March 2023
1. ABOUT US
2. OVERVIEW
3. WHAT TYPES OF INFORMATION DO WE COLLECT?
When you purchase our Platform you are contractually required to provide billing information including your name, address, and details of your chosen payment method for us to be able to process your transaction. Failure to provide this information means we will be unable to provide the requested Service/feature. At your option, you may choose to activate 2-factor authentication for your account through Auth0, a third-party provider of a user authentication service. Auth0’s service is based on providing you with a verification code, which you enter when logging into your Service to confirm your identity. Auth0 sends verification codes by text message to a telephone number that you provide. To facilitate your use of the Auth0 service, we will be required to share with Auth0 your telephone number to link it to your account with us and will therefore ask for your phone number for this purpose. Note that the Auth0 service is not part of the Service, and is subject to separate terms and conditions, including different policies concerning the collection, use, and disclosure of your Personal Data. We do not have control over Auth0. You will need to make your independent judgment regarding your interaction with them. Please note that if you decide to delete your NIL Donor Inc. account, we will delete your phone number from our records, but this will not affect Auth0 concerning the phone number we provided to Auth0 on your behalf. You will need to contact Auth0 directly concerning the management of your Auth0 account, including any deletion requests.
You may send messages on the Platform which may include or reveal Personal Data about you. Generally, we do not moderate or actively review the data which you include in messages sent between users, but this data is available to us and may be monitored for fraud, or where we suspect users of being under the age of 18, or of using our service for solicitation or any other violation of our Terms and Conditions or this notice. You should only include sensitive Personal Data (e.g., about health / sexual preferences) where you are comfortable to voluntarily make this data public and consent to us collecting/processing such data by this Privacy Policy.
You are encouraged to create a pseudonymous profile and are not required to include data in your profile that would allow you to be directly identified. If you want to remain anonymous to the public, please be careful about what you choose to share, especially if you upload photographs or choose a username that could allow you to be easily identified.
Where you have enabled the setting on your mobile device, with your permission, we will also collect your location data to help you identify other Platform members in your area who also have this feature switched on. You may turn off this feature through the location settings on your mobile device. We also collect your IP address which may reveal your general geographic location from your browser access to help us quickly and efficiently respond to inquiries and requests and help us protect against fraud. We also collect Personal Data through the use of cookies and other tracking devices. For more information about how we use cookies and other tracking devices.
Occasionally, we may receive Personal Data about you from third parties, such as from a credit card company or issuer concerning a disputed charge, or from another user of the Services respecting a complaint about your activities while using the Services; however, we do not seek or purchase Personal Data about you from third parties.
4. HOW DO WE USE YOUR INFORMATION?
We use the Personal Data and Non-Personal Data that we collect for the following purposes:to provide you with access to a forum focused on open-minded and discreet relationships, where members can search for and connect with other like-minded individuals. to allow users to find other users’ profiles based on preferences or user location and to allow you to create a profile that will appear on your chosen website(s) and to promote that profile to other users of the Services.
Our users communicate with each other through on-site mail messaging and instant messaging. While we do not, as a rule, moderate or monitor users’ private exchanges, we reserve the right to do so if we suspect users of being under the age of 18 or of using our service for solicitation or any other violation of our Terms and Conditions or Privacy Policy. As set out in further detail in our Terms and Conditions, submissions that appear on the public area of the Platform may be moderated and, if necessary, we reserve the right to edit, delete, remove, or not use any communication on a public area of the Platform. We also use Non-Personal Data. For example, we may collect and analyze aggregated and/or de-identified information to produce statistical data to help us improve our provision of the Services and manage user activity across the Platform. The following only applies to users residing in the EU. We collect your data as a Data Controller when we have a legal basis to do so. The following legal bases pertain to our collection of data:
5. HOW WILL WE SHARE YOUR INFORMATION?
We may provide Personal Data to third parties in the following limited circumstances:We will share your Data with third-party service providers that we have engaged to perform services on our behalf, based on our instructions, such as to our parent, subsidiary, or sister companies, or to advertising agencies, marketing agents, credit card payment processors, data processing and storage companies or organizations which provide administrative and support services to us. We limit our disclosure of your Personal Data to such third parties to that which is reasonably necessary for the purpose or service for which the third-party service provider is engaged. We also use contractual and other means to provide a comparable level of protection while the data is being processed by such third parties, including limiting such providers to using your Personal Data solely to provide us with the specific service for which those providers were engaged, and for no other purpose. You can obtain more information about our policies and practices concerning the use of Personal Data by third-party service providers by contacting [email protected].
to government bodies and law enforcement agencies, under warrant, order, subpoena, or statutory requirement. in connection with any legal proceedings or prospective legal proceedings involving ruby; and to otherwise establish, exercise or defend our legal rights and protect against misuse of our Platform (including providing information to third parties for fraud prevention and reducing credit risk), or to protect the personal safety and property or our users or the public as permitted by law. This means that if you provide false information or attempt to pose as someone else, information about you may be disclosed as part of any investigation into your actions.
as required, in connection with the sale, assignment, bankruptcy proceeding, or other transfer of the business or a portion of the business of our Platform, including a corporate merger, consolidation, restructuring, sale of assets, or other corporate change of our direct or indirect parent companies that affects us, as well as the insurance or securitization of our assets. In any such case, the recipient parties will be contractually required to keep the information confidential and use it only for the transaction, or proposed transaction, in question In the event a business transaction is completed, assignees or successors of our business or assets may use and disclose your data, as obtained from ruby only for the purposes set out in this Privacy Policy unless your further consent is obtained. We do not otherwise share, give, rent, or sell your Personal Data to any third parties unless you give us additional consent to do so. You should be aware that some of your Personal Data will be provided to, or otherwise visible to, other users of the Service as part of the normal operation of the Service (as set out in the terms or description of the service). For example, your username, profile information, and any information that you post to the Platform will be available to, and searchable by, other users of the Platform and Services. In the European Union, the lawful basis for this disclosure is voluntarily making the data public. If you are not comfortable making this data public, you can subscribe to our Hide Profile feature, which allows your profile to remain private and un-searchable. Other users of the Services, who may be in any country in the world where our Services are offered, may also receive notifications (on the Services, via email, or through device notifications) that promote your profile, including your nickname and your profile photo. Please note that we cannot prevent the content you post or share on our Platform or Services from being used by other users in a manner that may violate this Privacy Policy, the law, or your privacy, or from being shared or disclosed by other users. We may disclose Non-Personal Data in several circumstances including to third-party advertisers.
6. DATA TRANSFERS
As we have a global business operation, your Personal Data will be transferred to recipients located in jurisdictions outside your jurisdiction of residence, and your profile will be accessible to users all over the world. If you are concerned about this, you can stop using our Services at any time. These recipients include (NIL Office Inc.) and many of our service providers who are based in other countries. As a result, your Personal Data will be used, stored, and/or accessed in countries outside your jurisdiction of residence, including without limitation Canada and China. Some of these jurisdictions do not have an equivalent level of data protection laws as those in your country however we will take steps to ensure that the information receives the same level of protection as if it remained within your home country. In particular, if you are a resident of the European Union, whenever we transfer your data outside of Europe we will either: (a) ensure that the recipient is certified with the Privacy Shield Framework or that the country is deemed adequate by the European Commission; (b) put in place Standard Contractual Clauses or (c) implement appropriate safeguards approved by the European Commission to ensure an adequate level of protection in compliance with applicable data protection laws. You have a right to request details about the appropriate safeguard where this is documented (but it may be redacted to ensure confidentiality).
7. SECURITY
We take the protection of your Personal Data seriously. We implement appropriate measures and take steps to protect Personal Data against loss and theft as well as unauthorized access, disclosure, copying, use, and modification using security safeguards, including physical, organizational, and technological measures, commensurate with the sensitivity of your Personal Data. Employees who have access to your Data are made aware of the importance of keeping it confidential. Where we use service providers who might have access to your Personal Data, we require them to have privacy and security standards that are comparable to ours. We use contracts and other measures with our service providers to maintain the confidentiality and security of your data and to prevent it from being used for any other purpose. Please be aware that no data security measures can guarantee complete security. You should also take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, relying on two-factor authentication and keeping your log-in and password private.
8. HOW LONG DO WE KEEP THE PERSONAL DATA WE COLLECT?
We keep your Data only if it is required for the purposes for which it was collected, or as otherwise permitted by applicable law, after which we delete or de-identify your data, rendering it Non-Personal Data. In general, we retain your Data for a period corresponding to a statute of limitation setting out the period during which legal claims may be filed in court. For example, we’ll retain your Data during the statute of the limitation period, to maintain an accurate record of your dealings with us and, as applicable, assert or defend against a legal claim. We automatically delete data where an account has been inactive (e.g., no messages sent, etc.) for 18 months. As a rule, we will hold purchase information for 6 months past account deletion to ensure that we can deal with any chargeback/payment penalties. However, in some circumstances, we may retain Personal Data for other periods, for instance where we are required to do so by legal, tax, and accounting requirements, or if required to do so by a legal process, legal authority, or other governmental entity having authority to make the request, for so long as required.
9. CHILDREN
The Platform and Services are not for use by children under the age of 18 years. Accordingly, we do not knowingly collect, store, share, or use the Personal Data of children under 18 years. If you are under the age of 18 years, please do not use this Service or provide any Personal Data, even if the website prompts you.
10. YOUR RIGHTS
You could exercise the following rights:You have the right to withdraw your consent at any time, subject to legal and contractual restrictions. For example, if you wish to opt out of receiving electronic marketing communications, you can change your settings in your account on the website, use the ‘unsubscribe’ link provided in our emails, or otherwise contact us directly and we will stop sending you communications. Note that your withdrawal of such consent may limit your ability to fully use the Services.
You have the right to request access to and obtain a copy of any of your Personal Data that we may hold, to request correction of any inaccurate data relating to you, and to request the deletion of your Personal Data under certain circumstances. Please note that you can hide certain information visible to public users of the Platform at any time by going to the ‘Manage Profile’ or ‘Account Settings’ sections in your account.
Where the Personal Data is processed by automatic means, you have the right to receive all such Personal Data which you have provided us in a structured, commonly used, and machine-readable format, and also to require us to transmit it to another controller where this is technically feasible.
You have the right to object to our use of your Personal Data (including profiling) for direct marketing purposes, such as when we use your Personal Data to inform you of our promotions. You also have the right to complain to the privacy commissioner with jurisdiction over your place of residence if you consider that the processing of your Personal Data infringes applicable law (although we ask you to try to resolve any complaints with us first). If you would like to exercise any of these rights, please contact us using the contact information provided
11. COOKIES AND OTHER TRACKING
Where we have the necessary permissions and consent by local laws, we use cookies, clear GIFs, third-party analytics, and other tracking mechanisms to track your use of our Platform and Services. As you use our sites or apps, these tracking mechanisms may automatically collect information such as your IP address, browser type, and operating system; web pages you view; links you click; how you move through the Services and the length of time you use the Services or features or pages of the Services; and the referring URL, or the webpage that led you to our Platform. We may combine this information with other Personal Data we collect about you for statistical purposes, for measuring the effectiveness of advertising, for fraud detection and to assist our customer service representatives in responding to your inquiries. Provided we have obtained the necessary permissions and consents by local laws, we use these tools only to provide you with a more personalized user experience, to better understand your needs and preferences, to provide you with content (including advertising) that is most relevant to you and to monitor trends respecting the usage of our site and apps. Do-Not-Track. Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies or opting out of ad networks as described further in this section). Cookies. Cookies are small text files that are placed on your computer’s hard drive, through your web browser, for record-keeping purposes. We might use cookies to uniquely identify your browser/device/IP address, to help us to process your transactions and requests, to track aggregate and statistical information about user activity, and to display advertising both on our Platform and third-party sites. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. If you disable cookies some features of our Platform may not function. Further information may be found at www.allaboutcookies.org. Clear GIFs. Clear GIFs (a.k.a. web beacons, web bugs, or pixel tags) are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, though, clear GIFs are embedded invisibly on web pages, not stored on your hard drive. These “images” are automatically loaded to your browser/device when you visit our website or open an HTML format email message from us, thereby letting us know if a certain page was visited or an email message was opened. Clear GIFs allow us to record simple user actions related to our websites and to email communications received from us, to help us determine the usage and effectiveness of our site and communications. We might use clear GIFs to track the activities of our visitors and app users, help us manage content, and compile statistics about usage. We and our third-party service providers also might use clear GIFs in HTML e-mails to our customers, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded. These can be blocked either by using a third-party application such as Ghostery (https://www.ghostery.com)(https://www.ghostery.com), or, in the case of emails, by changing your settings to prevent images from being downloaded (where your email client supports this functionality). Third-Party Analytics. We also use automated devices and applications, such as Google Analytics (https://support.google.com/analytics/answer/6004245) (to opt out, go here (https://tools.google.com/dlpage/gaoptout) ), and AppsFlyer (to opt out, go here (https://www.appsflyer.com/privacy-policy/) to evaluate usage of our Platform and the Services we provide. We use these tools to obtain aggregated statistical information about the use of our Services to help us improve our services, performance, and user experiences. These analytics providers may use cookies and other technologies to perform their services and may combine the information that they collect about you on our Platform with other information that they have collected about you from your use of other sites. This Privacy Policy does not cover the collection, use, and disclosure of the tracking data collected by third-party analytics providers: for further information please see the relevant party’s privacy policy. For a list of additional third-party analytics providers, we may be using from time to time. Third-Party Ad Networks. We may use third parties such as network advertisers to serve advertisements on our Platform and third-party websites or other media and to evaluate the success of our advertising campaigns. This enables us and these third parties to target your browser with advertisements for products and services in which you might be interested, based on inferences made from browser activity. Third-party ad network providers, advertisers, sponsors, and/or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs), and other tracking technologies to measure the effectiveness of their ads and to personalize advertising content to you. These third-party cookies and other technologies are governed by each third party’s specific privacy policy, not this one. In some situations, we may provide these third-party advertisers with limited information about users (e.g., IP address and basic demographic information solely to reconcile payments for third-party advertising), but we do not disclose details such as your name or contact information. You may be able to avoid targeted ads by certain ad networks by blocking cookies (see your browser’s “Help” menu for information on how to do this); however, our Platform may not work if you block or disable cookies. For a list of network advertisers, we may use. For participating ad networks and providers of interest-based advertising, you may opt out of receiving online behavioral advertising by clicking on the AdChoices icon located in the top right-hand corner of any of our websites or the ads placed on our sites, reCAPTCHA. We use the reCAPTCHA service provided by Google Inc. (Google) to protect your submissions via internet submission forms on this site. This plugin checks if you are a person to prevent certain website functions from being abused by spam bots. This plugin query includes the sending of the IP address and possibly other data required by Google for the Google reCAPTCHA service. For this purpose, your input will be communicated to and used by Google. However, your IP address is previously truncated by Google within member states of the EU or in other states which are party to the agreement on the European Economic Area and is, as such, anonymized. Only in exceptional cases is a full IP address transmitted to a Google server in the USA and truncated there. On behalf of the operator of this website, Google will use this information to evaluate your use of this service. The IP address provided by reCAPTCHA from your browser shall not be merged with any other data from Google. This data collection is subject to the data protection regulations of Google. For more information about Google’s privacy policy, please visit https:www.google.com/intl/en/policies/privacy/. By using the reCAPTCHA service, you consent to the processing of data about you by Google in the manner and for the purposes set out above. Third-Party Links. Our Services may contain links to third-party websites. When you leave our websites and use the third-party website, that third-party website may collect your IP address and other Personal Data, by its privacy policy. Any access to and use of such linked websites, and any Personal Data collected in connection therewith, is not governed by this Privacy Policy, but rather by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites.
12. DIRECT MARKETING
Where we have necessary permissions and consents by local laws, (a) we will send you marketing information about our Platform and our Services, and about other products and services we offer where we legitimately believe this may be of interest to you, and (b) this content will be personalized. Where you have specifically requested marketing information from the partners that we work with or have expressly indicated that you would like to receive details from other ruby Corp. group entities we will also send promotional offers. Depending on your marketing preferences, marketing may be carried out by email, push notifications, or other electronic channels (see our Cookie Notice in Annex A for further details). If you change your mind, you can always choose to unsubscribe from receiving these marketing communications. You can do this by clicking the “unsubscribe” link on any of our emails, via the “Manage Profile” feature of the Platform.
13. PROFILING
We use the Personal Data that you provide in your user profile combined with certain algorithms and machine-based learning to improve our Platform search function and to present profiles to you which are more likely to be of interest – based on the demographic data of individuals with whom you interact to present more profiles of other similar users that you appear to be interested in. You can elect to change your preferences at any time on your profiling. This does not amount to “automated decision making” which would significantly impact you.
14. ACCESS AND UPDATES
You could (i) opt out of certain communications, (ii) modify/update Personal Data you have provided to us, and (iii) hide certain information visible to public users of the Platform at any time by going to the ‘Manage Profile’ or ‘Account Settings’ sections on your profile. Please be aware that it may take several hours for any custom changes you make to take effect on the public areas of the system. Please also note that changing or deleting your information through the ‘Manage Profile’ or ‘Account Settings’ section of the system, or opting out of email notifications from us, will only change or delete the data in our database for future activities and communications.
15. CONTACT US
it, unless we have your consent or as otherwise required by law) where: You have the right to restrict our processing of your Personal Data (meaning we could only storeright to access Personal Data we hold about you and to address any concerns you may have over our policies and practices. In addition, you have the right to obtain information regarding our policies and practices as they relate to the collection, use, and disclosure of Personal Data, including concerning the transfer and storage of your information outside your home jurisdiction, and to request updates to, or correction of, your data. For any such requests, or any questions related to our privacy practices or any of the terms or conditions of this Privacy Policy, or if you wish to complain to us in writing about how we have handled your Personal Data. All other inquiries, which do not relate to privacy issues or concerns, should be sent using our section. We aim to resolve all complaints promptly. For residents of the European Union, if you are not satisfied with any resolutions proposed, or if you have concerns with the processing of data, you may contact your local data protection authority, a list of which is found here.
16. IMPORTANT ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS
This section provides information for California residents. Under California privacy laws, including the California Consumer Privacy Act (“CCPA”), we provide California residents information about how we collect and process their Personal Information. Categories of Personal Information that We Collect, Disclose and Sell At ruby, we only collect and process the same Personal Data of California residents, as we collect from our users throughout the world to allow you to use our Services. This information is outlined in Sections 2-5 of this Privacy Policy. For a California-specific explanation of the categories of Personal Data we collect and how we use that Personal Data, please refer below to find the categories Personal Data. Personal Information of California Residents Categories Collected, Processed, Shared with Third PartiesIf you would like to exercise any of these rights, please contact us using the contact information provided in Section 15. California Residents’ Rights California law grants California residents certain rights and imposes restrictions on business practices as set forth below. Do-Not-Sell. We do not sell your Personal Data. Verifiable Requests for Copy, Deletion, and Right to Know. Subject to certain exceptions, California residents have the right to make the following requests, at no charge, up to twice every 12 months: Right of Deletion: California residents have the right to request deletion of the Data that we have collected about them, subject to certain exemptions, and to have such Personal Data deleted, except where necessary for specific purposes exempt under the law. Right to a Copy: California residents have the right to request a copy of the specific pieces of Personal Data that we have collected about them in the prior 12 months and to have this delivered, free of charge, either (a) by mail or (b) electronically in a portable and, to the extent technically feasible, a readily useable format that allows the individual to transmit this information to another entity without hindrance. Right to Know: California residents have the right to request that we provide them with certain information about how we have handled their personal information in the prior 12 months, including the:
Submitting Requests. Requests to exercise the right of deletion, right to a copy, and/or the right to know may be submitted by creating a customer ticket We will respond to verifiable requests received from California consumers as required by law. Incentives and Discrimination. The CCPA prohibits discrimination against California residents for exercising their rights under the CCPA and imposes requirements on any financial incentives offered to California residents related to their personal information. Discrimination: We respect your privacy rights. We do not discriminate against residents who exercise their rights under CCPA. California Privacy Rights under California’s Shine-the-Light Law Under California’s “Shine the Light” law (Cal. Civ. Code § 1798.83), California residents who provide us certain Personal Data are entitled to request and obtain from us, free of charge, information about the Personal Data (if any) we have shared with third parties for their direct marketing use. Such requests may be made once per calendar year for information about any relevant third-party sharing in the prior calendar year. California residents who would like to make such a request may submit a request in writing (see Section 15 “Contact Us” for ways to reach us).