form.

Please be aware that it may take several hours for any custom changes you make to take effect on the public areas of the system. Please also note that changing or deleting your information through the 'Manage Profile' or 'Message Center' section of the system, or opting-out of email notifications from us, will only change or delete the data in our database for the purpose of future activities and communications.

Do you monitor online behavior?

Our users communicate with each other through on-site mail messaging and instant messaging. We do not moderate or monitor users' private exchanges, except to the extent permitted by applicable law where we suspect users of being under the age of 18 or of using our service for the purpose of solicitation or any other violation of our Terms & Conditions or Privacy Policy. Submissions that appear on the public area of the Platform are moderated and, if necessary, we reserve the right to edit, delete, remove or not use any communication on a public area of the Platform.

All such Personal Data will be protected in accordance with applicable national law and this Privacy Policy. In particular, we will ensure an adequate level of protection for any personal data provided to third parties and Affiliate entities.

Please note that when your Personal Data is located outside your jurisdiction of residence it will be subject to the laws of the country in which it is situated: and these jurisdictions include territories such as the US which do not have an equivalent level of data protection laws as those in your country, and which are not considered by the European Commission or the laws of your country to offer an adequate level of protection. Whenever we transfer your data outside of the EEA or your country, appropriate safeguards will be put in place to ensure an adequate level of protection, in compliance with applicable data protection laws.

Changes to this Privacy Policy

This Privacy Policy is current as of the Effective Date set forth above. We may update this Policy from time to time, so please be sure to check back periodically. In the event we intend to materially change any of our practices set out in this Privacy Policy, including if we intend to use your Personal Information for any purpose not expressly contemplated herein, we will provide you a minimum of thirty (30) days prior written notice of such change and obtain your consent to the extent required under applicable law.

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Contact Us / Complaints

You have the right to access Personal Data we hold about you and to have any concerns you may have over our policies and practices addressed. In addition, you have the right to obtain information regarding our policies and practices as they relate to the collection, use and sharing of Personal Data, including those with respect to the transfer and storage of your information outside your jurisdiction of residence, and update your Personal Data.

If you have any questions related to the foregoing or any of the terms or conditions of this Privacy Policy, or if you wish complain to us in writing about how we have handled your Personal Data, please feel free to contact us using the Contact Form. All other inquiries should be sent using our Contact Us section.

You can also contact our Data Protection Officer by email at [email protected] or by writing to Praecellence Limited, 9 Karpenesiou Street, 2021 Nicosia, Cyprus.

We aim to resolve all complaints promptly.

If you are unhappy about how we are processing your data or how we have responded to a request or complaint, you have the right to make a complaint to the Cypriot data protection regulator, the Commissioner for Personal Data Protection, details for whom can be found here: http://www.dataprotection.gov.cy/

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