Data Privacy Statement for the EliteSingles App
As of August 2015
Finding a suitable partner for you requires gathering, processing, and using personal data. Since we are serious about our business as a matchmaking service, responsible use and protection of your data is close to our heart.
At this point, we would like to explain which personal data we process, for what purpose, and in what form, if you use our EliteSingles dating app on your mobile device.
Table of Contents
1. Protection of Your Personal Data
2. Collection, Processing, and Use of Data
2.1 Data Collection When Downloading and Installing the App
2.2 Data Collection When Using the App without Registering
2.3 Data Collection When Registering and Using the App
3. Data Collection and Processing When Using Specific Features
3.1 Messaging
3.2 Profile Visitors
3.3 Partner Suggestions
3.4 The “Like” Function
3.5 Push Notifications
4.1 Android Operating System (various manufacturers, e.g. Samsung, HTC, Sony, LG)
4.1.1 Reading Phone Status and Identity
4.1.2 Recording Pictures and Videos
4.1.3 Changing, Deleting, or Reading Contents of your USB Memory Device
4.1.4 Finding Accounts on the Device
4.1.5 Full Network Access and Obtaining Internet Data
4.1.6 Viewing Network Connections
4.1.7 Accessing Running Applications
4.1.8 Other Authorisations
4.2 iOS Operating System (e.g., Apple iPhone and iPad)
4.2.1 Notifications / Push Notifications
4.2.2 Access to the Camera
4.2.3 Access to Stored Photos
5. Configuring Push Notifications
5.1 Android Operating System (various manufacturers, e.g. Samsung, HTC, Sony, LG)
5.2 iOS Operating System (e.g., Apple iPhone and iPad)
1. Protection of Your Personal Data
EliteSingles is a reputable Internet portal that helps you to find the right partner for you.
The EliteSingles dating app is operated by Spark Networks Services GmbH, Kohlfurter Straße 41/43, 10999 Berlin. Spark Networks Services GmbH is the responsible entity for purposes of the German Federal Data Protection Act.
The privacy of your personal data is very important to us. We follow the strict provisions of German and European data protection laws. The purpose of the Federal Data Protection Act (BDSG) and of the Telemedia Act (TMG) is the protection of what is called personal data. This includes data that can be linked to a person (e.g., a name or an email address). Information that cannot be linked to a specific or ascertainable person, or that can be linked to a person only with a disproportionately large expenditure of time, cost, and work, are categorised as anonymous data.
In order to offer the service to its customers, EliteSingles collects, processes, or uses (“utilises”) personal data. In the context of legal provisions, we can evaluate profiles under a pseudonym for purposes of advertising, market research, and improving our services. But this is only if you not have made use of your legal right to object to this use of your data at any time.
If you have questions or concerns regarding data privacy, our customer service is always available. It can be reached at:
Spark Networks Services GmbH
– EliteSingles Customer Service –
Kohlfurter Straße 41/43
10999 Berlin
Email: [email protected]
2. Collection, Processing, and Use of Data
EliteSingles is a legitimate online partner-mediation offering that uses a scientifically based matching procedure to bring people together who are looking for a long-term relationship. To provide this service, we utilise a number of personal details from you. In many cases data is only utilised with pseudonyms or made anonymous. We would like to inform you about the relevant details below.
2.1. Data Collection When Downloading and Installing the App
In order to download and install our app from an app store (for example, Google Play, Apple AppStore), you need to first register with the provider of the respective app stores for a user account and conclude a corresponding user contract. We have no influence on this, and we are not a party to such a user contract. When downloading and installing the app, the information necessary for this is sent to the respective app store, in particular your user name, your email address, the customer number for your account, the time of the download, the payment information, and the individual device code. We have no influence on this data collection and are not responsible for it. We process the supplied data only, and to the extent that it is needed for downloading and installing the app on your mobile device (for example, a smart phone or tablet). In addition, the data is not stored afterwards.
2.2. Data Collection When Using the App without Registering
When the app is in use, we capture the following technical data to enable its functions; it is gathered automatically by your mobile device and sent to us:
• device information
• device code (unique Spark ID)
• information about the operating system
• Spark Unique Device Identifier (UDID)
• the Apple iOS Identifier for Advertisers (IDFA)
This data is used by us for troubleshooting, and evaluated anonymously for statistical purposes, in order to optimise our offering.
2.3. Data Collection When Registering and Using the App
If you want to use the offering described in more detail in EliteSingles’ General Terms and Conditions, we need some personal information from you that will be collected within the context of registration. Registration through the app is not possible at the present time – when you select “register now for free,” you will be redirected instead to the EliteSingles website. For more information about data processing on the website, please see the website’s data privacy statement.
After registering, when you log in to the app you can send messages to other EliteSingles participants, view partner suggestions, or upload photos. Some features are reserved for Premium members. When you use the app with registration, we collect the data that you provide us with (for example, by filling in the corresponding fields or activating a check box). This involves, for example, data like:
• user ID on the EliteSingles platform
• message contents
• interactions with other participants (e.g., likes or smiles)
• uploaded photos
3. Data Collection and Processing When Using Specific Features
3.1. Messaging
Other members can write messages to you. But EliteSingles does not give out your email address. Messages are delivered only through your EliteSingles mailbox. You can “block” undesired persons so that they can no longer contact you.
3.2. Profile Visitors
Other members can see when you have visited their profile page. By the same token, you also see which members have visited your profile. This feature within the app is available only to Premium members. Premium members can also view the photos you upload on EliteSingles.
3.3. Partner Suggestions
Your profile, including your profile details and uploaded photos, will be suggested to other members by our matching process. You will likewise receive partner suggestions. With the settings in your user account on the website, you can decide whether or not to continue being suggested and thus displayed to other members through our matching process. You can find further information on this in the data privacy statement for our website.
3.4. The “Like” Function
Within the profiles of other members, there are “like” buttons that can be clicked. Using the “like” feature, with a click you can make it clear that you like statements or photos in another member’s profile. As a result, the other member will be notified about this.
3.5. Push Notifications
The app notifies you of certain events or topics, such as messages or smiles from other users, even if you are not actively using the app.
To provide the push-notification feature, we use the Apple push notification service (iOS) or the Google CD2M service (Android). These services are part of the standard functionality of the mobile operating systems of Apple (iOS) and Google (Android), and can be configured in the device’s system settings. For push notifications to work on your mobile device, we need to collect the unique Device Token ID (iOS) or registration ID (Android) that is generated automatically with app use on your device by Apple or Google. The ID is used to identify the correct recipient – analogous to an email address or phone number. We find out your ID only if you give the app permission to display push notifications. To display push notifications on your mobile device, we send the contents of the message together with your ID in encrypted form to Apple or Google. They in turn use your ID to forward the message encrypted to your mobile device.
If you do not want this feature of the app, you can disable it in your device settings. For more information about push notifications and your configuration options, see section 5.
4. Requested Authorisations
For some functions, the app must be able to access certain services and data on your mobile device. Depending on which mobile operating system you use, this partly requires your explicit permission for access.
Separated below by the mobile operating systems for which we offer the app, we explain what permissions are requested and for what kinds of functions these permissions are needed.
4.1. Android Operating System (various manufacturers, e.g. Samsung, HTC, Sony, LG)
4.1.1. Reading Phone Status and Identity
During installation, the authorisation “Read phone status and identity” is requested. With this authorisation, you allow the app to determine whether you are on a phonecall or receiving a call, in order to interrupt the app’s action. Through this function, we can recognise your device model and the version of your operating system, in order to correctly display our content.
4.1.2. Recording Pictures and Videos
During installation, the authorisation “Record pictures and videos” is requested. With this authorisation, you allow the app to access the camera so that you can click on “Upload photo” (and then select “Take photo”) in order to take pictures and to make them available to other users.
4.1.3. Changing, Deleting, or Reading Contents of Your USB Memory Device
When you install, the authorisations “Change or delete the contents of your USB memory” and “Contents of your USB memory” are requested. With these authorisations, you allow the app to access the USB storage device on your mobile device. This allows app settings (for example such as the fact that you want to receive push notifications) to be stored on the USB storage device.
4.1.4. Finding Accounts on the Device
During installation, the authorisation “Find accounts on the device” is requested. This function allows the application to retrieve a list of known accounts on the phone. This enables the app to connect with different services. This does not give the app access to your passwords.
4.1.5. Full Network Access and Obtaining Internet Data
During installation, the authorisations “Obtain internet data” and “Full network access” are requested. With these authorisations, you allow the app to automatically load content from the Internet that is supposed to be shown in the app or that is needed to access individual functions (for example, for showing partner suggestions or for viewing “My Profile”). There is no technical limitation on individual pages.
4.1.6. Viewing Network Connections
During installation, the authorisation “View network connections” is requested. With this authorisation you are allowing the app to to determine whether there is an internet connection through a WLAN network or through a mobile data connection (GRPS, 3G, LTE). This can determine whether elements inside the app may be called up as you wish.
4.1.7. Accessing Running Applications
During installation, the authorisation “Access running applications” is requested. With this authorisation, you allow the app to access information on current and recently run applications. This function is used for sending our push notifications.
4.1.8. Other Authorisations
Finally, the authorisations “Deactivate hibernation,” “Control vibration,” and “Send long broadcast” are requested. This involves technical functions that are necessary for the operation of the app. These processes do not collect or process personal data.
4.2. iOS Operating System (e.g., Apple iPhone and iPad)
4.2.1. Notifications / Push Notifications
If you answer “Yes” to the question of whether EliteSingles may send push notifications to you, then you are allowing the app use push notifications to alert you to certain events and topics. This function is active even when you have not opened the app. The alerts can take the form of tones, messages (for example, as screen banners) and/or a character symbol (an image or a digit on the app icon).
For more information about push notifications and your configuration options, see section 5.
4.2.2. Access to the Camera
If you answer the question of whether EliteSingles may access your camera with “Yes,” you’re allowing the app to access the camera in order to take photographs with the function “Take photo” (and then by selecting “Take photo”) to provide them to other users.
4.2.3. Access to Stored Photos
If you answer the question of whether EliteSingles may access your photo gallery with “Yes,” you are allowing the app to access your stored photos. You can pick photos with the function “Take photo” (followed by selecting the option “Use album photo”) and make it available to other users.
5. Configuring Push Notifications
With push notifications (in iOS also called “messages”) you can be alerted to certain events and topics (for example, messages from other users), even if you have not opened the app. For this, you have to answer the question within the app of whether EliteSingles may send you push notifications with “Yes.” You receive this request when you open the app for the first time and sign in.
You can activate or deactivate push notifications within the app. To do this, open the “Settings” menu and select the item “Push notifications.” Depending on the setting currently selected, the request is “Activate push service” or “Deactivate push service.” If you have successfully enabled push notifications or disabled them, a confirmation message is sent.
5.1. Android Operating System (various manufacturers, e.g. Samsung, HTC, Sony, LG)
With Android, you can also turn push notifications on or off in the system settings. To do this, open the “Settings” app in your device’s main menu, and there select the menu item “Apps.” There you will find an overview of all the apps that are installed on your device. Select the EliteSingles app here. You can then turn the push-notification feature on or off using the checkbox for “Show notifications.” The labels may vary slightly depending on the version of Android.
5.2. iOS Operating System (e.g., Apple iPhone and iPad)
With iOS you can also turn push notifications on or off in System Preferences. To do this, open the iOS “Settings” app and select “Notifications.” In the following menu you’ll find an overview of all apps that are installed on your device and that use a push-notification function. Select the EliteSingles app. You can turn the push notification feature on or off here.
6. Sharing Personal Data
If in providing the service we convey data to other members, it is associated exclusively with the user name you have chosen. Under no circumstances do we give direct contact details to other members (such as your name, your address, or your email address). Contacts through EliteSingles go only to your internal mailbox, so that you can decide for yourself to whom you will disclose your contact information. Some data that you provide when creating your EliteSingles profile is always visible to other registered users. These details are your age, gender, height, ethnicity, religious affiliation, occupation, smoking habits, and whether you want to have children.
Personal data is not sold by us and is only disclosed to third parties if it is necessary for performing the offered services (for example, for payment processing with chargeable memberships), or if you have given us your consent for this purpose, or if disclosure is prescribed or permitted on the basis of relevant legal provisions (for example, if we need to comply with a request from a state investigative or security authority). An overview of possible third parties can be seen on our public index of procedures.
In addition, Apollo Solutions Ltd., Informatics Park, La Tour Koenig, Pointe aux Sables, Mauritius (“Apollo Solutions”) and Lionentry, Chevchenka 25, Liviv, Ukraine (“Lionentry”) check uploaded photos and texts from EliteSingles members for genuineness and probity, in order to ensure a high quality of service and protection for our members. Since the data protection laws outside the EU are in general less strict than in the EU, Apollo and Lionentry have signed standard contractual clauses adopted by the European Commission for the transfer of personal data to contracting processors in third countries, in order to ensure the protection of personal data at EU standards. The protection of your personal data is therefore completely ensured.
7. Reviewing Personal Data
In order to protect our customers from people abusing the EliteSingles service, we analyse activities on the platform through various automated monitoring tools, and our customer service performs random tests to check customer inputs for plausibility, without our being legally obligated to do so. Certain sequences of characters or logins by different members that appear to come from a computer can lead to the blocking of suspicious activities.
In addition, EliteSingles reserves the right to automatically filter messages. Texts written by customers are thereby checked against a word list for their compatibility with current law as well as with the General Terms and Conditions. For example, pornographic or clearly offensive words are automatically correlated with customer texts. Using “Anti-Scamming Scans,” we try to protect our members from scammers.
In case a suspicion of misuse of the EliteSingles service emerges from these checks, the legal consequences are listed for the membership in the General Terms and Conditions. EliteSingles may also block the receipt and delivery of incoming and outgoing messages, if as a result of the investigation there is a high probability that the affected message is unlawful and/or violates the General Terms and Conditions. In this case there is no notification of rejected or undelivered messages.
8. Right to Information
You have the right to receive information about the personal data and settings stored for your user account, and to have it corrected or deleted at any time.
We would like to point out that your right to deletion of data, according to legal storage obligations that we have to follow, can be restricted.
In addition, courts, law enforcement agencies, or other authorities designated by law, may have a legal basis to retrieve data or request information.
For information, correction, or deletion requests, please contact us using the contact information named in section 1, while stating your name, your email address, and your user name.
Of course you can also easily view, change, or delete many details yourself in your user account.
9. Data Security
Starting from the time you register, all the data that you send to us is transmitted in encrypted form. This encryption protects the confidentiality of data exchanged between you and our web server. It helps, for example, to prevent the interception of data. As encryption technology, we employ SSL (Secure Socket Layer). It is a recognised and widely-used technology.
Regarding our databases, all technical measures have been taken to store your data in a secure environment. Access to all your information is reserved for a few selected employees and is granted only for purposes of quality control, to review complaints, and to thwart fraud. All our employees are compelled by an agreement to ensure data protection, and are trained accordingly.
10. Right of Revocation
Whenever we use data for a purpose that requires your consent pursuant to statutory regulations, we will always ask you for your express consent and record your consent.
You may at any time withdraw the consent you have given and/or revoke future uses of your data.
To withdraw your consent or to make a revocation, it will be sufficient to send a simple email to the contact named in section 1.
Please keep in mind that in the case of revoking the use of certain data, it might become impossible for EliteSingles to provide its offering. We gladly remain available for your related questions.