Chispa Privacy Policy

Dated June 21, 2017

This Privacy Policy describes the information Affinity Apps LLC, (“Chispa,” “we,” and “us”) collects, how that information may be used, with whom it may be shared, and your choices about such uses and disclosures. We encourage you to read this Privacy Policy carefully when using our application or website. This Privacy Policy is incorporated into our Terms of Use. By using our website, application or other online services (our “Service”), you are accepting the practices described in this Privacy Policy. If you have any questions about our privacy practices, please refer to the end of this Privacy Policy for information on how to contact us.

Information we collect about you

In General. We may collect Personal Information, including Sensitive Data, and other information. “Personal Information” means individually identifiable information that would allow us to determine the actual identity of, and contact, a specific living person. Sensitive Data includes information, comments or content (e.g. photographs, video, profile, lifestyle) that you optionally provide that may reveal your ethnic origin, nationality, religion and/or sexual orientation. By providing Sensitive Data to us, you consent to the collection, use and disclosure of Sensitive Data as permitted by applicable privacy laws. We may also collect your geolocation with your consent. We may collect this information through a website, a mobile application, or other online services. We may also collect your geolocation information with your consent. By using the Service, you authorize us to gather, use and retain data in accordance with this Privacy Policy and our Terms of Use. While we are based in the United States, we may send this information to servers located outside of the United States.

Information you provide. In order to register as a user with Chispa, you will be asked to sign in using your Facebook login. If you do so, you authorize us to access certain Facebook account information consistent with your Facebook privacy settings, such as your public Facebook profile, email address, interests, gender, birthday, education history, relationship interests, current city, photos, personal description, friend list, and information about and photos of your Facebook friends who might be common Facebook friends with other Chispa users. You will also be asked to allow Chispa to collect your location information from your device when you download or use the Service. You may also provide us photos, and information about your gender and preferences for recommendations, such as search distance, age range and gender. If you communicate with other Chispa users, you provide us the content of your communications.

Information from other sources. Chispa is part of The Match Group family of businesses, which as of the date of this policy includes websites and apps such as Match.com, Tinder, OurTime.com, BlackPeopleMeet.com, OkCupid, Twoo, POF, Meetic and FriendScout24. We may obtain both personal and non-personal information about you from other Match businesses, business partners and other third parties.

Information about others. We may collect and store personal information about other people that you provide to us, such as their name, address and email address. If you use our website or application to send others (friends, relatives, colleagues, etc.) a product as a gift, we may store your personal information, and the personal information of each such recipient in order to process those requests or facilitate future activities.

Use of technologies to collect information. We use various technologies to collect information from your device and about your activities on our Service.

Information collected automatically. We automatically collect information from your browser or device when you visit our Service. This information could include your IP address, device ID and type, your browser type and language, the operating system used by your device, access times, your mobile device’s geographic location while our application is actively running, and the referring website address.

Mobile device IDs. If you're using our app, we use mobile device IDs (the unique identifier assigned to a device by the manufacturer), or Advertising IDs (for iOS 6 and later), instead of cookies, to recognize you. We do this to store your preferences and track your use of our app. Unlike cookies, device IDs cannot be deleted, but Advertising IDs can be reset in “Settings” on your iPhone. Ad companies also use device IDs or Advertising IDs to track your use of the app, track the number of ads displayed, measure ad performance and display ads that are more relevant to you. Analytics companies use device IDs to track information about app usage.

Cookies and use of cookie and similar data. When you visit our Service, we may assign your device one or more cookies or other technologies that facilitates personalization to facilitate access to our Service and to personalize your experience. Through the use of a cookie, we also may automatically collect information about your activity on our Service, such as the pages you visit, the time and date of your visits and the links you click. If we advertise, we (or third parties) may use certain data collected on our Service to show you Chispa advertisements on other sites or applications.

Pixel tags. We embed pixel tags (also called web beacons or clear GIFs) on web pages, ads, and emails. These tiny, invisible graphics are used to access cookies and track user activities (such as how many times a page is viewed). We use pixel tags to measure the popularity of our features and services. Ad companies also use pixel tags to measure the number of ads displayed and their performance (such as how many people clicked on an ad).

Information collected by third-parties for advertising purposes. We may allow service providers, advertising companies and ad networks, and other third parties to display advertisements on our Service and elsewhere. These companies may use tracking technologies, such as cookies or web beacons, to collect information about users who view or interact with their advertisements. We do not provide any non-masked or non-obscured personal information to third parties. Some of these third-party advertising companies may be advertising networks that are members of the Network Advertising Initiative, which offers a single location to opt out of ad targeting from member companies (www.networkadvertising.org). Opting out will not decrease the number of advertisements you see. To opt-out of cookies that may be set by third-party data or advertising partners, please go to http://www.aboutads.info/choices/.

How we use the information we collect

In General. We may use information that we collect about you to:

  1. deliver and improve our products and services, and manage our business;
  2. manage your account and provide you with customer support;
  3. perform research and analysis about your use of, or interest in, our or others’ products, services, or content;
  4. communicate with you by email, postal mail, telephone and/or mobile devices about products or services that may be of interest to you either from us or other third parties;
  5. develop, display, and track content and advertising tailored to your interests on our Service and other sites, including providing our advertisements to you when you visit other sites;
  6. website or mobile application analytics;
  7. verify your eligibility and deliver prizes in connection with contests and sweepstakes;
  8. enforce or exercise any rights in our Terms of Use;
  9. enroll you in the discount, rebate, and other programs in which you elect to participate, to protect against or identify possible fraudulent transactions;
  10. register you with and display your profile on other online dating and other social websites owned by Match Group, such as websites operated by Affinity Apps, chemistry.com and okcupid.com.; and
  11. perform functions or services as otherwise described to you at the time of collection.

In all circumstances, we may perform these functions directly or use a third party vendor to perform these functions on our behalf. Also, if you access our Service from a third party social platform, such as Facebook, we may share non-personal information with that platform to the extent permitted by your agreement with it and its privacy settings.

With whom we share your information

Information Shared with Other Users. Your Chispa profile and content will be viewable by other users of the Service. Other users may be able to view and share information you have provided to us directly or through Facebook, including your first name, photos, videos, content you provide and approximate location. Whenever you voluntarily disclose personal information on publicly-viewable pages, that information will be publicly available and can be collected and used by others. For example, if you post your email address, you may receive unsolicited messages. We cannot control who reads your posting or what other users may do with the information you voluntarily post, so we encourage you to exercise discretion and caution with respect to your personal information.

Personal information. We do not share your personal information with others except as indicated in this Privacy Policy or when we inform you and give you an opportunity to opt out of having your personal information shared. We may share personal information with:

  1. Service providers. We may share information, including personal and financial information, with third parties that perform certain services on our behalf. These services may include fulfilling orders, providing customer service and marketing assistance, performing business and sales analysis, ad tracking and analytics, member screenings, supporting our Service functionality, and supporting contests, sweepstakes, surveys and other features offered through our Service. These service providers may have access to personal information needed to perform their functions but are not permitted to share or use such information for any other purposes.
  2. Business partners. When you register or make purchases on our website or click-through our advertisements offered on third party websites or applications, we may share personal information with the businesses with which we partner to offer you the applicable products, services or any advertisements. When you elect to engage in a particular merchant's offer or program, you authorize us to provide your email address and other information to that merchant. To opt-out of cookies that may be set by third party data or advertising partners, please go to www.aboutads.info/choices/.
  3. Other Match Group businesses. Chispa is part of the Match Group family of businesses, which include the online dating websites and apps Match.com, Tinder, OkCupid, OurTime.com, BlackPeopleMeet.com, Twoo, Meetic, POF, FriendScout24 and others. We may share information we collect, including your profile and personal information such as your name and contact information, photos, interests, activities and transactions on our Service with other Match Group companies.
  4. Other Situations. We may disclose your information, including personal information:
    1. In response to a subpoena or similar investigative demand, a court order, or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us.
    2. When we believe disclosure is appropriate in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of our company, our users, our employees, or others; to comply with applicable law or cooperate with law enforcement; or to enforce our Terms of Use or other agreements or policies.
    3. In connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

Aggregated and/or non-personal information. We may use and share non-personal information we collect under any of the above circumstances. We may also share it with other Match Group companies and third parties to develop and deliver targeted advertising on our Service and on websites or applications of third parties, and to analyze and report on advertising you see. We may combine non-personal information we collect with additional non-personal information collected from other sources. We also may share aggregated, non-personal information, or personal information in hashed, non-human readable form, with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis, advertising, marketing, or other business purposes. For example, we may engage a data provider who may collect web log data from you (including IP address and information about your browser or operating system), or place or recognize a unique cookie on your browser to enable you to receive customized ads or content. The cookies may reflect de-identified demographic or other data linked to data you voluntarily have submitted to us (such as your email address), that we may share with a data provider solely in hashed, non-human readable form.

We may also share your geolocation information in de-identified form with Match Group companies and third parties for the above purposes. To opt-out of the sharing of your geolocation information, you can go to Location Services on your device and turn off location sharing for the Chispa application; however, this will result in the app no longer functioning. You can also uninstall the Chispa application.

Do Not Track disclosure

Do Not Track (“DNT”) is a privacy preference that users can set in their web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. We are committed to providing you with meaningful choices about the information we collect and that is why we provide the opt-out links above. However, we do not recognize or respond to any DNT signals, as the Internet industry works toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT.

Third party websites

If you access other websites or applications that do not operate under this Privacy Policy, we recommend that you consult the privacy statements of all such third-party websites or applications.

How you can access and correct your information

If you have a Chispa account, you have the ability to review and update your personal information within the Service by opening your account and going to settings. Applicable privacy laws may allow you the right to access and/or request the correction of errors or omissions in your personal information that is in our custody or under our control. Our Privacy Officer will assist you with the access request. This includes:

  1. Identification of personal information under our custody or control; and
  2. Information about how personal information under our control may be or has been used by us.

We will respond to requests within the time allowed by all applicable privacy laws and will make every effort to respond as accurately and completely as possible. Any corrections made to personal information will be promptly sent to any organization to which it was disclosed.

In certain exceptional circumstances, we may not be able to provide access to certain personal information we hold. For security purposes, not all personal information is accessible and amendable by the Privacy Officer. If access or corrections cannot be provided, we will notify the individual making the request within 30 days, in writing, of the reasons for the refusal.

Data Retention

We keep your information only as long as we need it for legitimate business purposes and as permitted by applicable legal requirements. We will retain data for analytical purposes and recordkeeping integrity, as well as to prevent fraud, enforce our Terms of Use, take actions we deem necessary to protect the integrity of our Service or our users, or take other actions otherwise permitted by law. In addition, if certain information has already been provided to third parties as described in this Privacy Policy, retention of that information will be subject to those third parties' policies.

Your choices about collection and use of your information

You can choose not to provide us with certain information, but that may result in you being unable to use certain features of our Service. Our Service may also deliver notifications to your phone or mobile device. You can disable these notifications by going into “App Settings” on the app or by changing the settings on your mobile device. You can also control information collected by cookies. You can delete or decline cookies by changing your browser settings. Click “help” in the toolbar of most browsers for instructions.

When you register on our site, you consent to receive email messages from us. You may modify this consent later by visiting the “App Settings” page associated with your account. At any time you can choose to no longer receive commercial or promotional emails from us by visiting the “App Settings” page associated with your account. You also will be given the opportunity, in any commercial email that we send to you, to opt out of receiving such messages in the future. It may take up to 10 days for us to process an opt-out request. We may send you transactional and relationship emails, such as service announcements, administrative notices, and surveys, without offering you the opportunity to opt out of receiving them. Please note that changing information in your account, or otherwise opting out of receipt of promotional email communications, will only affect future activities or communications from us. If we have already provided your information to a third party (such as a service provider) before you have changed your preferences or updated your information, you may have to change your preferences directly with that third party.

How we protect your personal information

We take security measures to help safeguard your personal information from unauthorized access and disclosure. However, no system can be completely secure. Therefore, although we take steps to secure your information, we do not promise, and you should not expect, that your personal information, chats, or other communications will always remain secure. Users should also take care with how they handle and disclose their personal information and should avoid sending personal information through insecure email. Please refer to the Federal Trade Commission's website at www.ftc.gov/bcp/menus/consumer/data.shtm for information about how to protect yourself against identity theft.

You agree that we may communicate with you electronically regarding security, privacy, and administrative issues, such as security breaches. We may post a notice on our Service if a security breach occurs. We may also send an email to you at the email address you have provided to us. You may have a legal right to receive this notice in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice), please notify us at privacy@support.chispa-app.com

Children's privacy

Although our Service is a general audience Service, we restrict the use of our service to individuals age 18 and above. We do not knowingly collect, maintain, or use personal information from children under the age of 18.

Onward transfer and consent to international processing

We are a growing corporation with users and operations in multiple countries, including the European Union. We have developed data practices designed to assure information is appropriately protected but we cannot always know where personal information may be accessed or processed. While our primary data centers are in the United States, we may transfer personal information or other information to our offices outside of the United States. In addition, we may employ other companies and individuals to perform functions on our behalf. If we disclose personal information to a third party or to our employees outside of the United States, we will seek assurances that any information we may provide to them is safeguarded adequately and in accordance with this Privacy Policy and the requirements of applicable privacy laws.

If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your personal data, including sensitive data, by Chispa from your region to countries which do not have data protection laws that provide the same level of protection that exists in countries in the European Economic Area, including the United States. By providing your personal information, you consent to any transfer and processing in accordance with this Policy.

No Rights of Third Parties

This Privacy Policy does not create rights enforceable by third parties or require disclosure of any personal information relating to users of the website.

Changes to this Privacy Policy

We will occasionally update this Privacy Policy to reflect changes in the law, our data collection and use practices, the features of our Service, or advances in technology. When we post changes to this Privacy Policy, we will revise the "last updated" date at the top of this Privacy Policy, which will be posted on the Services under “Settings” and also on chispa-app.com, and you should regularly check for the most recent version, which is the version that applies. If we make any material changes to this Privacy Policy, we will notify you of the changes by reasonable means, which could include notifications through the Services or via email. Please review the changes carefully. Your continued use of the Services following the posting of changes to this policy will mean you consent to and accept those changes. If you do not consent to such changes you can delete your account by following the instructions under Settings.

How to contact us

If you have any questions about this Privacy Policy, please contact us by email or postal mail as follows:

Privacy Officer
Affinity Apps LLC
P.O. Box 25458
Dallas, Texas 75225
privacy@support.chispa-app.com

Linked information:

  1. Cookies:

    A cookie is a small text file that is stored on a user's computer for record keeping purposes. Cookies can be either session cookies or persistent cookies. A session cookie expires when you close your browser and is used to make it easier for you to navigate our website. A persistent cookie remains on your hard drive for an extended period of time. Cookies on our website do not link to or store your personal information.

    For example, when you sign in to our website, we will record your user or member ID and the name associated with your user or member ID in the cookie file on your computer. We also may record your password in this cookie file, if you indicated that you would like your password saved for automatic sign-in. For security purposes, we will encrypt any usernames, passwords, and other user or member account-related data that we store in such cookies. In the case of sites and services that do not use a user or member ID, the cookie will contain a unique identifier. We may allow our authorized service providers to serve cookies from our website to allow them to assist us in various activities, such as doing analysis and research on the effectiveness of our site, content and advertising.

    We may allow third-parties, including advertising companies, analytics companies, and ad networks, to display advertisements on our site. These companies may use tracking technologies, such as cookies, to collect information about users who view or interact with their advertisements or our website or mobile applications. We do not provide any non-masked or non-obscured personal information to these third parties, but they may collect information about where you, or others who are using your device, saw and/or clicked on the advertisements they deliver (such as click stream information, browser type, time and date, subject of advertisements clicked or scrolled over, etc.), and possibly associate this information with your subsequent visits to the advertised websites or other data they have collected. They also may combine this information with personal information they collect from you to provide advertisements about goods and services likely to be of greater interest to you. The collection and use of that information is subject to the third-party's privacy policy. Some of these third-party advertising companies may be advertising networks that are members of the Network Advertising Initiative, which offers a single location to opt out of ad targeting from member companies and provides information about this behavioral advertising practice (www.networkadvertising.org). This policy covers the use of cookies by Match.com only and does not cover the use of cookies by any advertisers.

  2. Opting-Out of Advertising Cookies.

    You may opt out of our data collection for use by third party ad companies to provide targeted Match.com advertising to you when you visit other sites. Cookies are unique to each computer. Therefore, you must opt out separately on all computers you use. If you delete all of your cookies (specifically, the "Opt-Out" cookie), you will have to go through the opt-out process again to reactivate your opted-out status.

  3. Web Beacons:

    Web beacons (also known as clear gifs, pixel tags or web bugs) are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users or to access cookies. Unlike cookies which are stored on the user's computer hard drive, web beacons are embedded invisibly on the web pages (or in email) and are about the size of the period at the end of this sentence.

    Web beacons may be used to deliver or communicate with cookies, to count users who have visited certain pages and to understand usage patterns. We also may receive an anonymous identification number if you come to our site from an online advertisement displayed on a third-party website. Third parties may use anonymous information about your visits to our site and other websites in order to improve its products and services and provide advertisements about goods and services of interest to you.