Privacy and Communications Policy

This Privacy and Communications Policy ("Policy") is effective as of April __, 2019.

This Policy sets forth how Couples Clique, LLC a Wisconsin limited liability company, in operation of www.couplesclique.com (“Website”) and our mobile app (“App”) collect and use the information you provide to us and certain other information that we automatically collect through your use of our Website, App or through any communications with us.

If you have any general questions or concerns about this Policy, you may contact us by sending an email with your questions, comments or concerns to nick.bush@couplesclique.com.

MODIFICATIONS TO THIS POLICY

If we decide at any time to change this Policy, we will revise the effective revision date posted at the top of this Policy and we will also notify you by posting a notice of the change prominently on our home page and/or upon the next time you access our App. Failure to opt-out after receiving notice and following the opt-out instructions contained in the notice shall be deemed to be your assent to any such changes.

HOW WE COLLECT PERSONAL INFORMATION

There are a variety of ways in which you may submit certain personal data (personally identifiable information) on our App. We collect the following specific items of personally identifying information (collectively "Identity Information") that you submit through your use of our App: your first and last name, email address and mobile phone number.

Forms

When you provide any Identity Information through any form contained on our Website and/or our App in order to contact us or send us a message, we collect and store this information. We may use your email or any other Identity Information you provide as expressly set forth in this Policy.

Membership & Log-In

When you register and create an account to access our couples connection services as a registered user, we collect the Identity Information you provide during registration and use it as set forth in the remainder of this Policy. You will also be asked to create and provide a user name and password each time you log-in to access your account and we collect and store this information in our database.

Demographic Information

When you provide your age and gender (which is collectively known as "Demographic Information") we collect and store all Demographic Information. We will generally use this information internally to assist us analyze the profiles of who our App users are and our web traffic in general. We also may share this information in association with your Identity Information as specifically stated in this Policy.

Personal Information from Children Under 13

Children under the age of 13 are expressly prohibited from submitting or posting any Identity Information on our App. If it does come to our attention that any child under the age of 13 has submitted any personal information to our App, we will delete all such information that we have collected immediately. If you are a parent or guardian and you discover that your child under the age of 13 has submitted any of his or her Identity Information without your permission or consent, we will remove the information immediately upon your request. All requests should be made by email and sent to nick.bush@couplesclique.com. Please include your child's name and a description of the type of information you think he or she may have submitted via our App.

HOW WE AUTOMATICALLY COLLECT NON-PERSONAL INFORMATION

When you access our App, we collect and store through our host provider certain non-personally identifying information sent automatically by your browser using standard web server logs and automatic data collection tools such as cookies and web beacons. This information may include your IP address, which may tell us your general location information such as your country and sometimes your city, state and/or zip code, the domain name from which you access our App, your browser type and language, the pages you access, the date and time you access pages on our App and your operating system version. We also may determine what technology is available through your browser in order to provide you with the most appropriate version of any of our web pages. For example, we may determine that you have installed a version of Flash, and we will then send you the appropriate Flash version of the web page rather than an HTML page. We may also use this information to redirect you to a different version of our App if you are accessing our App through a mobile or similar device.

Device-Specific Information

We may automatically collect device-specific information about your mobile and other devices such as the type of device you are using, mobile network information including phone numbers, device model, manufacturer, screen resolution, device capabilities, service provider, preferred user language and your page views. We do this to help us determine which aspects of the App work best for mobile traffic and which mobile marketing campaigns work best for the business, including mobile advertising, mobile search marketing, text campaigns, and desktop promotion of mobile sites and services. This information does not identify your device uniquely.

Mobile App Use Information

We collect certain information from your mobile device through our App which may include physical device location information such as your phone’s zip code, Demographic Information such as age and gender, the unique device ID number and/or any application use data which is used by our business for internal analysis and research purposes. We also collect and store use information regarding your use of our App, such as how frequently you use the App, how much time you spend on the App, where you spend time on the App, etc. We do this for internal analysis and research in order to enhance the application or offer additional applications. We also use this information as expressly stated in this Policy.

Cookies & Tracking Use Policy

We along with third parties that assist us to operate our and Website and App may monitor your use of our Website and our App through cookies, web beacons and other “automatic data collection tools." Unless you have adjusted your browser setting to refuse all cookies, some cookies are placed on your browser immediately as soon as you visit our site. Cookies and similar collection tools are files with a small amount of data, which may include an a unique identifier. Cookies are sent to your browser from a App and transferred to your device. We reserve the right to monitor your use of our App and track you as described in this Cookies policy by the use of any automatic data collection tools at all times and you consent to the use of these tools when you use and access our App.

Our App uses both "first-party cookies" and "third-party cookies." First-party cookies are those used by our App each time you visit our App. Third-party cookies are cookies that are set by a third-party source other than our App. We do not have access or control over these cookies. We also use both "persistent cookies" that remain on your device for the period of time specified in the cookie (these cookies are activated each time you visit our App), and "session cookies," which allows us to track your actions on our App during a browser session. Each time you open up a browser window and close the browser window represents a single browser session. All session cookies are created temporarily and are deleted once you close your browser window.

Both the first-party and third-party cookies and tracking technologies used on our App can be broadly divided into the following categories:

-Necessary cookies help make our App usable by enabling basic functions like page navigation and access to secure areas of the App. Our App cannot function properly without these cookies.

-Statistic cookies helps us understand how visitors interact with Apps by collecting and reporting information anonymously.

-Marketing cookies are used on our App by Google and other third-parties to track visitors across the web. The intention is to display ads that are relevant and engaging for the individual Google user.

First-Party Cookies/Tracking Use

App Use: We use automatic data collection tools to track and record your App and Website use and activity data, including the pages you view and how long you spend on each page or portion of our App, the links you click on, the features of our App you access, whether you are a new vs. repeat visitor or in order to monitor your interactions with any video or other content that you access on our App ("Use Information"). This is done primarily for App traffic and general user analysis purposes. We also do this to help measure and research the effectiveness of the features contained on our App.

Analytics Services: We may use third party web analytics services, such as Google Analytics, in order to collect information about your use of our App. We pass a "first party cookie" onto your browser directly from our App when we use Google Analytics. You may opt-out of Google Analytics by using Google's Browser Add-on at https://tools.google.com/dlpage/gaoptout.

User Preferences: We use automatic data collection tools to identify and recognize your browser as a previous visitor to our Website and save and remember any user preferences that may have been set during a previous visit. We also store specific user preferences and settings on our App using cookies and/or similar session identifiers to help you navigate and access certain features on our App.

Third-Party Cookies/Tracking Use

Here are the specific third-party cookies/cookies providers we use on our App:

A. Push Notification Service Sharing Disclosure & Consent

We offer a free push notification service through Google firebase cloud messaging. Push tokens from firebase are grabbed and bundled with your user ID to distribute the notifications to you. We store all push tokens. This bundled information is stored and used internally and is not shared. Our push notification service enables Google to collect certain Identity Information and certain other information from your browser or device, which generally helps provide developers with functionality to target and personalize the notifications they send to end users. This data collected includes your mobile advertising identifiers (such as Apple IDFAs and Android Advertising identifiers), your email address, your IP address, your device push token, precise location (e.g., GPS coordinates) data, network information, language, your time zone, and your product and privacy preferences. IF YOU ELECT TO USE OUR PUSH NOTIFICATION SERVICE, SUCH USE SHALL BE DEEMED TO BE YOUR CONSENT TO THE COLLECTION, SHARING, USE, MARKETING, LICENSING, SALE, STORAGE, OR EXPLOITATION OF SUCH INFORMATION IN ANY MANNER BY GOOGLE, TO THE MAXIMUM EXTENT PERMITTED BY LAW, IF ANY, WHICH MAY INCLUDE USING SUCH INFORMATION FOR CROSS-APP, CROSS-DEVICE, AND OTHER INTEREST-BASED (BEHAVIORAL) ADVERTISING, ANALYTICS AND MARKET RESEARCH.

B. Google Maps. Each time you use Google Maps through our App or App, your device GPS location data and unique device identifiers (including your Google advertising ID (GAID) via the Google Maps API) is collected and used by Google according to its privacy policy.

C. Google NID cookie. Your browser sends this cookie with requests to Google’s sites. The NID cookie contains a unique ID Google uses to remember your preferences and other information and to help customize ads on Google properties, like Google Search. Google uses such cookies to remember your most recent searches, your previous interactions with an advertiser’s ads or search results, and your visits to an advertiser’s website to show you customized ads on Google.

How To Manage Cookies

You can block our cookies or third-party cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies), you may not be able to use all or parts of our site in the manner intended.

Your Internet browser allows you to change your cookie settings in the 'options' or 'preferences' menu of your browser. Please visit the following link for more information on these settings in various browsers:

https://www.thewindowsclub.com/disable-enable-cookies-internet-explorer

For even more information about deleting or blocking cookies, please visit: http://www.aboutcookies.org/Default.aspx?page=2

Our Data Processors & Subprocessors

A data processor is any third-party that we use to operate our App or provide our Services to you who has or potentially will have access to or process any personal data you provide to us. These data processors may engage different types of subprocessors to perform various functions. This limited access is incidental to the services being provided by such third parties to us to operate our App and/or to provide our Services to you and no permission or consent is granted by us to use or disclose this information in any manner other than as necessary to provide the applicable services to us or to facilitate any transactions with you.

In addition, we require all of our data processors and subprocessors to satisfy the requirements of the GDPR in terms of data protection and use, including but not limited to the requirements to:

  • Process personal data in accordance with our documented instructions;
  • Use only personnel who are reliable and subject to a contractually binding obligation to observe data privacy and security, to the extent applicable, pursuant to applicable data protection laws including the GDPR, in connection with their subprocessing activities;
  • Provide regular training in security and data protection to personnel to whom they grant access to any personal data;
  • Implement and maintain appropriate technical and organizational measures (including measures consistent with those to which we may be contractually committed to adhere to insofar as they are equally relevant to the subprocessor’s processing of personal data on our behalf);
  • Promptly inform us about any actual or potential data breaches; and
  • Cooperate with us in order to deal with requests from data controllers, data subjects or data protection authorities, as applicable.

We use the following data processors:

  1. Infrastructure & Data Storage

Hosting/Data Storage. We use Linode to host our Website and Amazon Web Services to store your data on their servers.

B. Specific Services. N/A

Social Media Features and Widgets

We may also provide access to services or features on our Website that enables you to share information with certain social networks and interact with us on our social media fan pages or other social media platforms that we may utilize. This may include the Facebook "Like" or share buttons or the Facebook "Comments" feature, social media "follow-us" buttons, etc., all of which are administered via third party applications or scripts (plugins). (For example, Facebook will attempt to track your use on our Website by placing Javascript code through the "like" button and that piece of code then allows Facebook to run a script on your browser which can set cookies and make more tracking requests). Your use of these features may result in the collection or sharing of information about you by these third party social media apps. This may include collecting your IP address, tracking your use on our Website and other third party websites containing the same social media features, including the pages you visit, duration, time, etc., through the use of a cookie or other unique identifier placed on your browser by such third parties. Your interactions with these social media features are governed by the privacy policy of the party that provides the specific feature or application. You should carefully review the privacy policies and settings on those specific social media sites. We shall, under no circumstances, have any liability to you whatsoever for the information collection and use/disclosure practices of any such third party that has provided or made available any social media feature or application that you use on our Website.

HOW WE USE/SHARE YOUR INFORMATION

Informational Use of Emails

We use the e-mail address provided by our registered users and users who check-out to send information and notifications to you related to your use of our App, but only if you have elected to receive such email communications from us. You can opt-out of receiving any promotional emails or newsletters at any time by either clicking "unsubscribe" in the body of the email communication and following the opt-out procedure contained in the email or by sending an email to: nick.bush@couplesclique.com and requesting to opt-out of receiving such communications.

Do We Sell Your Identity Information?

We make every effort to respect your privacy and we will never sell, license or disclose any of your Identity Information, by itself or bundled with any Use Information or other information you provide or that we collect to any third parties for any purpose not expressly set forth in this Policy without your express written consent. We only share or disclose any Identity Information or other information collected from You as expressly set forth in this Policy.

Required Disclosures

We may disclose certain Identity information if: i) requested via a subpoena, court order, or local, state, federal or international law enforcement request to release any such information; or ii) in order to investigate and help prevent security threats, fraud or other malicious activity; or iii) to protect our rights or protect our property, or any or the rights of our customers or other third parties.

Communications

When you visit our App or send e-mails to us, you are communicating with us electronically. You consent to receive communications from us electronically. You agree that all agreements, notices and other communications that we provide to you electronically satisfy any legal requirement that such communications be in writing. If you send us an email communication, call us or send a written correspondence for any reason, we may create a file and store your email and other Identity Information specific to you. We generally will maintain a record and keep notes of all communications with you. All messages transmitted by you on our App or to us shall not be treated as confidential and shall be deemed to be accessible to the general public. You should not transmit any communications or correspondences to us that you intend only the intended recipient(s) read. Notice is hereby given that all messages or electronic data transmitted onto our App can and may be read by us, regardless of whether we are the intended recipient of any such message(s).

THIRD PARTY ADVERTISERS PRIVACY PRACTICES

YOU MAY BE GIVEN THE OPPORTUNITY THROUGH OUR APP OR OUR APP TO PURCHASE OR OBTAIN MORE INFORMATION REGARDING CERTAIN CONTENT, PRODUCTS OR SERVICES THAT ARE SOLD BY THIRD PARTIES OR ANY EVENTS HOSTED BY THIRD PARTIES BY CLICKING ON ANY THIRD PARTY LINKS CONTAINED ON OUR APP OR APP. BY USING OUR APP INCLUDING SUBMITTING ANY REQUESTED INFORMATION, YOU AFFIRMATIVELY CONSENT TO HAVE THAT INFORMATION SHARED WITH THESE THIRD PARTIES FOR THE LIMITED PURPOSES STATED HEREIN. ANY INFORMATION USED BY ANY THIRD PARTIES MAY BE SUBJECT TO A DIFFERENT SET OF PRACTICES THAN THOSE DESCRIBED UNDER THIS POLICY AND WE ARE NOT RESPONSIBLE FOR THE PRIVACY PRACTICES OF ANY OF SUCH THIRD PARTIES. YOU SHOULD READ THE PRIVACY POLICY CONTAINED ON THE APP OF ANY THIRD PARTIES BEFORE YOU PROVIDE ANY INFORMATION TO THAT PARTY. YOU AGREE THAT WE SHALL NOT, UNDER ANY CIRCUMSTANCES, HAVE ANY LIABILITY TO YOU FOR ANY DAMAGES OF ANY KIND WHATSOEVER FOR THE MANNER IN WHICH ANY SUCH THIRD PARTIES USE OR DISCLOSE ANY PERSONAL, BILLING OR OTHER INFORMATION YOU PROVIDE VOLUNTARILY, OR THAT IS COLLECTED BY THOSE APPS, THROUGH YOUR ACCESS OR USE OF OUR APP OR OUR APP.

Your California Resident Privacy Rights

California Civil Code Section 1798.83 permits California residents to request certain information regarding our disclosure of their personal information to third parties for their direct marketing purposes. California law also allows California residents to opt-out of having this information disclosed. If You are a California resident and desire to make such a request, please contact nick.bush@couplesclique.com. Please include the words "California Privacy Disclosure Request" in the subject line.

HOW WE PROTECT YOUR INFORMATION

We encrypt all information your provide during transmission using Secure Sockets Layer (SSL) encryption. We make no guarantee, warranty or representation that your any information you provide through our App or on our App will remain secure at all times from any illegal or unauthorized access of the information by third parties. We shall not, under any circumstances, be held responsible or liable for information or transmissions that are accessed by third parties illegally or without authorization through our App and/or network. We will report any unauthorized access of your information promptly upon discovery, and we will use our best efforts to remedy any security vulnerability that contributed to the unauthorized access.

GENERAL INFORMATION

Information Storage And International Transfer

Any Identity information and all other information which we collect on our App will be stored and processed in our servers located in the United States. If you reside outside the United States, you consent to the collection, transfer, storage and processing of any information from your country to the United States.

How to Update, Change or View Your Identity Information

If you would like to request any changes or updates to any Identity Information you have provided to us, or if you would like to view any information we have collected from your use of our App, please contact us and request the same by sending an email to: nick.bush@couplesclique.com. Please include the words "Personal Information Request." If you make any information requests, we will require that you provide proof of your identity, which may include providing us with a copy of a driver's license, social security card and/or birth certificate. We also reserve the right to require that you sign and provide us with a notarized affidavit verifying your identity before we update or release any information to you.

Successors

Upon any acquisition, merger, sale or other change of control of our business/organization, we reserve the right to transfer any Identity information you have submitted to our App as part of the property owned by us to our successor resulting from such merger, acquisition, sale, etc. In the event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors' rights generally, We reserve the right to transfer your Identity Information to protect any of the our rights or as required by law.