Privacy policy

Welcome to our Privacy Policy. Thank you for taking the time to read it.

We are committed to protecting and respecting your privacy. This Privacy Policy covers the experience we provide for users aged 18 years old and over on our Services.

Capitalized terms that are not defined in this policy have the meaning given to them in the Terms of Use.

Who we are

The company responsible for your information under this Privacy Policy (the “Data Controller”) is:

CLADDA GROUP FZE

The Office 3 – One Central

Dubai World Trade Centre

Dubai, United Arab Emirates.

Where This Privacy Policy Applies

This Privacy Policy applies to websites, apps, events and other services we operate under the Cladda brand. For simplicity, we refer to all of these as our “Services” in this Privacy Policy. To make it extra clear, we’ve added links to this Privacy Policy on all applicable services.

Some services may require their own unique privacy policy. If a service has its own privacy policy, then that policy – not this Privacy Policy – applies.

Information We Collect

It goes without saying that we cannot help you develop meaningful connections without some information about you, such as basic profile details and the types of people you would like to meet. We also collect information about your use of our Services such as access logs, as well as information from third parties, like when you access our services through your social media account or when you upload information from your social media account to complete your profile. If you want additional info, we go into more detail below.

Information you give us

You choose to give us certain information when using our Services. This includes:

  • When you create an account, you provide us with at least your phone number and email address, as well as some basic details necessary for the service to work, date of birth and  location. 

  • When you complete your profile, you have the option to share your gender, pronoun, ethnicity, and sexual orientation with us. Where you provide such elements to us, you consent to us using it for the purposes identified and as laid out in this Privacy Policy. You can also share additional information with us, such as details on your bio and your interests, as well as content such as photos and videos. To add certain content, like pictures or videos, you may allow us to access your camera or photo album.

  • When you subscribe to a paid service or make a purchase directly from us (rather than through a platform such as iOS or Android), you provide us with information related to the purchases you make and our payment processors with information such as your debit or credit card number or other financial information.

  • When you participate in surveys, focus groups or market studies, you give us your insights into our products and services, responses to our questions and testimonials.

  • When you choose to participate in our promotions, events or contests, we collect the information that you use to register or enter.

  • If you contact our customer care team, we collect the information you give us during the interaction.

  • If you share with us information about other people (for example, if you use contact details of a friend for a given feature), we process this information on your behalf, in order to complete your request.

  • Of course, we also process your chats with other members, as well as the content you publish, to operate and secure the services, and to keep our community safe.

Information we receive from others

In addition to the information you may provide us directly, we receive information about you from others, including:

  • Members: Members may provide information about you as they use our services, for instance as they interact with you or if they submit a report involving you.

  • Social media: You may decide to share information with us through your social media account, for instance if you decide to create and log in to your Cladda account via your social media or other account (e.g. Facebook, Google or Apple), or to upload onto our services information.

  • Other partners: We may receive information about you from our partners where our ads are published on a partner’s service (in which case they may pass along details on a campaign’s success). Where legally allowed, we can also receive information about suspected or convicted bad actions from third parties, as part of our efforts to ensure our members’ safety and security.

Information generated or automatically collected when you use our services

When you use our Services, this generates technical data about which features you have used, how you have used them and the devices you use to access our services:

  • Usage information: Using the services generates data about your activity on our Services, for instance how you use them (e.g. when you logged in, features you’ve been using, actions taken, information shown to you, referring webpages address and ads that you interacted with) and your interactions with other members (e.g. members you connect and interact with, and when you matched and exchanged messages with them).

  • Device information: We collect information from and about the device(s) you use to access our services, including hardware and software information such as IP address, device ID and type, app settings and characteristics, app crashes, advertising IDs (which are randomly generated numbers that you can reset by going into your device settings and, in some cases, disable entirely), and identifiers associated with cookies or other technologies that may uniquely identify a device or browser.

  • Information collected by cookies and similar technologies: We use and may allow others to use cookies and similar technologies (e.g. web beacons, pixels, SDKs) to recognise you and/or your device(s). You may read our Cookie Policy for more information on why we use them and how you can better control their use.

Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) have a 'Do Not Track' (“DNT”) feature which tells a website that a user does not want to have their online activity tracked. If a website that responds to a DNT signal receives a DNT signal, the browser can block that website from collecting certain information about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many businesses, including ours, do not currently respond to DNT signals.

  • Other information with your consent:

    • Precise geolocation data: If you give us your consent, we can collect your precise geolocation (latitude and longitude) from your device. The collection of your geolocation may occur in the background even when you are not using the Services if the permission you gave us expressly permits such collection. If you decline permission for us to collect your precise geolocation, we will not collect it, and those of our Services which rely on precise geolocation may not be available to you.

    • Photo verification data If you choose to participate in our photo verification feature, we collect your face geometry data, which may be considered biometric data in some jurisdictions, to verify that you’re the real you.

    • Other information: We may collect other information with your permission, such as photos and videos (for instance, if you want to publish a photo or video or participate in streaming features on our Services).

How We Use Information

The main reason we use your information is to deliver and improve our Services. Additionally, we use your info to help keep you and our community safe, and to provide you with advertising that may be of interest to you. Read on for a more detailed explanation of the various reasons for which we use your information, together with practical examples.

A. To administer your account and provide our Services to you

  • Create and manage your account

  • Provide you with customer support and respond to your requests

  • Communicate with you about our Services

  • Personalise pricing, offer discounts and other promotions, and complete your transactions

  • Administer sweepstakes and contests

B. To help you connect with other users

  • Recommend you to other members and recommend other members to you

  • Show members’ profiles to one another

  • Enable members to search for and connect with other members

C. To provide new Cladda Services to you

  • Register you and display your profile on new Cladda features and apps

  • Administer your account on these new features and apps

D. To provide offers and operate advertising and marketing campaigns

  • Perform and measure the effectiveness of advertising campaigns on our services and marketing our services off our platform

  • Communicate with you about products or services that we believe may interest you

E. To improve our services and develop new ones

  • Administer focus groups, market studies and surveys

  • Review interactions with customer care teams to improve our quality of service

  • Understand how members typically use the services to improve them (for instance, we may decide to change the look and feel or even substantially modify a given feature based on how members react to it)

  • Develop new features and services (for example, we may decide to build a new interests-based feature further to requests received from members)

F. To prevent, detect and fight fraud and other illegal or unauthorised activities

  • Find and address ongoing, suspected or alleged violations of our Terms of Use, notably through the review of reports and interactions between members

  • Better understand and design countermeasures against violations of our Terms of Use

  • Retain data related to violations of our Terms of Use to address the violation and prevent against recurrences

  • Enforce or exercise our rights, for example our rights set out in our Terms of Use

  • Communicate to individuals who submit a report, including what we’ve done as a result of their submission

G. To ensure legal compliance

  • Comply with legal requirements

  • Assist law enforcement

To process your information as described in this Privacy Policy, we rely on the following legal bases:

  • Provide our service to you: The reason we process your information for purposes A, B and C above is to perform the contract that you have with us. For instance, as you go about using our Service to build meaningful connections, we use your information to maintain your account and your profile, make it viewable to other members and recommend other members to you, and to otherwise provide our free and paid features to you and other members.

  • Legitimate interests: We process your information for purposes D, E and F above, based on our legitimate interest. For instance, we analyse users’ behaviour on our services to continuously improve our offerings, we suggest offers we think might interest you and promote our own services, we process information to help keep our members safe, and we process data where necessary to enforce our rights, assist law enforcement and enable us to defend ourselves in the event of a legal action.

  • Comply with applicable laws and regulations: We process your information for purpose G above where it is necessary for us to comply with applicable laws and regulations and evidence our compliance with applicable laws and regulations. For example, we retain traffic data and data about transactions in line with our accounting, tax and other statutory data retention obligations and to be able to respond to valid access requests from law enforcement. We also keep data evidencing consents members give us and decisions they may have taken to opt out of a given feature or processing.

  • Consent: If you choose to provide us with information that may be considered 'special' or 'sensitive' in certain jurisdictions, such as your sexual orientation or your religion, you are consenting to our processing of that information in accordance with this Privacy Policy. From time to time, we may ask for your consent to collect specific information such as your precise geolocation or use your information for certain specific reasons. In some cases, you may withdraw your consent by adapting your settings (for instance in relation to the collection of our precise geolocation) or by deleting your content (for instance where you entered information in your profile that may be considered 'special' or 'sensitive'). In any case, you may withdraw your consent at any time by contacting us at the address provided at the end of this Privacy Policy.

How we share information

Since our goal is to help you make meaningful connections, the main sharing of members’ information is, of course, with other members. We also share some types of member information with service providers and partners who assist us in operating the services, and, in some cases, legal authorities. Read on for more details about how your information is shared with others.

With other members

You share information with other members when you voluntarily disclose information on the Service (including your public profile). Please be careful with your information, and make sure that the Content you share are things you are comfortable with being visible.

If someone submits a report involving you (such as a claim you violated our Terms of Use), we may communicate to the reporter actions, if any, we took as a result of their report.

With our service providers and partners

We use vendors to help us operate, distribute, market and improve our services, such as data hosting and maintenance, analytics, customer care, marketing, advertising, payment processing and security operations. We also share information with vendors who distribute and assist us in advertising our services. For instance, we may share limited information on you in hashed, non-human readable form to advertising vendors.

We follow a strict vetting process prior to engaging any vendor or collaborating with any partner. Our vendors and partners must agree to strict confidentiality obligations.

Sharing functionality

You may choose to share other members’ profiles and they may share yours with people outside of our Services, using the sharing functionality.

For corporate transactions

We may transfer your information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganisation, dissolution, bankruptcy or other change of ownership or control.

With law enforcement/when required by law

We may disclose your information if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government/law enforcement investigation or other legal requirements; (ii) to assist in the prevention or detection of crime (subject in each case to applicable law); or (iii) to protect the safety of any person.

To enforce legal rights

We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and the legal rights of our members, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent or take other action regarding illegal activity, suspected fraud or other wrongdoing.

With your consent or at your request

We may ask for your consent to share your information with third parties. In any such case, we will make it clear why we want to share the information. 

We may use and share non-personal information (meaning information that, by itself, does not identify who you are such as device information, general demographics, general behavioural data, location in de-identified form), as well as personal information in hashed, non-human readable form, under any of the above circumstances. We may also share this information with third parties (notably advertisers) to develop and deliver targeted advertising on our services and on websites or applications of third parties, and to analyse and report on advertising you see. We may combine this information with additional non-personal information or personal information in hashed, non-human readable form collected from other sources. More information on our use of cookies and similar technologies can be found in our Cookie Policy.

Cross-border data transfers

Sharing of information laid out in Section 5 involves cross-border data transfers to the United Arab Emirates and other jurisdictions that may have different laws about data processing. When we transfer personal information outside of the United Arab Emirates, EEA, the United Kingdom, Switzerland or other countries which data protection laws have been deemed adequate by the United Arab Emirates or other competent governmental body, we use standard contractual clauses (standard contractual clauses are commitments between companies transferring personal data, binding them to protect the privacy and security of your data) or other appropriate transfer mechanism.

Your rights and choices

We want you to be in control of your information, so we want to remind you of the following options and tools available to you:

  • Access/update tools in the Service. Tools and account settings can help you access, rectify or remove information that you provided to us and that is associated with your account directly within the service. If you have any questions on those tools and settings, please contact us for help.

  • Device permissions. Mobile platforms can have permission systems for specific types of device data and notifications, such as phone contacts, pictures, location services, push notifications and advertising identifiers. You can change your settings on your device to either consent or oppose the collection or processing of the corresponding information or the display of the corresponding notifications. Of course, if you do that, certain Services may lose functionality.

  • Uninstall. You can stop all information collection by an app by uninstalling it using the standard uninstall process for your device. Remember that uninstalling an app does NOT close your account. To close your account, please use the corresponding functionality on the Service.

  • Account closure. You can close your account by using the corresponding functionality directly on the Service.

United States:

• Rights under the California Consumer Privacy Act (CCPA) to access, delete, and opt-out of the sale of personal information.

European Union:

• Rights under the General Data Protection Regulation (GDPR) to access, rectify, erase, and restrict processing of personal data.

United Kingdom:

• Rights under the U.K. General Data Protection Regulation (U.K. GDPR) and the Data Protection Act 2018, including access and rectification rights.

We also want you to be aware of your privacy rights. Depending on where you live, you may have the right to:

  • Access/know. You may have the right to request a copy of the information we keep about you, and in certain circumstances to receive this in a portable format. 

  • Delete/erase. You may request that we delete the personal information we keep about you. 

  • Correct/rectify/update. You can correct most information you provided to us by editing your profile directly in the Service. If you believe the information we hold about you is inaccurate, you may contact us to rectify it.

  • Object/restrict. You may also have the right to object to or request that we restrict certain processing. To do so, please contact us.

For your protection and the protection of all of our members, we may ask you to provide proof of identity before we can answer the above requests. Keep in mind, we may reject requests, including if we are unable to authenticate you, if the request is unlawful or invalid, or if it may infringe on trade secrets or intellectual property or the privacy or other rights of someone else. If you wish to receive information relating to another member, such as a copy of any messages you received from them through our service, the other member will have to contact us to provide their written consent before the information is released. We may also ask them to provide proof of identity before we can answer the request. We may also not be able to accommodate certain requests to object to or restrict the processing of personal information, notably where such requests would not allow us to provide our service to you anymore. For instance, we cannot provide our Service if we do not have your date of birth and, thus, cannot ensure that you are 18 years of age or older.

In United Arab Emirates, you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how we process your personal information. The data protection authority you can lodge a complaint with may be that of your habitual residence, where you work or where an alleged infringement took place.

How long we retain your information

Your personal information is retained by Us in a form which permits your identification for a minimum of 5 years from the closing of your Account but no longer than is necessary for the purposes for which your personal information is processed in line with legal, regulatory or statutory obligations. We retain your personal information (1) on the basis of our legitimate interest where there is an outstanding or potential issue, claim or dispute requiring us to keep information (in particular if we receive a valid legal subpoena or request asking us to preserve data (in which case we would need to keep the data to comply with our legal obligations) or if data would otherwise be necessary as part of legal proceedings); and (2) to support our customer care decisions, enforce our rights and enable us to defend ourselves in the event of a claim, information on the existence of past accounts and subscriptions.

No children allowed

Our services are restricted to individuals who are 18 years of age or older. We do not permit individuals under the age of 18 on our platform. If you suspect that a member is under the age of 18, please use the reporting mechanism available on the Service.

Keeping your personal information secure

We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Changes

We may update this Privacy Policy from time to time. When we update the Privacy Policy, we will notify you by updating the “Last Updated” date at the top of this policy and posting the new Privacy Policy and providing any other notice required by applicable law. We recommend that you review the Privacy Policy each time you visit us to stay informed of our privacy practices. 

How to contact us

Please contact us, if you have any questions about this Privacy Policy terms or the information we hold about you. If you wish to contact us, please send an email to care@cladda.com.