Privacy Policy

  1. WHO ARE WE?
  • Collector: ULINDR LTD (here in after, “ULINDR”)
  • Registered office: Flat 8, Grandstones, María Teresa Spinelli Street, GZR 1712, Gzira, Malta
  • Email address: hola@ulindr.com
  1. INFORMATION WE COLLECT

In this statement of our Privacy Policy, the user (hereinafter referred to as the “User” or, where appropriate, the “Users“) is informed that the personal data provided through the online platform (hereinafter, the “Platform” ) available on the website located at the URL <https://www.ulindr.es> (hereinafter, the “Website”) or in the mobile application (hereinafter, the “Application”), as well as the data derived from your navigation and any other data that you may provide in the future are treated by ULINDR as explained below.

The User must carefully read this Privacy Policy, which has been written in a clear and simple way in order to facilitate its understanding, allowing the user to freely and voluntarily determine whether you wish to provide your personal data to ULINDR.

It is understood by the Users that ULINDR is a social network for lesbians and bisexual women. Therefore, the fact of registering on the Platform and having a profile on it will lead the User to make publicly the data related to their life or sexual orientation

Users’ privacy is a TOP PRIORITY for ULINDR, hence the use of the data will be carried out only when it will be strictly necessary for the proper functioning of the Platform. The verification of the profile through a social network (in this case, Facebook or Instagram) is done for the sole purpose of proving the identity of the Users, not collecting more data than the name used in the social network and the main photograph of the account. The name may be modified by the User once your account is verificated and the photo deleted through the procedure established in the Conditions of Use https://www.ulindr.es/aviso-legal/

  1. OBLIGATION TO PROVIDE DATA

The data requested in the forms of the Platform are, in general, mandatory (unless otherwise specified in the required field) to comply with the purposes for which they are being collected, obtaining only those that are strictly necessary to guarantee the Proper functioning of the Application.

Therefore, if they are not provided or not correctly provided, the services offered through the Platform cannot be adequately provided.

  1. HOW WE USE INFORMATION?

It should be understood that the main reason for using your information is to deliver and improve your experience. The personal data of the User will be treated by ULINDR according to the following purposes:

  1. Registration management in the Platform and management of the commercial relationship with the User, as well as the collection and exchange of ULINDS (see the Conditions of Use https://www.ulindr.es/aviso-legal/).
  2. Creation, verification and management of your account (the User’s) and information collection through Facebook, Instagram and other social networks indicated by the User.
  3. Provision of services and features to the Users, as well as communication of relevant information in relation to those services and features of the Platform, such as (i) Girls around; (ii) “Meet up now”; (iii) Instant chat; or (iv) collection and exchange of ULINDS.
  4. Answer to the questions raised through the contact forms and / or the different communication channels offered to the Users.
  5. Attention and emphasis on the exercise of Users’ rights.
  6. Prevention and use regulation of the Platform for illegal or unauthorized purposes, with or without economic purpose, including the reports of the Users.
  7. Preparation of reports, statistics and internal analysis to improve the services and content offered on the Platform.
  8. Optimization and maintenance of services, features and contents, as well as error and problem detection in the Platform.
  9. Preparation of User’s profile to offer personalized services and content through the Platform.
  10. Sending personalized communications.
  1. WHAT USER DATA WILL ULINDR TREAT?

Meanwhile using the platform it will be possible to process the following Users’ personal data, collecting some of these data from Facebook, Instragram and other social networks through which the User carries out its registration process and the Verification and development of your profile:

  1. Identifying data.
  2. Contact information.
  3. Personal characteristics when completing profile: preferences, lifestyle, interests, photos.
  4. Transaction data of goods and services.
  5. Geolocation data.
  6. Navigation data on the Platform.
  7. Data related to the life and sexual orientation of the User.
  8. Other data provided by the Users themselves in the open fields of the forms provided by ULINDR.

In the event that the data provided directly by the User who carries out the acceptance of this Privacy Policy refers to other natural persons and not to the said User, it guarantees to have informed and obtained the prior unequivocal consent of those for the treatment of that data, in accordance with the purposes set forth in this Privacy Policy, exempting ULINDR from any responsibility in this regard. In the specific case of minors, the access is not allowed. ULINDR may carry out periodic verifications to verify this fact, adopting the appropriate due diligence measures, in accordance with the data protection regulations.

  1. LEGITIMACY OF USER’S DATA PROCESSING BY ULINDR?

Data processing of the User by ULINDR is legitimized in the fulfilment of the contract for the provision of services between the parties, as well as, where appropriate, in the legitimate interest and in the fulfilment of legal obligations.

Notably, ULINDR treats the data with the following legitimate reasons:

  • Management of the registration in the Platform and management of the commercial relationship with the User, as well as the collection and exchange of ULINDS.

All treatments derived from this purpose will be based on the legitimate compliance with the contractual relationship.

  • Creation and verification of the User’s profile and information collection from Facebook, Instagram and other social networks provided by the User.

All the treatments derived from this purpose that are necessary for the creation and verification of the User’s profile will have as a basis of legitimization the fulfilment of the contractual relationship.

However, in the event that the User wants to link a verified profile on the Platform with other social networks, the basis of legitimization of the treatment for this purpose would be the consent of the User.

  • Provision of the services and features offered by ULINDR to the Users, as well as showing them relevant information in relation to said services and features of the Platform

All the treatments derived from this purpose that are necessary for the creation and verification of the User’s profile will have as a basis of legitimization the fulfilment of the contractual relationship. The User can configure the notifications that you want to get or the activation of the geolocation.

  • Answer to the questions raised through the contact forms and / or the different communication channels offered to the Users.

The treatment of data derived from this purpose is the fulfilment of the contractual relationship or for the application at the request of the User of pre-contractual measures.

  • Attention to the exercise of rights of the Users.

All the treatments derived from this purpose will have as a basis of legitimization the fulfilment of legal obligations, according to what is established in the applicable data protection regulations.

  • Prevention and control of the use of the Platform for illegal or unauthorized purposes, with or without economic purpose, including the reports of the Users.

All treatments derived from this purpose will be legitimately based on the legitimate interest, recognized to the person responsible for the treatment by the regulations.

This legitimate interest is based on ensuring that the services, features or contents are not used for illicit purposes and, in the case of happening, management, processing and resolution of illegal behaviours carried out by the User.

  • Preparation of reports, statistics and internal analysis to improve the services, features and contents offered in the Platform.

All the treatments derived from this purpose will have as legitimate basis the legitimate interest, recognized by the person in charge of the treatment by the data protection regulations.

This legitimate interest is based on being able to offer to the users the services of ULINDR with the highest quality and best possible experience.

  • Optimization and maintenance of the services, features and contents, as well as the detection of errors and problems in the Platform.

All treatments derived from this purpose will be based on the legitimacy of the legitimate interest, recognized to the person responsible for the treatment by the regulations.

This legitimate interest is based on being able to offer the users the services of ULINDR with the highest quality and best possible experience.

  • Preparation of a User profile to offer personalized services and content through the Platform:

All treatments derived from this purpose will be based on the legitimization compliance with the contractual relationship.

  • Sending personalized commercialized communications.

The treatment derived from this purpose will be based on the legitimacy of the legitimate interest, recognized to the person responsible for the treatment by the applicable regulations.

This legitimate interest is based on the consideration of the Users’ interest as ULINDR customers for offering goods and services through direct marketing, through email or push notifications on their devices.

In the event that the User gives their consent for ULINDR to process the data for any purpose other than those mentioned in this Privacy Policy, the User should be duly informed of that treatment. The User is empowered to revoke the consent by contacting ULINDR in the following email: hola@ulindr.com

  1. WHO WILL HAVE ACCESS TO USERS’ DATA?

The personal data provided by the User through the Platform may be shared with:

  • Public Administrations in the cases established by law.
  • Courts and Tribunals in the cases established by law.
  • The State Security Forces and Bodies in the cases established by law.
  • The entities that are part of the ULINDR LTD business group, based on the legitimate interest determined by the data protection regulations, for administrative management purposes of the business group.

The Platform is free, but in the event that there were payments within the App, they will be made through third-party payment gateways, such as G-Pay, Apple Pay or Stripe. In this sense, ULINDR will not have access to the financial and / or banking data of the User, these platforms being responsible for the data processed through their own payment gateways.

  1. INTERNATIONAL DATA TRANSFERS.

The User is informed that ULINDR has contracted services with third parties that are outside the European Economic Area which may have access to the User data. In particular, technology service providers. In this case, it is reported that the international transfer of data will be carried out with the adequate guarantees, maintaining in any case the security, confidentiality and the duty of secrecy over them. For this reason, ULINDR has signed with the suppliers the Contractual Clauses type approved by the European Commission. The User can obtain a copy of these through the following link: https://eur-lex.europa.eu/legal-content/ ES / TXT / PDF /? Uri = CELEX: 32010D0087 & from = en

  1. HOW LONG WE RETAIN USER’S INFORMATION

The personal data provided by the User will be kept in the databases of the Platform during the following deadlines:

a) Data processed for the management of registration in the Platform and for the management of the commercial relationship with the User, as well as for obtaining and exchanging ULINDS.

The data provided for registration in the Platform, as well as to manage, process, formalize subscriptions, features and services, will be kept during the time in which the User has a profile created and verified on the Platform and, once that relationship is over, during the limitation period of legal actions that may arise from it.

b) Data processed for the creation and verification of the User profile and the collection of information through Facebook, Instagram and other social networks provided by the User.

The data obtained by ULINDR through other social networks, will be kept during the time in which the User has a profile created and verified on the Platform and, once the User stops having this profile, during the statute of limitations of legal actions that may be derived from the use and creation of a profile on the Platform.

c) Data processed to provide services and features offered by ULINDR to the Users, as well as to show them relevant information.

The data obtained by ULINDR through other social networks, will be kept during the time in which the User has a profile created and verified on the Platform and, once the User stops having this profile, during the statute of limitations of legal actions that may be derived from the use and creation of a profile on the Platform.

d) Data processed to answer the questions raised through the contact forms and / or the different communication channels offered to the Users.

The data provided through the contact forms and the different communication channels made available to the Users will be kept for the necessary period to process and answer your request and, once it is finished, during the period of prescription of the legal actions derived from the aforementioned request.

e) Data processed to attend the exercise of rights of the Users.

The data used to attend the exercise of rights of the Users will be kept for the necessary period to process the right requested by the User and, once this right has been fulfilled, they will be kept until the prescription of the possible responsibilities derived from this treatment.

f) Data processed for the prevention and control of the use of the Platform for illegal or unauthorized purposes, with or without economic purpose, including the reports of the Users.

The data used for the resolution of problems, incidents or illicit derived from the activities of the Users will be kept for the necessary period to process and solve the aforementioned problems, incidents or illicit and, once resolved, during the period of prescription of the legal actions that could derive from those.

g) Data processed for the preparation of reports, statistics and internal analysis to improve the services and content offered in the Platform.

The data used for the preparation of reports, statistics and analysis will be kept for the necessary  period to process and prepare the aforementioned reports, statistics and / or analysis, and, once finished, during the period of limitation of legal actions derived from the aforementioned request.

h) Data processed for the optimization and maintenance of the services, features and contents, as well as the detection of errors and problems of the Platform.

The data used for the optimization of the services and error and problem detection of errors in the Platform will be kept for the necessary period to process and develop the aforementioned works of optimization and error detection and, once they have been performed, during the prescription period of the legal actions that could derive from those.

i) Data processed for the preparation of a profile for the User to offer personalized services and content through the Platform.

The data provided for registration on the Platform, as well as for managing, processing, formalizing and monitoring the services provided through it, will be kept during the contractual relationship and, once that relationship is finalized, during the limitation period of the legal actions that may be derived from it.

j) Data processed for sending personalized commercial communications.

The data used to send personalized commercial communications will be processed until the User opposes. You can object at any time, by checking the corresponding box on the forms enabled for this purpose in the registration process, clicking on the link that will appear at the bottom of the commercial communication, sending an e-mail indicating your opposition to the following email address electronic: hola@ulindr.com, or by configuring the App through the settings of your device so that we do not notify you of news via push notifications.

In any case, ULINDR will duly block the personal data of the Users, not having access to them at the time they cease to be necessary to fulfill the purpose for which they were collected, being only treated in case of requirement by the competent judicial or administrative authority in the cases expressly established in the Law

  1. GEOLOCATION AND PUSH NOTIFICATIONS.

Some of the Platform’s features require geolocation permissions in the device from which it is accessed or on which it is installed (tablet, smartphone, etc.).

The User may disable this option directly on the device itself, however, deactivating this option will prevent the use of some of the Platform’s features, and it may not work properly.

Likewise, the Platform allows to display information through push communications on the User’s device. The user can configure the notifications that you wish to receive.

  1. USER RESPONSIBILITY.

The User guarantees that she is a woman and over eighteen (18) years of age and that the information provided to ULINDR is true, accurate, complete and up-to-date. For these purposes, the User responds to the veracity of all the data that you communicate and will keep the information provided updated, so that it responds to your real situation.

Likewise, it guarantees that you have informed the third parties that you provide your data, if so, of the aspects contained in this document. It also guarantees that you have obtained your authorization to provide your data to ULINDR for the purposes indicated.

In any case, the User will be responsible for false or inaccurate information provided through the Platform and for direct and indirect damages and losses caused by ULINDR or third parties.

  1. EXERCISE OF RIGHTS.

As owner of the data, the User can send a written request to ULINDR, to the provided address in the header of this Privacy Policy, or via email to the following address: hola@ulindr.com, attaching a photocopy of your identity document, at any time and for free, to exercise the following rights:

a) Right of Access:

You will have the right to have ULINDR informing you about whether or not we are processing your personal data and, in this case, to be able to access such data and receive information about the purposes for which they are treated, the categories of data affected by the treatment, the recipients to whom your personal data and the expected period of data retention were communicated, among other information.

b) Right of Rectification and Suppression:

You will have the right to request the deletion of personal data as long as the legal requirements of application are met, and the rectification of inaccurate data that concerns you when, among other reasons, these are no longer necessary for the purposes for which they were collected.

c) Limitation of treatment, Revocation of consent and Total or partial opposition to treatment:

In certain circumstances (for example, in the event that the applicant challenges the accuracy of their data, while verifying the accuracy of the same), they may request that the processing of their personal data be limited, these being only treated for the exercise or Claims defense.

You will also have the right to revoke the consent given and oppose to the treatment at any time, for reasons related to your particular situation, in case the treatment is based on our legitimate interest or the legitimate interest of a third party (including the treatment you have by object the direct marketing and the elaboration of the corresponding profiles). In this case, ULINDR will cease the treatment, unless accreditation of legitimate reasons.

d) Portability of your data

You will have the right to receive the personal data that ULINDR has provided in a structured, common and mechanical reading format, and to be able to transmit them to another person responsible for the processing without being prevented by the person responsible for providing them, in the cases provided by the law.

e) Automated individual decisions

Likewise, in addition to the aforementioned rights, in the event that automated decisions are taken, including profiling, that have legal effects on the User or significantly affect the User in a similar way, you will have the right to obtain human intervention from ULINDR and express your point of view and challenge the decision.

f) Other

You may file a claim regarding the protection of your personal data before the Spanish Agency for Data Protection at the address C / Jorge Juan, 6, 28001 – Madrid, in case the interested party considers that ULINDR has violated the rights that are recognized by the applicable regulations on data protection.

  1. HOW WE PROTECT YOUR INFORMATION

ULINDR will treat the User’s data at all times in an absolutely confidential manner and keeping the mandatory duty of secrecy with respect to them, in accordance with the provisions of the applicable regulations, adopting the necessary technical and organizational measures that guarantee the security of your data and avoids its alteration, loss, treatment or unauthorized access, taking into account the state of the technology, the nature of the stored data and the risks to which they are exposed.

  1. CHANGES.

ULINDR reserves the right to revise its Privacy Policy at the time it deems appropriate, in which case, it will be communicated to the Users. For this reason, please check this privacy statement regularly to read the most recent version of the Privacy Policy and have full knowledge of the treatment activities carried out by ULINDR.

  1. ACCEPTANCE AND UNDERSTANDING.

The User declares to have been informed of the conditions on protection of personal data, accepting and understanding the content of this Privacy Policy. Otherwise, do not accept the Privacy Policy or use the Platform.

Last update: August 28, 2019.

Copyright © 2019 ULINDR LTD All rights reserved.

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