In advance: Your data belongs to you
Most apps make more or less of a point of telling you exactly how they use your data and why. Instead, they rely on veiled explanations and complicated phrases. Transparency and honesty? No way! At unlikeany, we take a different approach. Not only with our basic idea of really bringing people together and creating real, deep relationships. But also with the claim to openly and clearly communicate how, why and when we collect data from you. In the following sections, we describe our approach to this. Is something unclear to you or do you have suggestions for improvement? Then please contact us at any time by email at hey@unlikeany.app. We look forward to your message!
1. Information on the collection of personal data and contact details of the person responsible.
1.1 Handling of personal data
In the following we inform you about the handling of your personal data when using our app. Personal data is all data by which you can be personally identified.
1.2 Person responsible
Responsible for data processing regarding this app within the meaning of the General Data Protection Regulation (GDPR) is New Social UG (limited liability), 48143 Münster, Germany. Email: hey@unlikeany.app The person responsible for the processing of personal data is the natural or legal person who alone or jointly with others decides on the purposes and means of processing personal data.
1.3 Data Protection Officer
The person responsible has appointed a data protection officer who can be reached as follows: Nils Möllers, Keyed GmbH, email: info@keyed.de
1.4 Safe Storage and Transmission Measures
All data processed by us directly is stored on servers in Europe; This data is stored encrypted. For security reasons and to protect the transmission of personal data and other confidential content, our app uses an SSL or. TLS encryption.
1.5 What is personal data?
The term personal data is defined in the Federal Data Protection Act and in the EU-DS-GVO. According to this, these are individual details about personal or factual circumstances of a specific or identifiable natural person. This includes, for example, your real name, your address, your telephone number or your date of birth.
1.6 Legal bases for the processing of personal data
We process your data in accordance with and in order to fulfill our contract with you pursuant to Article 6 Paragraph 1 Letter b) GDPR:
to provide you with the platform and related services;
to notify you about changes to our services;
to provide you with user support;
to enforce our terms, conditions and policies;
to administer the platform, including troubleshooting;
to enable you to share and interact with User Content with other users.
In order to provide an effective and dynamic platform in accordance with our legitimate interests in accordance with Article 6 Paragraph 1 Letter f) GDPR, we can use your data for the following:
to ensure your safety and security, including reviewing User Content, messages, and associated metadata for violations of our Community Guidelines and our Terms of Service;
to ensure that content is presented in the most effective manner for you and your device;
to understand how users use the platform so that we can improve, promote and develop the platform;
to verify your identity, e.g. B. to allow you to get a "verified account" as well as to check your age, e.g. B. to ensure you are old enough to use certain features;
to serve advertisements on third-party networks and to measure the effectiveness of those advertisements.
When we process your data to fulfill our legitimate interests, we carry out a balance of interests to assess whether the use of personal data is really necessary to achieve our business purpose. When we carry out this balancing test, we also consider the rights of our users with regard to the protection of their privacy and take appropriate precautions to protect their personal data.
Insofar as we obtain the consent of the person concerned for the processing of personal data, Article 6 Paragraph 1 lit. a) of the EU General Data Protection Regulation (GDPR) serves as the legal basis for the processing of personal data. Article 6 (1) (b) GDPR serves as the legal basis for the processing of personal data required to fulfill a contract to which the data subject is a party. This also applies to processing operations that are necessary to carry out pre-contractual measures. Insofar as processing of personal data is necessary to fulfill a legal obligation to which our company is subject, Article 6 (1) (c) GDPR serves as the legal basis. In the event that vital interests of the data subject or another natural person require the processing of personal data, Article 6 Paragraph 1 Letter d) GDPR serves as the legal basis. If the processing is necessary to safeguard a legitimate interest of our company or a third party and if the interests, fundamental rights and fundamental freedoms of the person concerned do not outweigh the first interest, Article 6 Paragraph 1 Letter f) GDPR serves as the legal basis for the processing.
2. Which data we collect and how we use it
In a nutshell: We collect data to provide you with the functions of our app and to improve them over time. You can be sure that we will not sell your data to third parties or disclose it in any other way.
2.1 Verification of a new member
We ask our members for proof of identity so that we can live up to our value proposition and only release verified members to the platform. The verification takes place by having the active telephone number confirmed. We use the Google Firebase tool from Google LLC for this purpose. (1600 Amphitheater Parkway Mountain View, CA 94043, USA). Only the data required for verification (telephone number and name) will be transmitted.
2.2 Use of your photos (optional)
You can register with our app without giving us access to your photos. However, this is necessary to complete your profile and to be able to display it to other users.
2.3 Recording your voice (optional)
You can add a recording of your voice to your profile with us. If you want to use this function, we need access to the microphone of your end device. This allows you to record your voice. You and other users can then listen to your recording via the app.
2.4 Entering your email address (optional)
You can choose to provide an email address in our app in order to receive the latest information about our app via our marketing newsletter. If you comply, you will receive an email that you can use to confirm that you would like to receive the newsletter using the double opt-in procedure. Every time we receive an e-mail, we offer you the option of unsubscribing from the newsletter if you wish.
2.5 Sharing your contacts (optional)
You can choose to let us access your contacts, so you can connect with your friends inside the app. Connections with friends allow you to chat with friends, share profiles with them and create posts for each other. You can always decide to revoke access to your contacts. Existing connections in the app will stay, but you'll lose the chance of adding more friends.
2.6 Collection of your location data
We request your location data so that you can decide how far away people you want to contact via our app should be from you. We reduce the accuracy to a technical minimum. We round your location data to the third decimal place and slightly change the exchange with random numbers before saving.
2.7 Survey of your place of residence
In the app we ask about your place of residence, since we are only gradually available with unlikeany in individual areas of Germany. If your place of residence is in one of our access areas, you can already use the app with all its functionalities. If not, you have the option to wait with an early access account until we unlock all features for you as soon as we are represented in your region.
2.8 Sending push notifications (optional)
In the app you have the option of opting to receive push notifications from us for individual events in the app. This includes, for example, a push notification when someone writes you a new message or information about a new function. If you wish, you can also decide in the app to only be notified of certain events.
2.9 Recommendations/Invitation to the Platform
You can recommend unlikeany through our “Invite Friends” feature, inviting your contacts to register with us as well. We give you the opportunity to share a link to our website, which people use to access the store entry of our app in the App or Play Store.
2.10 Information Collected Automatically
When downloading the app
Since we make our app available for download via the App Store (iOS) or Google Play Store (Android), these providers receive personal data. This includes, among other things, your email address, the customer number of your account, the time of the download, payment information and your individual device code.
When starting the app
When you start our app, we collect your version of the app and the operating system. This information helps us to fix errors in the app or to draw attention to necessary updates in good time.
2.10 Data generated by your use
When creating an account
Data we process
What we process this data for
Phone number
To identify you when registering or logging in
First name
So that you and other users can see a name in profiles and address each other.
Date of Birth, Own Gender, Gender Preferences
So that you and other users can be shown profiles that match their own preferences
Lifestyle details, child preferences, height
So that you can integrate this information into your profile and take it into account when evaluating other profiles
Anonymized recording of the beginning and completion of steps in the registry
So that we can improve registration for you and other users.
When creating an account and/or editing a profile (optional)
Data we process
What we process this data for
Interests, preferences regarding music, values
So that you can integrate this information into your profile and take it into account when evaluating other profiles
Free text information by you, free text information by your friends
So that you can integrate this information into your profile and take it into account when evaluating other profiles and profile elements
When performing actions in the app
Data we process
What we process this data for
Ratings of profile elements and profiles
To determine whether we show you certain profile items and profiles for review
Matches made
To allow you and other users to connect with each other if you like each other
Chat messages
To enable you to communicate with your match via text messages
Reporting operations of profile items and profiles
To review user-generated content reported by you and other users
Share the app with friends
Statistical recording of how often you and other users share our app with friends
In addition, we use data related to the rating of profile elements and profiles to improve our matching algorithm. By evaluating these actions, we are pursuing the goal of showing you and other users profile elements and profiles that better match your preferences over time.
3. Recipients of Personal Data/Cooperation with Processors and Third Parties
In order to achieve the above-mentioned purposes, we use service providers as processors in accordance with Art. 28 DS-GVO, for example as IT service providers, for sending e-mails and SMS or for contacting you by telephone. These service providers can be based both inside and outside the European Union or the European Economic Area. We ensure through contractual agreements (so-called "order processing contract") with the service providers that they process personal data in accordance with the requirements of the DS-GVO, even if the data processing takes place outside the European Union or the European Economic Area in countries in which an adequate level of data protection is otherwise not guaranteed and for which there is no adequacy decision by the European Commission. For more information about the existence of a European Commission adequacy decision and appropriate safeguards, and to obtain a copy of these safeguards, you can contact our Data Protection Officer. In addition, we only transfer data to third parties if there is a legal obligation to do so. In this case, the transmission is based on Article 6 Paragraph 1 Clause 1 Letter c) GDPR.
As part of processing on our behalf, a third-party provider provides us with the services for hosting and displaying the platform. This serves to protect our overriding legitimate interests in a correct presentation of our offer within the framework of a balancing of interests. If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or this happens as part of the use of third-party services or disclosure or transmission of data to third parties, this only takes place if it to fulfill our (pre)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we only process or leave the data in a third country if the special requirements of Art. 44 et seq. GDPR. That means the processing takes place e.g. B. on the basis of special guarantees, such as the officially recognized determination of a data protection level corresponding to the EU or compliance with officially recognized special contractual obligations (so-called "standard contractual clauses").
4. What we share with third parties and why
In a nutshell: We only share data with third parties if we believe it is necessary for the provision of our app, if it contributes significantly to improving the app, or if we are legally obliged to do so. Below is a list of the data we share with third parties and why.
Data We Share
With whom and for what
Your profile and promotion data
Amazon Web Services, Europe: To store data from you and other users on an external server that provides the functionalities of our app.
A replication of your profile and action data
Amazon Web Services, Europe: To secure your data in relation to the risk of data loss or other problems on our main server
Data about your visit to our website or app (e.g. if you downloaded our app or created an account on Bumble), IP address (and your estimated location based on your IP address), age and gender, devices -ID (CCPA categories B, C, G, F and K)
Meta Platforms Ireland Limited, Europe: To serve ads on third-party networks and measure the effectiveness of those ads
Your device information (device type, device ID, app version, operating system) with reference to an encrypted identification number
Hetzner, Germany: Solely for logging and analyzing errors that occur through the use of the app.
Your mobile number
Google Firebase, USA: To verify your identity via your cell phone number and send you an SMS code and to collect crash reports
Your mobile number
Expo Push Notifications, USA: To send you notifications from the app
Photos and voice recordings of you
Google Firebase, USA: For storage and retrieval of media files
Verschlüsselte Identifikationsnummern zum internen Rückbezug auf Profile von Nutzer*innen
Encrypted identification numbers for internal reference to user profiles
Your e-mail address
Mailchimp, USA: To send you a confirmation email when you sign up to receive our newsletter.
Your anonymous user behavior in the app
Google Analytics, USA: For anonymous analysis of user behavior
8. Typeform
Description and purpose
For surveys, we use the service of the provider www.typeform.com on our site. Typeform is a service of TYPEFOMR S.L., Carrer Bac de Roda 163, 08018 Barcelona, Spain. If you take part in one of our surveys, Typeform collects the following data from you. utm_source=autopilot&utm_medium=email&utm_campaign=gdpr&utm_content=policyupdate If you want to avoid this type of data usage, you should refrain from using the surveys mentioned above. Further information on the collection and use of data by Typeform can be found in Typeform's data protection information under the above link.
Legal basis
The legal basis for the processing of personal data is consent in accordance with Article 6 (1) (a) GDPR.
Recipient
Recipient TYPEFOMR S.L., Carrer Bac de Roda 163, 08018 Barcelona, Spain.
Transmission to third countries
This data is processed on servers located in the USA. A transfer of data to the USA thus takes place.
Storage duration
The data will be deleted as soon as they are no longer required to achieve the purpose for which they were collected. In addition, the data will be deleted if you revoke your consent or request the deletion of the personal data.
Contractual or legal obligation for the provision of personal data
There is no contractual or legal obligation to provide the data.
Possibility of revocation and objection
You have the option to revoke your consent to data processing at any time. A revocation does not affect the effectiveness of past data processing operations.
More privacy notices
https://termsandconditions.typeform.com/to/L9Crcj? utm_source=autopilot&utm_medium=email&utm_campaign=gdpr&utm_content=policyupdate
9. Meta
Description and purpose
We work with Meta to help us market and advertise our App and Services on third party websites and applications and to measure the effectiveness of our advertising campaigns. For example: to exclude you from advertising campaigns aimed at finding new users if you already have an unlikeany account. Working together also helps us create an audience for our advertising from other potential users who share characteristics similar to yours, based on the information the Marketing Service Provider holds about you (also known as a Lookalike Audience); or to include you in a "custom audience" who will receive advertising content from unlikeany (a custom audience is essentially a list of people who we think are most likely to be interested in a particular advertisement). If you are using an Apple device with iOS 14.5 or higher, we will only share your data with Meta if you have given your explicit consent via your device settings.
Legal basis
The legal basis for the processing of personal data is consent in accordance with Article 6 (1) (a) GDPR.
Recipient
Recipient Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Dublin, D02x525, Ireland.
Transmission to third countries
This data is processed on servers located in the USA. A transfer of data to the USA thus takes place.
Storage duration
The data will be deleted as soon as they are no longer required to achieve the purpose for which they were collected. In addition, the data will be deleted if you revoke your consent or request the deletion of the personal data.
Contractual or legal obligation for the provision of personal data
There is no contractual or legal obligation to provide the data.
Possibility of revocation and objection
You have the option to revoke your consent to data processing at any time. A revocation does not affect the effectiveness of past data processing operations.
More privacy notices
https://en-gb.facebook.com/policy.php
10. Duration of storage of personal data
In a nutshell: As a rule, we store your data as long as you have an account with us. When your data is no longer used for the above purposes, we will automatically delete it.
The duration of the storage of personal data is based on the respective legal basis, the processing purpose and - if relevant - also based on the respective statutory retention period (e.g. commercial and tax retention periods). When processing personal data on the basis of an express consent in accordance with Article 6 Paragraph 1 lit. a GDPR, this data is stored until the person concerned revokes his consent. If there are statutory retention periods for data that are processed as part of legal or similar obligations on the basis of Article 6 (1) (b) GDPR, this data will be routinely deleted after the retention period has expired, provided that it is no longer required to fulfill or initiate a contract and/or we have no legitimate interest in further storage. When personal data is processed on the basis of Article 6 (1) (f) GDPR, this data is stored until the data subject exercises his or her right to object under Article 21 (1) GDPR, unless we can provide compelling reasons worthy of protection for processing that outweigh the interests, rights and freedoms of the data subject, or the processing serves to assert, exercise or defend legal claims. When processing personal data for the purpose of direct advertising on the basis of Article 6 Paragraph 1 lit. f GDPR, this data is stored until the data subject exercises his right of objection under Article 21 Paragraph 2 GDPR. Unless otherwise stated in the other information in this declaration on specific processing situations, stored personal data will be deleted when they are no longer necessary for the purposes for which they were collected or otherwise processed.
11. Rights of the data subject
In a nutshell:
In principle, you can insist on information about your data, correction of your data and deletion of your data.
11.1 Your Rights
The applicable data protection law grants you comprehensive data subject rights (rights to information and intervention) vis-à-vis the person responsible for the processing of your personal data, about which we will inform you below:
Right to information according to Art. 15 GDPR: you have in particular a right to information about your personal data processed by us, the processing purposes, the categories of processed personal data, the recipients or categories of recipients to whom your data was or will be disclosed, the planned Storage period or the criteria for determining the storage period, the existence of a right to correction, deletion, restriction of processing, objection to processing, complaint to a supervisory authority, the origin of your data if they were not collected from you by us, the existence automated decision-making including profiling and, if applicable, meaningful information about the logic involved and the scope and intended effects of such processing on you, as well as your right to information about the guarantees under Art. 46 GDPR when your data is forwarded to third countries exist;
Right to rectification in accordance with Art. 16 GDPR: you have the right to immediate rectification of incorrect data concerning you and/or completion of your incomplete data stored by us;
Right to deletion according to Art. 17 GDPR: you have the right to request the deletion of your personal data if the requirements of Art. 17 Para. 1 GDPR are met. However, this right does not exist in particular if the processing is necessary to exercise the right to freedom of expression and information, to fulfill a legal obligation, for reasons of public interest or to assert, exercise or defend legal claims;
Right to restriction of processing in accordance with Art. 18 GDPR: you have the right to request the restriction of the processing of your personal data as long as the accuracy of your data, which you dispute, is checked, if you refuse to delete your data due to inadmissible data processing and instead Request restriction of the processing of your data if you need your data to assert, exercise or defend legal claims after we no longer need this data after the purpose has been achieved or if you have lodged an objection for reasons of your particular situation, as long as it is not yet clear whether our legitimate reasons prevail;
Right to information according to Art. 19 DSGVO: If you have asserted the right to correction, deletion or restriction of processing against the person responsible, he is obliged to inform all recipients to whom the relevant personal data has been disclosed of this correction or deletion of the data or restriction of the processing, unless this proves impossible or involves a disproportionate effort. You have the right to be informed about these recipients.
Right to data portability in accordance with Art. 20 GDPR: you have the right to receive your personal data that you have provided to us in a structured, common and machine-readable format or to request transmission to another person responsible, insofar as this is technically feasible;
Right to revoke granted consent in accordance with Art. 7 Para. 3 GDPR: you have the right to revoke your consent to the processing of data at any time with effect for the future. In the event of revocation, we will delete the data concerned immediately, unless further processing can be based on a legal basis for processing without consent. The revocation of the consent does not affect the legality of the processing carried out on the basis of the consent up to the point of revocation;
Right to complain according to Art. 77 GDPR: If you are of the opinion that the processing of your personal data violates the GDPR, you have - without prejudice to any other administrative or judicial remedy - the right to lodge a complaint with a supervisory authority, in particular in the member state of your whereabouts, your place of work or the location of the alleged violation.
11.2 Right to Object
If we process your personal data as part of a balancing of interests on the basis of our overriding legitimate interest, you have the right at any time to object to this processing for reasons arising from your particular situation with effect to insert the future. If you exercise your right to object, we will stop processing the data concerned. However, further processing remains reserved if we can demonstrate compelling legitimate grounds for processing that outweigh your interests, fundamental rights and freedoms, or if the processing serves to assert, exercise or defend legal claims.
11.3 How is an objection possible?
By deleting your account. We consider the deletion of your account as an objection to the processing of your data and will stop it immediately. Alternatively, you can email us at hey@unlikeany.app.
12. Integration of other services and content of third parties
12.1 Description and Purpose
It may happen that content from third parties, such as videos, fonts or graphics from other websites are integrated within this online offer. This always presupposes that the providers of this content (hereinafter referred to as "third-party providers") perceive the IP address of the users. Because without the IP address, they could not send the content to the browser of the respective user. The IP address is therefore required for the display of this content. We endeavor to only use content whose respective providers only use the IP address to deliver the content. However, we have no influence if the third-party providers store the IP address, e.g. for statistical purposes. As far as this is known to us, we inform the users about it. We would like to provide and improve our online offer through these integrations.
12.2 Legal Bases
The legal basis for the integration of other services and third-party content is Article 6 (1) (f) GDPR. Our overriding legitimate interest lies in the intention of a corresponding presentation of our online presence and in user-friendly and economically efficient services on our part. You can find further information in the respective data protection information of the providers: https://firebase.google.com
12.3 Contractual or legal obligation for the provision of personal data
The provision of personal data is neither required by law nor by contract and is also not necessary for the conclusion of a contract. You are also not obliged to provide the personal data. However, failure to provide it may mean that you cannot use this function or cannot use it to its full extent.
13. Data transfer to third countries
The controller may transfer personal data to a third country. In principle, the person responsible can ensure through various suitable guarantees that an appropriate level of protection for the processing is brought about. It is possible to transmit data on the basis of an adequacy decision, internal data protection regulations, approved rules of conduct, standard data protection clauses or an approved certification mechanism in accordance with Article 46 (2) lit. a) - f) GDPR. If the person responsible carries out a transfer to a third country on the legal basis of Art. 49 Para. 1 a) DS-GVO, you will be informed at this point about the possible risks of data transfer to a third country. There is a risk that the third country receiving your personal data may not have an equivalent level of protection compared to the protection of personal data in the European Union. This can be the case, for example, if the EU Commission has not issued an adequacy decision for the respective third country or certain agreements between the European Union and the respective third country are declared invalid. Specifically, there are risks in some third countries with regard to the effective protection of EU fundamental rights through the use of surveillance laws (e.g. USA). In such a case, it is the responsibility of the controller and the recipient to assess whether the rights of the data subjects enjoy an equivalent level of protection in the third country as in the Union and can also be effectively enforced. However, the General Data Protection Regulation should not undermine the Union-wide level of protection for individuals when personal data are transferred from the Union to controllers, processors or other recipients in third countries or to international organisations, even when originating in or from a third country an international organisation, personal data are forwarded to controllers or processors in the same or another third country or to the same or another international organisation.
14. Security
We have taken extensive technical and operational precautions to protect your data from accidental or intentional manipulation, loss, destruction or access by unauthorized persons. Our security procedures are regularly reviewed and adapted to technological advances. In addition, we guarantee data protection on an ongoing basis through constant auditing and optimization of the data protection organization.
15. Changes to the Regulations
It may be that these conditions change at any time in compliance with the applicable data protection regulations. Here you will always find the current version of the data protection declaration. If you have any questions for us, you can reach us by email at hey@unlikeany.app
We wish you a lot of fun with our app,
Your unlikeany team