We respect the privacy of every person who registers with or visits paidwings’s website and/or uses the services made available by us from the paidwings website (the “paidwings Service”) and we are committed to ensuring a safe online experience.
1 PURPOSE OF THIS NOTICE
This privacy notice explains our approach to any personal information that you might supply to us (or that might be collected from you) in connection with your use of the paidwings Service and sets out your rights in respect of paidwings’s processing of your personal information. For more information click here.
This privacy notice will inform you how you can verify which of your personal information is collected by us through the paidwings Service and how you can request that we delete, update or transfer it.
Please also note that this privacy notice only applies to the use of personal information collected by us from your use of the paidwings Service or during your communications with us. It does not apply to personal information collected during your communications with third parties (including any brand partners associated with naughtysaucy.com).
2 WHO ARE WE AND WHAT DO WE DO?
The paidwings Service is operated by Paidwings AG (“paidwings”) whose principal activities include operating a centralised platform for a network of online dating sites which enable Users to create their own dating profiles and contact other Users of the platform or any of our additional platforms that we operate. Please be aware that when you create a dating profile on naughtysaucy.com, your profile will also be publicly available to Users of our additional platforms. For more information click here.
paidwings is the data controller responsible for your personal information.
Paidwings AG is a swiss company with registered company number: CHE-372.592.771 and whose principal address is Alte Steinhauserstrasse 1, 6330 Cham, Switzerland.
3 HOW TO CONTACT US?
The representative of the operator in the EU is Ms. in Düsseldorf, Germany. The representative can be reached directly by e-mail and serves in the EU in addition to the operator as a point of contact for questions relating to the processing of personal data under the GDPR.
4 WHAT PERSONAL INFORMATION DO WE COLLECT AND HOW DO WE COLLECT IT?
Our primary goal in collecting personal information from you is to give you a customised experience while allowing us to provide services and features that most likely meet your needs. In order to do so personal information may be collected from you in the following ways:
→ Information you voluntarily provide to us. For more information click here.
We collect and maintain personal information that you voluntarily submit to us during your use of the paidwings Service (e.g. when registering with the domain, subscribing to Premium Membership, during the course of your interactions and communications with any other Users, through any email exchanges with us or as part of any customer support interactions).
In particular, in order to sign up and create an account we require the following personal information from you:
• e-mail address;
• date of birth; and
In order to subscribe to Premium Membership, we require the following information from you:
• payment method;
• debit or credit card details; and
• billing address.
Through your use of the paidwings Service we may also ask you for the following additional personal information in order to complete your dating profile:
• your image;
• description of yourself;
• sexual preferences and any other interests; and
• current relationship status.
You have the flexibility to provide us with as little or as much of this information as possible. However, the more information you provide, the more you will get out of the paidwings Service.
If you contact us, we may collect additional information from you such as a telephone number.
→ Information we collect through your use of the paidwings Service. For more information click here.
• IP address of device(s) used;
• browser type;
• operating system and device type;
• approximate location (e.g. London);
• access times and dates; and
• referring website addresses.
We may also collect personal information regarding your use of and activity on the paidwings Service.
We use the reCAPTCHA feature of Google on our websites. This function is used to distinguish whether an input is made by a natural person or is abusive i.e. made by a machine or automated processing. The service includes sending the IP address and possibly other data required by Google for the reCAPTCHA service to Google.
5 HOW DO WE USE YOUR PERSONAL INFORMATION?
We collect and use your personal information to operate the paidwings Service efficiently and to deliver you the very best service. In particular, we may use your personal information for the following purposes:
→ Provision of the paidwings Service. For more information click here.
We collect personal information in order to enable you to register for the paidwings Service and create a dating profile which will be made publicly available to other users of the paidwings Service. We also collect personal information to process any payment owed by you in return for access to the Service. As part of the Service, we may also send you notification emails relating to the Service.
What is our legal basis?
It is necessary for the performance and fulfilment of the contract between us and to provide you with access to the best content and network of other dating profiles.
→ Service administration. For more information click here.
We may use your personal information to:
o develop and improve the paidwings Service;
o send you administrative e-mails about the paidwings Service; and
o contact you to answer any queries or customer service queries that you may have.
What is our legal basis?
It is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best service we can to you.
→ User Data Analysis. For more information click here.
We may use your personal information on an anonymised basis to analyse, benchmark and conduct research on Users and their interactions with the paidwings Service.
What is our legal basis?
It is in our legitimate interest to continually evaluate personal information to ensure the Service is working properly, that we are aware of market trends and ensure that the products and services we provide are relevant to you.
→ Internal record keeping and legal compliance. For more information click here
What is our legal basis?
→ Marketing by third parties. For more information click here.
As an online dating platform provider with multiple sites, we operate sites for and on behalf of certain brands. Where you are directed to our paidwings Service through naughtysaucy.com, we may share your personal information (e.g. your gender, title, username, email address, IP address, date of birth and city) with naughtysaucy.com to enable them to send marketing communications to you.
We also share your personal information with so that they can send you marketing about similar goods and services.
What is our legal basis?
→ Sharing information with third party processors. For more information click here.
We may share your personal information with third party processors in order to provide the paidwings Service and associated products and services to you. For example, IT support for the Service to ensure it is running correctly.
What is our legal basis?
It is in our legitimate interest to share your personal information in such a way to ensure that we provide the very best service we can to you. Where we share your sensitive personal data, which is not publicly available, we shall be relying on your consent to do so.
→ Sharing information with professional advisors & potential purchasers. For more information click here.
We may share your personal information with professional advisers or regulatory authorities:
(i) to enable them to process your personal information on our behalf in a manner consistent with this privacy notice;
(ii) to comply with our legal obligations;
(iii) to enforce our legal rights; or
(iv) protect rights of third parties.
Your personal information may also be shared with prospective buyers if we go through a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets.
What is our legal basis?
It is in our legitimate interest to share your personal information with such third parties to enable them to process your information on our behalf, to comply with and/or enforce our legal rights and obligations, to protect the rights of third parties and to facilitate business transitions. Where we share your sensitive personal data, we shall be relying on your consent to do so.
Any other purposes for which we wish to use your personal information will be notified to you either by updating our privacy notice or otherwise from time to time including the legal basis of such use.
6 HOW DO WE OBTAIN YOUR CONSENT?
Where use of your personal information by us requires your consent, you can provide such consent:
• at the time we collect your personal information following the instructions provided; or
• by informing paidwings by e-mail or post using the contact details set out in this Privacy Notice.
8 THIRD PARTY LINKS AND SERVICES
The paidwings Service may contain links to third party websites and services. Please remember that when you use a link to go from paidwings to another website or you request a service from a third party, this privacy notice no longer applies. For more information click here.
Your browsing and interaction on any other website, or your dealings with any other third party service provider, is subject to that website’s or third party service provider’s own rules and policies.
We do not monitor, control, or endorse the privacy practices of any third parties.
We encourage you to become familiar with the privacy practices of every website you visit or third party service provider that you deal with and to contact them if you have any questions about their respective privacy policies and practices.
This privacy notice applies solely to personal information collected by us through the paidwings Service and does not apply to these third party websites and third party service providers.
9 TRANSFERS OUTSIDE THE EEA
We do not currently transfer your personal information outside of the EEA.
10 HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION FOR?
We do not keep your personal information for any specific period but will not keep it for longer than is necessary for our purposes.
In considering how long to keep it, we will take into account its relevance to our business and our legal and regulatory obligations.
11 CONFIDENTIALITY AND SECURITY OF YOUR PERSONAL INFORMATION
We are committed to keeping the personal information you provide us secure and we will take reasonable precautions to protect your personal information from loss, misuse or alteration. For more information click here.
We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from:
• unauthorised access;
• improper use or disclosure;
• unauthorised modification; and
• unlawful destruction or accidental loss.
All our employees and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information of all users of the paidwings Service.
12 HOW TO ACCESS YOUR INFORMATION AND YOUR OTHER RIGHTS?
You have the following rights in relation to the personal information we hold about you:
• Your right of access. For more information click here.
If you ask us, we’ll confirm whether we’re processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.
• Your right to rectification. For more information click here.
If the personal information we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If we’ve shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
• Your right to erasure. For more information click here.
You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or you withdraw your consent (where applicable). If we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
• Your right to restrict processing. For more information click here.
You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or object to us processing it. It won’t stop us from storing your personal information though. We’ll tell you before we lift any restriction. If we’ve shared your personal information with others, we’ll let them know about the restriction where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
• Your right to data portability. For more information click here.
With effect from 25 May 2018, you have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or ask us to transfer this to a third party of your choice.
• Your right to object. For more information click here.
You can ask us to stop processing your personal information, and we will do so, if we’re:
o relying on our own or someone else’s legitimate interests to process your personal information except if we can demonstrate compelling legal grounds for the processing;
o processing your personal information for direct marketing; or
o processing your personal information for research unless such processing is necessary for the performance of a task carried out in the public interest.
• Your rights in relation to automated decision-making and profiling. For more information click here.
You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, and it produces a legal effect or similarly significantly affects you unless such profiling in necessary for entering into, or the performance of, a contract between you and paidwings.
• Your right to withdraw consent. For more information click here.
If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.
• Your right to lodge a complaint with the supervisory authority. For more information click here.
If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to the UK Information Commissioner’s Office (ICO). You can find details about how to do this on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.
13 CHANGE TO THIS PRIVACY NOTICE
We may make changes to this privacy notice from time to time. For more information click here.
To ensure that you are always aware of how we use your personal information we will update this privacy notice from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. We may notify you by e-mail of any significant changes. However, we encourage you to review this privacy notice periodically to be informed of how paidwings uses your personal information.
Last Updated December 2017