This Privacy Policy (the "Policy") applies to all websites (the "FFN Website(s)") FriendFinder Networks Inc. and its subsidiaries (collectively, "FFN", "us", "we").
We understand that the privacy of its members, subscribers, guests and/or visitors (collectively, "Members", "you" or "your") is very important. We developed this Policy to ensure that your privacy is protected while using any of the FFN Websites or services.
1. How We Collect, Use and Disclose Information
What Information Do We Collect?
During the registration process for, or while using, any of the FFN Websites, you may choose to provide us with certain "Personal Information" including:
When we refer to "Personal Information" in this Policy, unless we say otherwise, this includes "Sensitive Personal Information."
We may also collect information about your activities or postings on FFN Website when you choose to send us personal correspondence such as emails or letters or when other FFN Website users or third parties send us correspondence, which may include their comments about you. All this information will be kept in a file that is accessed only by authorized FFN personnel or representatives.
On some of the FFN Websites, you may choose to use our referral service to tell a friend or friends about us. In this case, we will ask you for your friend's name and email address and email your friend an invite to him or her to visit an FFN Website.
Providing your Personal Information to us is voluntary. However, if you do not provide your Personal Information to us, you will not be able to access some or all of our services.
How do We Use Your Information?
When you provide Personal Information to us, we will use it to contact you about our services, to process payment for our services, and to tailor our services to your meet your preferences.
We use your Personal Information for many specific purposes, including:
If you have provided us with certain Personal Information, we will also use it to facilitate your communication with other members, for example, by the use of the message center or delivery of "Cupid Reports" or "Ice Breakers".
We may also use your Personal Information to resolve disputes, troubleshoot problems, enforce any agreements, policies and rules governing the use of FFN Websites, and observe the FFN Websites for quality control and customer service purposes.
If you use our referral services, we will use your friend's name and email address only to send an invitation and to track the status of the referral. Your friend(s) may use the unsubscribe function in the email or contact us at [email protected] to request that we remove their email address from our records.
When and to Whom Will We Disclose Your Information?
Due to the nature of many of the services provided by the FFN Websites, certain of your Personal Information will be disclosed to other Members. As an example, if you complete a "dating" profile and choose to disclose your religious affiliation or ethnic origin, this information will be available to other Members using the services on the applicable FFN Website. By providing this type of profile information to us, you have consented to the use and disclosure of your Personal Information in this manner.
We may share or transfer your Personal Information with our subsidiaries operating other FFN Websites so that they can send you information about their products or services that you may be interested in.
We also disclose Personal Information to our service providers (for example, credit card processing companies, billing services) as reasonably necessary or appropriate to provide services on the FFN Websites. Our service providers are legally required by us to protect your Personal Information. Because many of the FFN Websites operate or use service providers located in different countries, your Personal Information may be transferred to a country in which you do not reside, and while in that foreign country, may be accessible to its law enforcement authorities.
We may be required to disclose your Personal Information in order to comply with a court order, subpoena, search warrant, or a lawful request by public authorities, including to meet national security or law enforcement requirements. In addition, we expressly reserve the right to disclose your Personal Information when we have a good faith belief that disclosure is necessary to protect our rights, to enforce our agreements, policies, and rules governing your use of the FFN Websites, and/or to report information concerning a threat of serious injury or death.
We DO NOT sell or rent any of your Personal Information to third parties for marketing purposes without your express permission or consent. We may, however, disclose to third-party advertisers certain aggregated or hashed (i.e., encrypted) information in a manner that no longer reflects or references an individually identifiable user, for other marketing and promotional purposes.
When you provide your Personal Information and Sensitive Personal Information to us, you consent to our use and disclosure of that information as described in this Policy. If you do not want us to use or disclose your Personal Information as described in this Policy, do not provide it to us. We note that this may result in you being unable to access some or all of our services.
2. Our Use of Cookies and Your Options; Pixel Tags; Do-Not Track
FFN Websites use "cookies" to store and sometimes track information to make your online experience easier and more personalized.
Cookies are small pieces of data that are stored by a user's web browser on the user's storage drive. Cookies may record information that is accessed by a user on a webpage in order to simplify subsequent interactions with that website by the same user, or to streamline the user's transactions on related webpages. Cookies make it easier for a user to move from webpage to webpage and to complete transactions over the Internet.
Most major web browsers are set up so that they will initially accept cookies, but you may modify your computer's preferences to issue you an alert when a cookie is downloaded, or to disable the ability of third parties to download a cookie to you. If you choose to reject all cookies, there are areas of FFN Websites that may not function properly. You may obtain further information about cookies and how they function at: https://en.wikipedia.org/wiki/HTTP_cookie.
We, or a data provider or advertiser that we have engaged, may also place or recognize a cookie on your browser to enable you to receive customized ads or content. These cookies contain no Personal Information. The cookies may reflect de-identified demographic or other data that is linked to data that you have voluntarily have submitted to us (e.g., your email address) that we may share with the data provider or advertiser solely in a hashed (i.e., non-human readable) format. To opt-out of these cookies or to learn more about them, please go to https://www.aboutads.info/choices.
We may also use standard Internet technology, such as web beacons or 1x1 "gifs" and other similar technologies (collectively "Pixel Tags"). A Pixel Tag is an electronic image, often a single pixel (1x1), that is ordinarily not visible to Members and may be associated with cookies on the Members' storage drives. We use Pixel Tags to track your use of the FFN Websites, for advertising, marketing, or promotional purposes, and to determine whether you opened an email message from us. The information also enables us to customize the services we offer.
Other parties may collect Personal Information about your online activities over time and across different websites when you use FFN Services. We honor web browser "do not track" signals that provide you with the ability to exercise choice regarding the collection of Personal Information about your online activities over time and across third-party websites or online services, when the web browser's http header includes the field "dnt:1". We do not presently honor any other types of "Do Not Track" mechanism.
3. Collection, Use and Disclosure of Personal Information by Third Parties
This Policy only addresses the use and disclosure of Personal Information that we collect from you. To the extent that you disclose your Personal Information to others while using the FFN Websites or other websites throughout the internet, different rules may apply to its use, maintenance, or disclosure. FFN does not control the privacy policies of third parties, and you are subject to the privacy policies or practices of those third parties.
4. Your Use of FFN Websites' Members' Information
You may not use another FFN Websites' Members' information, whether private or not, for commercial purposes, to spam, to harass, or to make unlawful threats. We reserve the right to terminate those who misuse other Members' information or who otherwise violate any user agreements, policies, or rules governing the use of any FFN Website.
5. A Special Note About Children.
Children under eighteen years of age are prohibited from using the FFN Websites or services. We ask that children not submit information to us.
6. Do Not Disclose Your Personal Information or Password.
Please DO NOT post, share or disclose in public forums (e.g., chat rooms, blogs) any Personal Information that you do not wish other Members to know. We encourage you to ask questions before you disclose your Personal Information to others. Similarly, you should never disclose or share your password with anyone else. If you lose control of your password, you may lose substantial control over your Personal Information and may be subject to legally binding actions taken on your behalf. If your password has been compromised for any reason, you should immediately change your password and/or contact us at: [email protected].
7. How We Protect Your Information
FFN Websites use reasonable security measures to help protect and prevent the loss, misuse, and alteration of the information under our control. We use industry standard efforts, such as firewalls, to safeguard your Personal Information. While "perfect security" does not exist on the Internet, or elsewhere, our technical staff works hard to help ensure your secure use of our services.
FFN is located in the United States. If you are visiting any of the FFN Websites from outside the United States, you must be aware that your Personal Information may be transferred to, stored, and processed in the United States or other countries in which FFN or its service providers are located. The data protection and other laws of the United States and these other countries might not be as comprehensive as those in your country, and your Personal Information may be accessible to law enforcement authorities in the United States or of other countries.
When you use the FFN Websites, you consent to us transferring your Personal Information (which includes, for the avoidance of doubt, your Sensitive Personal Information) from your country to the United States or countries in which the FFN or its service providers are located for the purposes described in this Policy.
9. Reviewing, Updating, Accessing or Removing Your Personal Information and Registering Privacy-Related Complaints
Once you register, you will be able to review and change much of your Personal Information including:
Please promptly update your information by logging in to your account and following the screen prompts. We strongly urge you to change your password periodically to help reduce the risk of unauthorized access to your account information.
You have the right to ask in writing whether we hold any Personal Information about you, and to see that information as well as how we collect, use or disclose your Personal Information. We note that we may not be able to provide you with all of the information you request, depending on the circumstances (e.g., if it contains the Personal Information of other Members). There may be a charge for any copy of Personal Information requested.
Upon your request, we will remove your credit card number, credit card expiration date and other Personal Information from our main databases. We note that, despite your request, we may retain in our files certain data (including credit card information) if necessary to:
We note that despite our best efforts to remove information from our database on your request, removed information may exist in backup copies or other users' caches. As an example, an information exchange with another Member may remain in that Member's e-mail boxes, computer caches, or instant message archive. Whether your exchanged information is kept by another Member is beyond the control of FFN.
You will be able to update, modify and delete some of your Personal Information by logging in with your password and modifying or deleting your profile. For all other requests to access, update, modify or delete your Personal Information, please:
You are entitled to contact us using the above contact information to register a privacy-related complaint. We will explain our complaint procedure to you and investigate all complaints. If a complaint is justified, we will take all appropriate steps to set the situation right. We will also let you know what other complaint procedures may be available to you.
11. Revisions to this Privacy Policy
We reserve our right, in our sole and absolute discretion, to revise, amend, modify or revoke this Privacy Policy at any time, and in any manner to the fullest extent permitted by law. If the changes are significant, we will provide a more prominent notice. Changes to this Policy will be effective by posting revisions on the FFN Websites.
(This section is effective on May 25, 2018)
This section applies to data processing activities of data subjects residing in the European Economic Area as well as, regardless of residence, to the processing of any Personal Data in the European Economic Area. To the extent there is any conflict between the Specific Disclosures for the European Economic Area and any other part of the Privacy Policy or Terms of Use, this section shall control.
For purposes of this section, the following definitions apply:
1. Legal Basis for Processing
We collect and process your Personal Data for a variety of different purposes which are set out in further detail in this section.
In some cases, we will ask for your consent so that we may process your Personal Data. However, in certain circumstances, applicable data protection laws allow us to process your Personal Data without needing to obtain your consent.
1.1. CONSENT FOR PROCESSING SENSITIVE PERSONAL DATA
We obtain your explicit consent to process your Sensitive Personal Data. Certain Sites may require this data to provide the Services. Please note that, if you choose not to provide Sensitive Personal Data, certain features or Services may be unavailable or not function properly.
In certain limited circumstances, we may process or otherwise disclose your Sensitive Personal Data without your consent to protect the vital interests of you or of another person where the data subject is physically or legally incapable of giving consent, or where it is necessary to establish, exercise, or defend legal claims, including to comply with law enforcement or other legal or judicial orders or requests for such purposes.
1.2. CONSENT FOR PROCESSING NON-SENSITIVE PERSONAL DATA
In cases where we are not already authorized to process the Personal Data under applicable law, we may ask for your consent to process your non-Sensitive Personal Data, including:
1.3. PROCESSING PERSONAL DATA WHERE CONSENT NOT REQUIRED
In certain cases where we are not processing Sensitive Personal Data, separate consent may not be required, including:
2. WITHDRAWING YOUR CONSENT
You may at any time withdraw the consent you provide for the processing of your Personal Data or Sensitive Personal Data for the purposes set forth in this Privacy Notice by contacting us here, provided that we are not required by applicable law or professional standards to retain such information.
If you want to stop receiving future marketing messages and materials, you can do so by clicking the “unsubscribe” link included in our email marketing messages or by contacting us at here.
3. DATA SUBJECT RIGHTS
You have the right in certain circumstances to request confirmation from us as to whether or not we are processing your Personal Data. Where we are processing your Personal Data, you also have the right to request access to, modification of, or deletion of such Personal Data.
You also have the right in certain circumstances to receive the Personal Data concerning you that you provided to us, to restrict processing of your Personal Data, or to transmit such data to another controller.
To exercise your rights with respect to your Personal Data, please contact us at here. As permitted by law, certain data elements may not be subject to access, modification, portability, restriction, and/or deletion. Furthermore, where permissible, we may charge for this service. We will respond to reasonable requests as soon as practicable and as required by law.
4. DE-IDENTIFIED OR ANONYMIZED DATA
We may create de-identified or anonymous data from Personal Data by removing data components (such as your name, email address, or linkable tracking ID) that makes the data personally identifiable to you or through obfuscation or through other means. Our use of anonymized data is not subject to this Privacy Notice.
5. DATA RETENTION
We will retain your Personal Data for as long as long as you maintain an account or subscription agreement or as otherwise necessary to provide you the Services. We will also retain your Personal Data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
6. RIGHT TO LODGE A COMPLAINT WITH A SUPERVISORY AUTHORITY
You may have a right to lodge a complaint with a supervisory authority.
7. CONTACT US
For questions regarding this Privacy Notice, please contact us at: here.
FRIENDFINDER NETWORKS INC. PRIVACY POLICY Effective on: May 24, 2018
Click here to view the December 8, 2016 version of the FFN Privacy Policy.