Privacy Policy

Positive Plus One Limited (we in this document) are committed to protecting your personal data and respecting your privacy. When taking advantage of any dating or social network service you are strongly advised to take particular note of the way in which your personal data and other data provided by you may become accessible by others as part of the service we provide. This privacy notice has been developed to provide in the clearest possible terms (whilst complying with data protection laws and requirements for notices of this kind) details about how your personal data is used within the service and options available to you to manage the access others have to your personal information.


This is version 1.0 of the privacy policy. It was published on the 1st of June, 2020.


INTRODUCTION

This policy (together with the Terms and Conditions and Acceptable Use Policy) under which we make available our App set out at positiveplusone.com/terms (“Terms and Conditions”) and positiveplusone.com/terms (“Acceptable Use Policy”) applies to your use of: Positive Plus One application (App) hosted at iTunes and Google Play Store (each referred to in this privacy policy as an App Store). The purpose of this privacy policy is to make you aware of the detail of our access to, control of and processing of your personal data once you have downloaded the App onto your mobile telephone or handheld device (Device) and begun to make use of the App.

We also explain how we deal with data that you provide or authorise us to access in other circumstances and which we then retain and which may thereafter be further processed.

This policy confirms the basis on which any personal data that we collect from you or from third parties where you permit us to do that, or that you provide to us, will be processed by us. This App is provided for the use of individuals who are 18 years or older. We do not knowingly collect data relating to children and so far as reasonably practicable take steps to exclude use by under 18s. Please read the following carefully to understand our practices regarding your personal data and how we will treat it. This policy is provided in sections with links to take you straight to particular information. You can click through to the specific areas set out below. You will also be able to access a complete pdf version of the policy here (see below).

• INTRODUCTION TO POSITIVE PLUS ONE
• THE DATA WE COLLECT ABOUT YOU
• HOW IS YOUR PERSONAL DATA COLLECTED?
• HOW WE USE YOUR PERSONAL DATA
• PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
• AGGREGATION OF PERSONAL DATA THAT WE HAVE COLLECTED
• DISCLOSURES OF YOUR PERSONAL DATA
• INTERNATIONAL TRANSFERS
• DATA SECURITY
• DATA RETENTION
• CONTACTING THE INFORMATION COMMISSIONERS OFFICE

INTRODUCTION TO POSITIVE PLUS ONE
Positive Plus One Limited is the controller and is responsible for your personal data (collectively referred to as “we”, “us” or “our” in this policy). We have appointed a data protection officer (DPO). If you have any concerns regarding or would like clarification concerning any detail in this privacy policy, please contact our DPO using the details set out below.

Contacting Positive Plus One
Our full details are:
Full name of legal entity: Positive Plus One Limited (we are a company registered in England and Wales under company number 11394568). Name or title of DPO : The Positive Plus One DPO Email address: dataprotection@positiveplusone.com Postal address: 3 Greengate, Cardale Park, Harrogate, North Yorkshire, England, HG3 1GY

Third party links
Our Sites may contain links associated with other websites. The links may take you to one of our partner organisations and other parties whose services or products may be of interest to you. The websites and any services that may be accessible through links provided will operate their own privacy policies. Please accordingly take care when visiting any sites of this kind. Note also that Positive Plus One does not accept liability for these policies or for any personal data that may be collected through these websites or services.


THE DATA WE COLLECT ABOUT YOU
At Positive Plus One we look to engage with Members at all times in a way that is relevant to the Member. Please remember that you have the responsibility to update us as when any data that we have collected and hold about you requires updating. This could be your change of mobile telephone number or email address for example. We provide means to update your information at any time. Please let us know if any of your personal details change whilst you are a Member of Positive Plus One.

We may collect, use, store and transfer different kinds of personal data about you. The data we may collect through your use of the App falls into categories described in the first column of the table below. The second column provides more information about the individual elements of data that may be collected and which comprise the data set for the particular category:-


Identity Data
Full name as you provide this, date of birth, your location (full address details are not requested), email address, gender and Facebook id. In addition the five most recent photographs associated with your Facebook profile are imported to the App.If using iTunes as your App Store you have the option of providing your iTunes unique identity (see below)

Special Category Data
This includes data associated with your sexuality as well as gender. In order to benefit from the services provided within the App you will be requested to indicate your sexual orientation. By including information in this category in your profile you understand that the information is then publishable and taking that action on your part will be taken by us as an express consent on your part to the data being processed

Contact Details for yourself
We collect your telephone number and email address

Profile Data you upload
This is provided by you at your discretion but in order to enjoy the benefits of the App you must provide information associated with your sexual orientation in order to complete a profile of yourself

Device(s) operated by you
This information is collected automatically

Usage
We may receive information in the form of statistics regarding App usage, but always in the form of anonymised data

Marketing and Communications
If you contact Privacy Plus One by email or text you are indicating that you wish us to communicate with you and we will keep a record of these communications. You may be invited to receive newsletters and other communications and with your consent we will keep a record of your contact information in those circumstances

Location
Your location details will be accessible subject to location settings being on. The data is only accessible when location settings permit. The information is available on a transitory basis and is not stored by us

Transactions you enter into with us
We receive data associated with your in-app purchases

We leave it to App Stores to manage payments that you make and we do not have access to bank account, credit card or other means of payment information. Chat Logs provide Members with end-to-end encryption. We are responsible for processing this information to a limited extent (we facilitate the interactions and data storage for chats) but we do not have the means to access data within an individual chat. We do collect Special Category Personal Data about you but this is currently limited to information about your sexual orientation. We do not collect any information that would be treated as other special category data such as race or ethnicity, religious or philosophical beliefs, sex life, political opinions, trade union membership, information about your health and genetic and biometric data. We also do not collect information regarding criminal convictions and offences.


HOW IS YOUR PERSONAL DATA COLLECTED?
We will collect the following data about you:

Information you give us.
This is information (including Identity, Contact, Decisions to enter into transactions with us and Marketing and Communications Data) you consent to giving us information about you by the way you respond to any requests to provide information within the App, or by corresponding with us (for example, by email or chat). It includes information you provide when you make an in-App purchase, share data via the App's social media functions, enter a competition, promotion or survey and when you report a problem with an App. If you contact us, we will keep a record of that correspondence.

Your Profile.
This, again is information directly provided by you including through your authority to allow us to import the required information from Facebook. This includes photographs that are imported from Facebook or uploaded directly by you.

Information we access from Apple.
We will receive your email address registered with Apple unless you have opted to request that Apple use a unique identifier when communicating with Positive Plus One

Information we access from Facebook.
In order to complete the activation of your use of the App and as a security precaution, you are asked to allow us access to and to collect information about you from Facebook. The data we take is your full name, date of birth, gender, current town, home town, email address and profile photos.

Information we collect about you and your device.
When you visit our website or use one of our Apps we may automatically collect personal data including Device, Content and Usage Data. This data would be collected using cookies and other similar technologies. Please see our cookie policy below for further details.

Location Data.
We also use GPS functions within any mobile device that you use to access the service when you have location services on. This allows us to access the detail of your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings,

Other App Users.
Are likely to make reference to you within chat interactions and personal data created on that basis becomes part of the data that we will hold about you (but in encrypted form). Other App users may also provide us with information about you that is to be treated as personal data when making any complaint or raising any query with Privacy Plus One.

Information we receive from other sources including third parties and publicly available sources.
We don’t collect information from third parties other than as identified above. Specifically we do not buy third party mailing lists.

COOKIES
We may use cookies and/or other tracking technologies to distinguish you from other Users of the App and to remember your preferences. This helps us to provide you with a good experience when you use the App or browse our website and also allows us to improve the App and our website. You will be alerted in the usual manner to any request that cookies operate on your device. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy below.


HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to do so. Typically your personal data is processed by or on behalf of Positive Plus One in the following circumstances:

• Where we have asked you for consent and you have provided that consent;
• As we are entitled to do because we have a contract with you and need to undertake a processing task in preparation for or in order to perform our contractual obligations owed to you.
• When the processing is considered by us to be permitted in order that we can satisfy our legitimate interests provided that we are also able to demonstrate that we have taken into account as a balancing factor your interests as a data subject and it is still reasonable to proceed;
• When processing the data is expected of us because of a legal or judicial requirement that we should be compliant with. We use Mailchimp and Campaign Monitor to support our business in its marketing and communication exercises. Information provided when you register to use the App will be shared with Mailchimp and Campaign Monitor as appropriate. These companies agree to act as a processor on our behalf and have committed to only process your data in accordance with our instructions. Your data will accordingly not be used by or shared by these companies with any third party other than our documented instructions which restrict the sharing of data.

To understand the privacy commitments of these companies please visit:-

• Mailchimp: https://mailchimp.com/legal/privacy/ See section 3 “Privacy for Contacts”; and
• Campaign Monitor: https://www.campaignmonitor.com/policies/#priv-section-5a

We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us or by opting out as detailed in our newsletters and other communications. In order to enhance user experience of GPS location services we have an arrangement with Tutella who receive on an anonymised basis information relating to your experience in communicating with us over a smartphone. Tutella works in turn with mobile phone operators to identify locations where mobile signal quality could be improved.


PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We summarise below the key activities that are undertaken involving your personal data. As mentioned above by law we must be able to demonstrate that under data protection laws we have a lawful basis for the activity concerned. The final column in the table below provides you with that information.

Purpose/activity	Type of data	Lawful basis for processing
To register you as an App user	Identity Contact Device	Your consent including for the purpose of providing access to certain of your Facebook data
To process in-App purchases and deliver Services that we may in future provide	Identity Contact Transaction Device Marketing and Communications Location	Your consent Performance of a contract with you Necessary for our legitimate interests (marketing activities that you have not opted out of as an example)
To provide you with chat messaging functionality and experiences offered as part of our service through the App	Identity Contact Connections Likes you have generated and likes received by you	Your consent Performance of a contract with you
To manage our relationship with you including notifying you of changes to the App or any Services	Identity Contact Profile Marketing and Communications	Your consent Preparation to perform and performance of a contract with you Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services) Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)

AGGREGATION OF PERSONAL DATA THAT WE HAVE COLLECTED
We will also routinely extract from the data you provide particular data that, when aggregated with data extracted from other Users, creates further data sets that are of a statistical nature. Data sets created that way are referred to as “Aggregated Data”. The data sets created in this way do not form a basis upon which your personal identity can be established. Should we then, however, link Aggregated Data with your personal data leading to you becoming associated with any of that Aggregated Data we will then regard the combined data as personal data which will be protected in accordance with this privacy policy.


DISCLOSURES OF YOUR PERSONAL DATA
When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes described below. Please note that we do not sell Member lists to third parties or make them available on any basis. The third parties that we do need to disclose your personal data to are as follows:-

• Facebook Inc – where you access the App using the Facebook login option. You can review Facebook’s Privacy Policy at: https://en-gb.facebook.com/policy.php
• Apple Inc for the purpose of initiating and receiving payments as authorised by the Member. Apple’s Privacy Policy is available at: https://www.apple.com/uk/legal/privacy/
• Google Inc for the purpose of initiating and receiving payments as authorised by the Member. Google’s privacy policy is available at: https://policies.google.com/

INTERNATIONAL TRANSFERS
Your personal data will be subject to international transfer but on a basis that is compliant with the data protection laws that we as data controller are subject to. The data processors we identify in this notice may receive and further process your personal data outside of the United Kingdom. Where processing occurs in the Republic of Ireland the data processing is conducted within the European Economic Area(“EEA”) and therefore directly subject to GDPR. Where processing is undertaken by companies outside of the EEA these companies must none the less accept the jurisdiction of the European Union in respect of their processing of the data of EU data subjects and have, accordingly, made formal commitments to Privacy Plus One to comply with the requirements expected of a data processor under EU (and also UK data protection laws) – for more information follow the links to their privacy policies above.


DATA SECURITY
Our commitment to protection of your personal data extends to the operational policies and procedures that we apply within Positive Plus One – and expect others who work with us to also comply with. We take all appropriate and reasonable steps within our organisation and in the manner we interact with Members through the internet to protect your personal data from unlawful access, misuse, alteration, loss or inappropriate access. We employ external parties to support us in meeting our data security obligations such as for the conducting of cyber security monitoring and test penetrations of our internal network, communications and data storage systems. We will collect and store personal data on your Device facilitated by Google Firebase using application data caches. It is also our policy to ensure that Postitive Plus One personnel will receive induction and ongoing training and that they are subject to and fully understand confidentiality obligations in connection with personal data any member of staff is entitled to access for the purpose of that person’s employment duties. All information you provide to us is stored securely. Any payment transactions carried out by our chosen third-party provider of payment processing services will be encrypted using appropriate technological solutions. Apple and Google are recognised as organisations that apply highly secure payment methodologies. Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way. We operate procedures that help us to respond to suspected personal data breaches and will notify you and any applicable regulator when we are legally required to do so.


DATA RETENTION
Details of retention periods for different aspects of your personal data are available in our retention policy, which you can request by contacting us. By law we have to keep basic information about our customers (including Contact, Identity, and Transaction Data) for six years after they cease being customers for tax purposes. In some circumstances you can ask us to delete your data. See “Your legal rights” immediately below this section for further information. Chat logs that you generate or contribute to will by definition refer to and include data concering other individuals whose personal data we are accountable for. We cannot in such circumstances delete data until such time as we provide for automatic deletion or you are able to demonstrate that all parties referred to in the relevant chat have provided Positive Plus One with their consent to the deletion. In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. In the event that you do not use the App for a period of 12 months then we will treat the account as expired and your personal data (excluding data within chat logs) will be deleted in accordance with our data retention policy.

YOUR LEGAL RIGHTS
Under certain circumstances you have the following rights under data protection laws in relation to your personal data. You can exercise any of these rights at any time by contacting us at 3 Greengate, Cardale Park, Harrogate, North Yorkshire, England, HG3 1GY or dataprotection@positiveplusone.com

1.1. Your legal rights

You have the right to:

• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
  if you want us to establish the data's accuracy;
  where our use of the data is unlawful but you do not want us to erase it;
  where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

1.2.
You also have the right to ask us not to continue to process your personal data for marketing purposes. We provide an opt-out facility associated with emails issued and you may also contact us at dataprotection@positiveplusone.com to opt out.

CHANGES TO THIS PRIVACY POLICY
We keep our privacy policy under regular review. This version was last updated on 1st June, 2020. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you by SMS OR by email The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or the Services.


CONTACTING THE INFORMATION COMMISSIONERS OFFICE
Should you have any concerns regarding the way we treat your personal data or the way we undertake control of the data do, please, get in touch. Please contact us at dataprotection@positiveplusone.com. We will respond to you quickly and will want to help you. In the event that you are not happy with our response or prefer in any event for your concern to take an alternative route you are entitled to make contact with the Information Commissioner’s Office. Contact details are as follows:- https://ico.org.uk/make-a-complaint/your-personal-information-concerns/