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Gay Twink Dating cares about your privacy!
Sharing private details about yourself and the kind of match you are seeking is a core part of joining and participating in an online dating site or app. We appreciate that you entrust us with this data, and we take your privacy very seriously. For this reason, we have decided to dispense with the technical jargon as much as possible and communicate our privacy practices to you in a very clear and concise way. We hope you take some time to read through this policy, and please reach out to us if there you have any further questions about how we collect, store and process your personal information.
In order to provide the dating and social networking function of the Gay Twink Dating website and mobile application (the "Site"), it is necessary that we (Elite Marketing Solutions Inc. or ODS Online Dating Systems LTD , depending on your location) need to process your personal information. By accepting this policy and creating an account with the Site you are confirming that you have read and understand this policy, including how and why we use your information. If you don't want us to collect or process your personal information in the ways described in this policy, you must not use the Site. Please be aware that while we impose certain use restrictions in our Terms and Conditions, we are not and cannot be responsible for any user or third party's(ies') use of information you may determine to share through the Site, whether through your profile, chat, direct message or otherwise. This Policy applies to any information you provide to us, including through this website, our mobile applications, and communications by email.
Effective Date: May 25, 2018
This Policy may change over time, as we are constantly striving to provide you the best possible experience on site, and also completely safeguard your information in our system. Please be sure to check back over time to see any changes we make to the policy.
Your options for contacting us
The easiest and quickest way to contact us is by using our online CONTACT PAGE.
If you wish to contact us by post, please write to:
Elite Marketing Solutions
Attn: Data Protection Officer
6919 W. Broward Blvd. #270
Plantation, FL 33317
1. About our Company
Elite Marketing Solutions Inc.
Charges appear as: ELITEBILL.COM
PO BOX 12187
Zephyr Cove, NV 89448
ODS Online Dating Systems LTD
Charges appear as: ODSHELPDESK.COM
Dimokratias 31, 2nd Floor, Office 201
2. Who can we collect data from?
Use of the Site is restricted to only those adults that are 18 years of age and older. We never knowingly collect, store, or process data from users under the age of 18. If you suspect a user on the Site to be under the age of 18, please use the reporting option inside the Site to let us know as soon as possible.
3. Data that we collect and process.
The purpose of you joining here is to find new and meaningful connections with other members, and we can’t help you do that without getting some data both about you and the type of person you are seeking. Also, through your everyday activities on the Site, we will collect further information about your usage and the usage of members around you, in the hopes of facilitating a connection. We will go into some more detail about the data we collect and process below.
Information and data that you give to us:
- When you create a profile and account, you supply some details that are necessary to uniquely identify yourself and allow you to access the site in future sessions. This includes data like your email address, username, password, age, location and gender.
- After creating your profile, you have the option to share additional information about yourself in the hopes of attracting the type of people with whom you wish to match. This data includes things like your personality, physical appearance, hobbies and interests, and entertainment preferences. You also have the option of adding photos to your profile, sometimes allowing us access to your mobile device to upload them. Some of the data you can optionally provide to us may be considered special or sensitive in some jurisdictions, such as your political affiliation, ethnicity, religion or sexual preference. Providing this information is completely optional, and by providing any of it you consent to our processing of this data.
- If you choose to upgrade your account to Premium status on our website (and not one of our mobile applications, which are billed by the app stores themselves), you will need to provide us or one of our payment service providers with payment data such as your debit/credit card number or other financial data. Sensitive payment data such as this is not stored by us indefinitely, but rather kept with our payment partners, who are fully certified to securely store this information for possible future purchases and rebills.
- If you contact our customer service team, either by our contact form, email, live chat or phone, a record is kept of your interaction in order to better service your account.
- We store preferences that you supply us for your account settings, such as which types of email communication you prefer to receive, your billing status and history, which types of members can contact you, and your internal notification feed options. We also keep a record of the last member search you performed as your default search, and you can save specific common searches you want to perform often for your convenience.
- We store and process your communications with other members, including flirts and messages sent to and from these members. This includes other Site communication and connection features, like our Icebreaker and Rapid Match..
Information supplied to us by others:
- It may be possible to use your account data from certain social media sites, like Facebook Login, in order to create a profile and login to the Site. You may also optionally share photos from these services to your account here.
- From time to time, we may receive information about you from other users, such as complaints about account abuse or spam. We investigate these matters seriously, and reserve the right to store this data for further use, or to delete it if we find the claims to be baseless.
- Sometimes, our partners will offer to create your profile on the Site using information they have about your account on their own website or application. This method of account creation is always done on an explicitly opt-in basis (i.e. you must tell our partner site you want to create a profile on the Site). We collect, store and process this data with the same security and care we do for data you supply us directly.
Information and data collected as you use the website:
- Each time you log in and use our the Site, we collect data and information about your visit. This includes data like the date and time of your use, how long you spend on the Site, the IP you connected from, your location at the time of connection, advertisements you interact with, and other profiles you visited. This may include information on the device you use to connect to the site, its identification number and any software used.
- We employ the use of a data analytics service, specifically Google Analytics, to track certain non-personally identifiable pieces of data about your visits, such as your device type, how you reached the site, your location and browser language. This data is not stored by us, but rather collected using software we have installed on the Site and then stored by this analytics service and used by us to help us improve your experience on the Site. If you wish to opt out of making your data available to the Site, please visit THIS page.
4. Cookies, web beacons, pixels, and other data collection technology.
We employ the use of technology like cookies, web beacons and pixels in order recognize you and the devices you use to access the Site. We do this for several reasons, including authentication on future visits, keeping track of your preferences and settings, and helping to show you more relevant advertising and offers. Depending on your web browser and other software you have installed, you may be able to better control how we use these technologies. “Do Not Track” (or “DNT”) is a feature on certain web browsers that you may use to access the Site, whereby users can activate this setting to tell responding websites they do not wish to be tracked. Not all browsers offer this “DNT” option, and not all of these signals are currently uniform, so the Site does not yet respond to these signals.
5. How we process the data and information we collect about you.
We only collect and store data about you that we feel is absolutely necessary. Here are the reasons why we collect that data, and how we use it:
- To manage your account and profile and help you meet your dating goals. This includes setting up your account and profile, giving you support when needed, processing your payments, and helping you to find the types of members you are seeking.
- To show you relevant advertisements, as well as offers to join trusted partner dating sites quickly and easily. This includes ads you see inside the Site, as well as offers we may send you by email.
- To detect and prevent fraudulent activity on the Site. We use data from all members with an internally developed fraud detection system in order to detect and eliminate bad actors from the Site. This is for the protection of all our members using the Site with good intentions.
- To be sure we are compliant with all legal requirements in all our operating jurisdictions. From time to time, this includes providing law enforcement with information they officially request from our records.
- As we operate in many different countries, sometimes data needs to be transferred across borders, such as when a citizen of the European Union joins a site that we operate from the United States. We have worked to become compliant with the new EU General Data Protection Regulation (GDPR) in this situation, and as such use suitable safeguards for the transmission of this data.
6. How we share data and information with other partners, including third parties.
- First and foremost, by creating your profile and sharing information about yourself, you are in turn sharing that information with other users on the Site. As we cannot control what other users do with the data you share, please only add information to your profile that you are comfortable sharing with the public. In your settings on the Site, you will find options to limit which members can and cannot send you messages.
- Sensitive personal data like your supplied gender will help other users find you. Your gender seeking preference(s) will be used to help identify other users that may be of interest to you.
- Sometimes it is necessary to share data with trusted third-party service providers and vendors. Some examples of this would be our payment service providers, in order to facilitate payments for Premium access, and our email validation service, which lets us know if you provided us with a valid email address. We will never sell your personal data to a third party for purposes of monetization. We take much care in ensuring that our few data partners follow best practices for safeguarding data, and encourage you to reach out to our customer care team if you have any questions regarding this.
- In some cases, we make your profile visible on other brands within our network of dating websites and applications. These are simply brand extensions of the Site, with the same database of users on each of these other websites and applications. This is only done for marketing purposes, usually to account for differences in terminology for certain interests in different locations.
- With your explicit permission, we will sometimes share the information you have provided us with other websites or applications that are wholly owned by our company, in order to set up a profile on that website or application for you. This is to give you the best possible chance to make a meaningful connection and enlarge your dating pool in other similar-niche websites and applications. We ONLY do this with your express consent and instruction, such as when you opt-in at the time of profile creation, through a one-click registration offer while using the Site, or when you choose to upgrade your membership.
- We use completely internal service providers which are sometimes passed your account data. Some examples of this would be our internal fraud detection system, which helps to eliminate bad actors on our network of websites and applications, and our internal ad serving system, which uses your demographic and interest data to show you relevant advertisements on the service. In all these cases, this data is completely retained within the company and safeguarded with the same high level of care your data is on the Site.
- If we are ever involved in a merger or sale, control of your data may transfer to a new company. This will be fully disclosed to you in advance should this situation occur.
- We reserve the right to share any and all account information with law enforcement or agencies authorized by applicable governmental authorities either in response to their written request or at our own election should we believe, in our sole discretion, that you or your account may be involved with illegal activity, or if we believe, in our sole discretion, that such disclosure is necessary to protect the rights or property of the Site, our users, and/or one or more third parties.
- Sometimes, it may become necessary to share data if that disclosure could mitigate our liability in a lawsuit, either filed or threatened. This could also happen if we need to protect the legal rights of either ourselves or of our users, or to investigate or take action regarding perceived illegal activity or fraud.
7. Your rights regarding your data
The data that we collect, store and process with regards to your account you is your own, and as such you have associated rights regarding that data as detailed below.
- You have the right to add or hide data as you see fit on a self-serve basis inside your profile editing area on the Site. This will enable you to tailor exactly what others see about you at any time.
- You have the right to download an export of all the information we are currently storing in relation to your account. This is available from the Settings area of the Site.
- You have the right to configure your device settings to allow the level of access to your data that you choose, from the configuration options available on your specific device(s), browsers, etc. Please note that some configurations may not allow you full access to all our Site features.
- You typically have the right to fully delete your information from the Site and its database permanently, barring a few extenuating conditions. For more information on this, please see Section 11 below.
- In some countries and jurisdictions, including the EU, you have the right to lodge an official complaint with an applicable data protection authority. Please consult the data protection rules of your country of residence for more information about the availability of this option.
8. Use of your email for triggered notifications and promotional marketing
An important part of your membership is being notified of specific triggered events and special promotions that will maximize your chances of a successful dating experience on the Site. We use an internal email marketing system to send you these notifications as part of your membership.
- Some examples of triggered events would be notification of a matching member coming online in your area, or a nearby match uploading a new photo. In these cases, your personal information is used to match with others to generate these events and send you an email notification.
- Examples of special promotional emails may be a special introductory monthly offer at a steeply discounted price, or a discounted trial offer based on an action you previously attempted that requires Premium membership. The type of promotion sent determines which personal information is processed to generate the email.
- You can select exactly what kind of emails you receive from us at any time inside your Settings on the Site. We store your preferences there until you tell us you want to change them again. Also, you can choose to stop receiving all emails from us by using the Unsubscribe link that is embedded in every email that we send you.
9. Specific rights for residents of the State of California
California residents are entitled to be disclosed a list of third parties to whom their data has been shared for direct marketing purposes over the previous year. Currently, we do not share any customer data with third parties for direct marketing purposes. If that policy was to change, we will update this section with instructions on how to obtain that information.
If you are a California resident and wish to exercise your rights under the California Consumer Privacy Act (CCPA), please contact us using one of the contact methods shown below.
Personal Information Sales Opt-Out and Opt-In Rights. You have the right to direct us to not sell your personal information at any time (the right to opt out). Consumers who opt-in to personal information sales may opt-out of future sales at any time. To exercise the right to opt-out you may submit a request to us by reaching out to our Customer Support via the Contact page. If your location on profile matches California, you will be able to see on website's homepage footer Do Not Sell My Personal Information link that will lead you to the requested page. Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales and personalized ads at any time by editing preferences on you data panel. Site visitors who do not have an account are not served advertisements, and as such will only need to opt out of targeted advertisements if they decide to create an account.
In some cases, we may be unable to fulfill your request because we have no way to verify your identity to the standard the law and/or its associated regulations require. For example (but without limitation), if you have visited our website, but never registered, left a comment, submitted a Contact Form, completed a financial transaction with us, or interacted with us via email or other means, we probably do not have enough information to confirm your identity to even a “reasonable degree of certainty” (as the applicable regulations may define that term). Also, in addition to any other exemptions applicable law and/or regulation may provide to your rights under the CCPA (particularly with regard to the deletion of your personal information), we may be unable to delete certain information (e.g., our web host’s server, caching and error logs) for technical reasons.
10. Specific right for residents of the country of Brazil
The Lei Geral de Proteção de Dados (LGPD) is a new Brazilian privacy law that is going into effect from August 16th, 2020. It applies to the processing of personal data, which can include online identifiers, of users located in Brazil. We are committed to supporting our partners as they work to comply with this regulation. The LGPD shares many concepts with the European General Data Protection Regulation (GDPR) and our services already provide features that customers can use to support their LGPD compliance efforts, including the ability to serve non-personalized ads to users regarding data processing based on a user's geographic location. Our status under the LGPD as either a controller or processor will be the same as under the GDPR. The LGPD terms will be incorporated into our existing data protection terms, so no action is required to accept the LGPD terms where the existing data protection terms already form part of your consent.
11. Protection for your personal data and information
Protecting the data that you entrust to us is extremely important, and we are constantly striving to ensure that it is safeguarded from harm at all times. However, like at any technology company, there is always risk of unauthorized access or destruction of this data. We employ both security experts and automated protocols that are constantly analyzing our systems for any signs of intrusion or attack, and have processes in place in case of any unauthorized access, including those mandated by certain jurisdictions (such as the EU in the case of the aforementioned GDPR). At our discretion, we may suspend usage of the Site pending investigation into a suspected breach. We also encourage you to reach out to our customer care team immediately if you feel that you or any other account on the Site has been compromised.
12. Retention and Deletion of your data
Dating and relationships are a personal exercise for each person, and as such people tend to use our dating site at different times throughout their dating lives. For your convenience, we retain your personal information until such time as you advise us to discontinue doing so. This data will also be retained to service your account, develop new services and products related to the Service, and as otherwise provided in this Policy. Our data retention policy may be amended from time to time.
If you wish to completely remove all of your data on the Site, that option is available by utilizing our CONTACT PAGE to advise our customer care team of your request. Please be advised that in some instances, such as compliance with applicable laws, or in order to police fraud on our site more effectively, we may not be able to completely comply with your request. We will advise you upon your request if this is the case, and let you know the reason we cannot fully comply, as well as which data points we will need to retain. Please also note that while data may be fully and permanently erased from production (live) servers quickly, you should allow up to 30 days for data stored on backup servers to be fully deleted.