Welcome to the Golovefy Privacy Policy (“Policy”)! This
explains how we collect, store, protect, and share your information, and
with whom we share it. We suggest you read this in conjunction with our
Terms and Conditions of Use.
Whilst you’re enjoying the Golovefy mobile application
(“App”), our websites and microsites (such as Golovefy.com) or
using our digital products and services (such as our competitions or
surveys) (together, referred to in this Privacy Policy as our
“Sites”), we collect some information about you. In addition,
you may choose to use the App or Sites to share information with other
users, including your friends and contacts (“Users”). We may
also need to share your information sometimes. The App and Sites are
global, and your information will be sent to and used in the United States
and the UK regardless of the country you reside in. This Policy explains
how we protect your personal data when we transfer it overseas, so please
read very carefully!
Who we are.
The App and Sites are operated by the “Daesil international
Consulting Group” (also referred to in this policy as
“we” or “us”) which is a controller of personal
information collected and processed through the Golovefy App and Sites.
1. COLLECTION OF INFORMATION.
Registration Information
When you download the App and create an account (“Account”),
we may collect certain information (“Registration
Information”) about you, such as:
Name;
Username;
Email address;
Mobile number;
Gender identity;
Date of birth;
Sexual preference;
Photographs;
Location; and
Login information for social media accounts that you connect to your
Golovefy Account (this could include, for example, your Facebook and
Instagram accounts).
For more information about this, see “Linking other Accounts to
Golovefy” in section 7 below.
Once you register, you will be able to review and change this information
at any time just by logging in to Golovefy (other than your date of birth
and location (which, if you have given Golovefy access to your location in
your device settings, is automatically updated based on the location of
your device)).
It is your responsibility to ensure that your account details are kept up
to date.
If your phone number changes, please ensure that you update this in your
account.
The information we collect helps to enhance the App and verify our Users
(robots are not welcome!). Registration Information such as your sexual
preference, name and username may be visible to other Users who view your
profile page.
For Users who are California residents, the data we may collect falls
within the following categories of “personal information”, as
defined by the California Consumer Privacy Act (CCPA):
A. Identifiers, such as name and location;
B. Personal information, as defined in the California customer records
law, such as contact (including email and telephone number) and financial
information;
C. Characteristics of protected classifications under California or
federal law (if you choose to provide them), such as age, gender identity,
marital status, sexual orientation, race, ancestry, national origin,
religion, and medical conditions;
D. Commercial information, such as transaction information and purchase
history;
E. Biometric information;
F. Internet or network activity information, such as browsing history and
interactions with our Sites and App;
G. Geolocation data, such as mobile device location;
H. Audio, electronic, visual and similar information, such as photos and
videos;
I. Professional or employment-related information, such as work history
and prior employer;
J. Non-public education information; and
K. Inferences drawn from any of the personal information listed above to
create a profile or summary about, for example, an individual’s
preferences and characteristics.
Profile Information
We recommend and encourage you (and all our members) to think carefully
about the information you disclose about yourself. We also do not
recommend that you put email addresses, URLs, instant messaging details,
phone numbers, full names or addresses, credit card details, national
identity numbers, drivers’ licence details and other sensitive
information which is open to abuse and misuse on your profile.
When you post information about yourself or use the messaging function to
communicate with other Users, the amount of personal information you share
is at your own risk. Please see Section 4 below for more information on
who can access what you post on Golovefy.
Profile Verification Information (Including Biometric Information)
For safety and security and to ensure you have the best possible user
experience, we require Users to verify their accounts and might ask for
your phone number and, in some instances, we might also ask that you carry
out photo verification. We want to make sure you are not a robot! And we
also want to avoid fake Golovefy accounts being created which can be used
for malicious activities and cybercrime – they threaten the Golovefy
network and spoil things for everyone. This verification might be required
by us for the prevention of fraud. You can also verify your photo on a
voluntary basis (to add the blue ‘verified’ badge to your
profile).
If you choose to verify your profile photo, we will scan each photo that
you submit. The scan may include the use of facial recognition technology
so that we can compare the photo you submit to your profile photo, to help
ensure that you are who you say you are. We do not add the verification
photos to your profile. We retain the scans so that we can verify you in
the future and for our record-keeping purposes until we no longer need
them for such purposes or for three years after your last interaction with
us, whichever occurs first. After the applicable retention period expires,
we take commercially reasonable steps to permanently and securely delete
the scans from our systems.
Purchases Information
If you decide to purchase any of our premium services, we will process
your payment information and retain this securely for the prevention of
fraud and for audit/tax purposes.
Golovefy uses automated decisions to prevent fraudulent payment
transactions being processed as part of its anti-fraud procedures. In
order to do this, our systems check payment transactions for behavior that
indicates breaches of our Terms and Conditions of Use. If a transaction
meets certain criteria that demonstrate that the Terms and Conditions of
Use are likely to have been breached and the transaction is likely to be
fraudulent, the relevant transaction may automatically be blocked. Where a
transaction is blocked, the user will be notified that their transaction
cannot be processed and affected Users can contact Golovefy to contest the
decision.
Please note that if your account is blocked for any reason, any account(s)
that you have on other Golovefy Group platforms/applications, such as
Badoo, may also be blocked as part of our anti-spam and anti-fraud
procedures.
Geolocation Information
If you have given Golovefy access to your location in your device
settings, when you use your mobile, we will collect information about WiFi
access points as well as other location information about your longitude
and latitude and may save your device’s coordinates to offer certain
features to you. This information helps us identify your physical location
and we use it to personalize the App and make it easier for you to
interact with other Users, by enabling the general locality information to
be displayed to Users seeing your profile and showing you the profiles of
other Users who are near you.
If you have given Golovefy access to your location, but wish to turn this
off, you can do so by the following methods:
iPhone app — settings, privacy, location services, Golovefy
Android — settings, location, Golovefy, permissions, location
Device information
We may collect information about your device when you use the App
including the unique device identifier, device model, and operating
system, for a number of purposes, as set out in this policy. In addition,
if you permit us to do so, the App may access your device’s address
book solely in order to add someone to your contacts.
Links
We may keep track of how you interact with links available on Golovefy
including third party services by redirecting clicks or through other
means. We may share aggregate click statistics such as how many times a
particular link was clicked on.
Golovefy Success Stories, Surveys and other Contributions
From time to time, we run surveys for research purposes and we may contact
you to find out if you would like to take part. We may also contact you to
find out if you would like to provide feedback, a testimonial or take part
in marketing campaigns (for example, if you let us know that you have
found a match on the App, we may contact you to ask if you would be happy
to feature in advertising for Golovefy). Such surveys and marketing
campaigns are optional and more information will be provided at the point
of contact.
When you Contact Customer Support
If you contact our Customer Support team, we will receive your email
address, and may track your IP address, as well as the information you
send to us to help resolve your query. We will keep records of our
communications with you, including any complaints that we receive from you
about other Users (and from other Users about you) for 6 years after
deletion of your account.
Cookies and similar technologies
When you visit our Sites or when you use our App, we may collect personal
data from you automatically by using cookies or similar technologies. A
cookie is a small file that can be placed on your device or browser that
allows us to recognise and remember you.
If you would like to find out more about cookies, including how we use
them and what choices are available to you, please refer to our Cookie
Policy.
2. USE OF YOUR INFORMATION.
Our main goal is to ensure your experience on Golovefy is an enjoyable one
and you don’t end up getting stung! In order to deliver an enjoyable
experience to you, we may use your Registration and other information
to:
offer you our services and features;
contact you with information about the App (e.g., updates and new
features);
personalize the App/Sites and the content we deliver to you;
conduct research and analytics about how you use and interact with the
App/Sites;
resolve disputes, troubleshoot problems and to enforce our Terms &
Conditions;
investigate fraud, protect our legal rights, and to enforce our Terms
& Conditions.
to send you information about the promotions and offers we have available
- if you’ve signed up for our communications or otherwise told us
it’s OK (you can withdraw from marketing at any time via Settings in
the App or by using the opt-out mechanisms and links provided in each
message); and
protect our Users and third parties from harm.
Moderation Practices
We use a combination of automated systems and a team of moderators to
monitor and review accounts (including photos and any other information
uploaded onto user profiles) and messages for content that indicates
breaches of our Terms and Conditions of Use. If an account or message
meets certain criteria that demonstrate that the Terms and Conditions of
Use are likely to have been breached, the relevant account will be subject
to a warning and the user’s access restricted and/or blocked.
Affected Users can contact Golovefy to contest the decision.
If you post anything that is inconsistent with our Terms and Conditions of
Use, we reserve the right to terminate or restrict access to your
Account.
3. DISCLOSURE OF INFORMATION.
Our policy is to not disclose your Registration Information or personal
data, except in the limited circumstances described here:
Circumstances where data may be disclosed
Disclosed data
Service Providers – We engage certain trusted third parties to
perform functions and provide services to us. We may share your
Registration Information or personal data with these third parties, but
only for the purposes of performing these functions and providing such
services. More information about this is available directly below.
This could include all data, including all CCPA Categories listed above
Moderators – To monitor activity on the App and approve content.
Name and user registration details, profile information, content of
messages and photographs (CCPA Categories A, B, C, and H)
Payment Processing and Telecommunications Companies – To facilitate
payments for our premium services.
Cardholder name, cardholder address, card number, payment amount,
transaction date/time (CCPA Categories A, B, and D)
Law and Harm – As we mentioned in the Terms & Conditions, we
think it is very important that all Users behave whilst using the App. We
will cooperate with all third parties to enforce their intellectual
property or other rights. We will also cooperate with law enforcement
enquiries from within or outside your country of residence where we are
required to by law, where there is an investigation into alleged criminal
behavior or to protect the vital interests of a person. This may include
preserving or disclosing any of your information, including your
Registration Information, if we believe in good faith that it is necessary
to comply with a law or regulation, or when we believe that disclosure is
necessary to comply with a judicial proceeding, court order, or legal
request; to protect the safety of any person; to address fraud, security
or technical issues e.g. through anti-spam providers to protect the
service from criminal activity or to protect our rights or property or
those of third parties. In such cases we may raise or waive any legal
objection or right available to us.
This could include any personal data that Golovefy holds about you,
depending on the nature of the request or the issue that we are dealing
with, including all CCPA Categories listed above
Business Transfers – In the event that a Golovefy Group entity or
any of its affiliates undergoes a business transition or change of
ownership, such as a merger, acquisition by another company,
re-organisation, or sale of all or a portion of its assets, or in the
event of insolvency or administration, we may be required to disclose your
personal data.
This could include all personal data that Golovefy holds about you,
including all CCPA Categories listed above
Marketing Services Providers – To help us serve marketing and
advertising on third party websites and applications and measure the
effectiveness of our advertising campaigns. More information on this is
available below
Advertising identifier associated with your device (Device ID), estimated
location (based on your IP address), age, gender and data about your visit
to our Sites or App and action taken on those (for example if you
downloaded our App or created an account with our App), hashed email
address (for ‘custom audiences’ only) (CCPA Categories B, C,
G, F and K)
Anti-Spam and Anti-Fraud – Your data may be shared with other
Golovefy Group companies, for example, to block accounts and suspected
fraudulent payment transactions as part of our anti-spam and anti-fraud
procedures.
Email address, phone number, IP address and IP session information, social
network ID, username, user agent string, and transaction and payment data
(CCPA Categories B, F and D).
Aggregated Information – We may share aggregated information with
third parties that includes your personal data (but which doesn’t
identify you directly) together with other information including log data
for industry analysis and demographic profiling.
Golovefy does not sell your data and has not sold your personal data in
the previous 12 months.
MORE INFORMATION ABOUT DISCLOSURES
Service Providers We engage certain trusted third parties to perform
functions and provide services to us (“Service Providers”).
The suppliers with which Golovefy shares User personal data vary depending
on a variety of factors, such as which of our App, Sites and services a
User engages with. For example, to provide our services to Users, we
typically use the following suppliers:
Billing services – to allow customers to purchase paid features of
our App (for example, Google Play)
Authentication services – to allow customers to authenticate their
account (for example, MessageBird)
Social media providers – to allow customers to create/connect their
Golovefy account with their account(s) on such platforms (for example
Facebook, Instagram or Spotify)
Product improvement and market research – we use third party
platforms (such as Typeform) and agencies (such as Kantar) to carry out
customer surveys and market research to improve our products and
services
IT services – some of the third-party software providers used in the
operation of our business may process Users’ personal data.
We carry out due diligence on all Service Providers we engage to ensure
they have adequate data protection and information security measures in
place and only provide them with the personal data necessary to the
service they are providing. Measures are taken to ensure that the data
shared is non-attributable to the greatest extent possible and our
suppliers are also subject to extensive obligations under our contractual
arrangements, including strict data retention limits.
Marketing Services Providers
We partner with providers of marketing services (such as Facebook for
example) (‘Marketing Services Providers’) to help us market
and advertise our App and services on third party websites and
applications and measure the effectiveness of our advertising campaigns.
For example:
to exclude you from advertising campaigns aimed at finding new users, if
you already have a Golovefy account;
to show Golovefy adverts to users who have visited the Golovefy App/Sites
but haven’t yet created a Golovefy account;
to create an audience for our advertisements of other potential users who
have similar characteristics to you based on the information the Marketing
Service Providers holds about you (also known as a Lookalike Audience);
or
to include you in a ‘custom audience’ that will receive
Golovefy advertising content (a custom audience is essentially a list of
people who we think are most likely to be interested in a particular
advertisement).
We share a limited amount of your personal data with these Marketing
Services Providers, such as:
the advertising identifier associated with your device (this is a random
number assigned by your mobile device manufacturer (for example Apple or
Google) to your device to help advertisers (including the manufacturer)
know when an ad has been viewed or clicked in an app, and when an ad
causes a ‘conversion’ (for example, downloading the app
advertised to you))
your estimated location (based on your IP address)
age and gender data about your visit to our Sites or App and action taken
on those (for example if you downloaded our App or created an account with
our App)
a hashed* version of your email address (to create ‘custom
audiences’).
*Hashing is a way of encrypting information by turning it into a
combination of random numbers and letters - this code cannot be traced
back to the email address. When hashed email addresses are sent to a
Marketing Service Provider, they’re then matched against the
Provider’s own existing list of their own users’ hashed
information and our ads are served to those of our users who have
successfully been matched with the Provider’s. Matched and unmatched
hashes are then deleted by the Provider. For more information about how we
use cookies and other tracking technologies, including how you can set and
manage your preferences with regards to such technologies, please see our
Cookie Policy.
In some cases, these third parties will also use the data that they
collect for their own purposes, for example they may aggregate your data
with other data they hold and use this to inform advertising related
services provided to other clients.
Facebook
Where we share data with Facebook as our Marketing Service Provider
(including via the Facebook “Like” function), we are Joint
Data Controllers with Facebook Ireland for this processing.
This arrangement means that Golovefy has to provide you this notice, but
you should contact Facebook if you wish to exercise your data protection
rights. Further information, including how Facebook enables you to
exercise your data protection rights, and subsequently processes your
information as independent data controller can be found in Facebook
Ireland’s Data Policy.
This data referred to above can include actions that you take on our
website such as your interactions with our Sites or other information
collected from cookies or similar technologies including the Facebook
pixel. This allows us to measure the effectiveness of our advertising,
improve our marketing practices, and helps us deliver more relevant
advertising to you and people like you (including on social media such as
Facebook).
4. WHAT OTHERS MAY SEE ABOUT YOU.
We think our Users are awesome, and we want you to share how awesome you
are with the world, so we have built certain features to enable this. Our
App is designed to make it easier for you to connect with other Users and
to interact with them.
When using the Golovefy App, you should assume that anything you post or
submit on the App may be publicly-viewable and accessible, both by Users
and non-users of the App. We want our Users to be careful about posting
information that may eventually be made public.
Please be careful about posting sensitive details about yourself on your
profile such as your religious denomination and health details. You may
also choose to add sensitive information about yourself when you add
certain Golovefy badges to your profile, such as your religion and
political leanings. While you may voluntarily provide this information to
us when you create your profile, including your sexual preferences, there
is no requirement to do so. Please remember that photographs that you post
on Golovefy may reveal information about yourself as well. Where you do
upload and choose to tell us sensitive information about yourself,
including through the addition of badges to your profile, you are
explicitly consenting to our processing of this information and making it
public to other Users.
Your Golovefy profile and other information you make available via the
App, including certain information added to your profile through third
party accounts (such as Facebook, Instagram or Spotify – see section
7 of this Privacy Policy for more information about this) may be viewed
and shared by Users with individuals who may or may not be users of the
App. For example, a User may recommend you as a match to his or her
Facebook friend(s) by taking a screenshot of your profile picture and
sharing it, regardless of whether such friend(s) is also a User of the
App.
Please also note that in certain countries (currently, South Korea only),
Users are provided with functionality enabling them to download a copy of
their conversation history (as this is required by local laws) and that
Golovefy has no control over how users may then publish or use that
information.
If you log in to or access the App through your Facebook account or
another third-party account on a device which you share with others,
remember to log out of the App and the relevant third-party account when
you leave the device in order to prevent other users from accessing your
Golovefy account.
5. OUR POLICY TOWARDS AGE.
Although we want as many people as possible to enjoy our creation, you
have to be at least 18 years old to use the App - sorry kids, we know
Golovefy is cool, but you’ll have to come back when you’re old
enough!
Golovefy does not knowingly collect any information about or market to
children, minors or anyone under the age of 18. If you are less than 18
years old, we request that you do not submit information to us. If we
become aware that a child, minor or anyone under the age of 18 has
registered with us and provided us with personal information, we will take
steps to terminate that person’s registration.
6. SECURITY.
Here at Golovefy, we pride ourselves on taking all appropriate security
measures to help protect your information against loss, misuse and
unauthorized access, or disclosure. We use reasonable security measures to
safeguard the confidentiality of your personal information such as secured
servers using firewalls.
Unfortunately, no website or Internet transmission is ever completely 100%
secure and even we cannot guarantee that unauthorized access, hacking,
data loss or other breaches will never occur, but here are some handy tips
to help keep your data secure:
Please make sure you log out of your Account after use as you never know
who may stumble onto your Account!
Please don’t share the password you use to access your Golovefy
Account with anyone else!
Change your password periodically.
We cannot guarantee the security of your personal data while it is being
transmitted to our site and any transmission is at your own risk.
7. LINKING OTHER ACCOUNTS TO Golovefy.
Using your social media details to sign in to Golovefy
When you sign in to our App using your Facebook account, you give
permission to Facebook to share with us your name and profile picture.
Unless you opt-out, you also give permission to Facebook to share with us
your email address (if there is one associated with your Facebook
account), date of birth, profile photos, gender, Page likes and current
town/city.
If you register or sign in with your Apple ID, you give Apple permission
to share your Apple login, a name (that can be edited by you) and an email
(you can choose to hide your email and Apple will create a random email
address so your personal email can stay private). This email address will
be linked to your Golovefy account and will be used to retrieve your
Golovefy account.
We will then use this personal data to form your Golovefy account. If you
remove the Golovefy app from your Facebook settings, or from your Apple
ID, we will no longer have access to this data. However, we will still
have the personal data that we received when you first set up your
Golovefy account using your Facebook or Apple ID (you must delete your
Golovefy account entirely for us to no longer have access to this data).
Linking social media accounts to your Golovefy account
You may link your Golovefy account with your Instagram, Facebook or
Spotify accounts. This allows you to share some information from those
accounts directly to your Golovefy account (for example, Instagram photos,
or your top Spotify artists).
We only receive the limited information that Instagram or Spotify permits
to be transferred (as detailed by Instagram/Facebook/Spotify and agreed by
you when you first connect your account from such platforms with your
Golovefy account).
If you no longer want to link your Golovefy account to your Instagram,
Facebook or Spotify account, please visit the settings in your Instagram,
Facebook or Spotify account and follow the instructions to remove the
Golovefy app access permissions. Please note that any information already
added to your Golovefy account from those platforms will not be deleted
unless you delete it within your Golovefy account as well.
8. YOUR RIGHTS.
Privacy laws applicable in your country may give you the following
rights:
Right to be informed: what personal data an organization is processing and
why (we provide this information to you in this Privacy Policy).
Right of access: you can request a copy of your data.
Right of rectification: if the data held is inaccurate, you have the right
to have it corrected.
Right to erasure: you have the right to have your data deleted in certain
circumstances.
Right to restrict processing: in limited circumstances, you have the right
to request that processing is stopped but the data retained.
Right to data portability: you can request a copy of certain data in a
machine-readable form that can be transferred to another provider.
Right to object: in certain circumstances (including where data is
processed on the basis of legitimate interests or for the purposes of
marketing) you may object to that processing.
Rights related to automated decision-making including profiling: there are
several rights in this area where processing carried out on a solely
automated basis results in a decision which has legal or significant
effects for the individual. In these circumstances your rights include the
right to ensure that there is human intervention in the decision-making
process.
The particular rights which are applicable to you (which might include
other rights not listed above) may vary depending on your country. You
should make yourself aware of the rights you have under applicable privacy
laws in your country.
You can also contact us by post at the following address: 71-75, Shelton
Street, Covent Garden, London, WC2H 9JQ, UNITED KINGDOM. For your
protection and the protection of all of our Users, we may need to request
specific information from you to help us confirm your identity before we
can answer the above requests.
If you have a concern about how we have processed your request or your
personal data, you should contact us in the first instance via the contact
details listed above.
If you feel we have not resolved your concern, you have the right to make
a complaint at any time to the Information Commissioner’s Office
(ICO), the UK supervisory authority for data protection issues
(www.ico.org.uk). If you live in a country or territory located in the
European Union (EU) or European Economic Area (EEA), you may also get in
touch with your local Data Protection Regulator. If you live in a country
outside the EU, you may have the right to lodge a complaint with your
local privacy or data protection regulator.
9. DATA RETENTION AND DELETION.
We keep your personal information only as long as we need it for the legal
basis relied upon (as set out in Section 2 above) and as permitted by
applicable law. Please see “Profile Verification Information
(Including Biometric Information)” in Section 1, above, to learn
about our retention policy with respect to biometric information.
When you delete your Account, or it is deactivated by us, we make sure it
is no longer viewable in the App. For up to 28 days, it is still possible
to restore your Account if it was accidentally deleted or wrongfully
deactivated. After 28 days, we begin the process of deleting your personal
information from our systems, unless:
we must keep it to comply with applicable law (for instance, if you make
purchases within the App, some personal data may be kept for tax and
accounting purposes);
we must keep it to evidence our compliance with applicable law (for
example, if an account is blocked, we keep some account information and a
record of the behaviour that led to the block - this information is
retained for evidential purposes in case of queries or legal claims
concerning the block);
there is an outstanding issue, claim or dispute requiring us to keep the
relevant information until it is resolved; or
the information must be kept for our legitimate business interests, such
as fraud prevention and enhancing Users’ safety and security (for
example, information may need to be kept to prevent a user who was banned
for unsafe behaviour or security incidents from opening a new account).
Warning: Even after you remove information from your profile or delete
your Account, copies of that information may still be viewable and/or
accessed to the extent such information has been previously shared with
others, or copied or stored by others. We cannot control this, nor do we
accept any liability for this. If you have given third party applications
or websites access to your personal information, they may retain such
information to the extent permitted under their terms of service or
privacy policies.
Thanks for reading, we hope we didn’t drone on for too long!
10. CHANGES TO THIS POLICY.
As Golovefy evolves, we may revise this Privacy Policy from time to time.
The most current version of the policy will govern our use of your
information and will always be at Golovefy.com/privacy. If we make a
change to this policy that, in our sole discretion, is material, we will
notify you, for example, via an email to the email associated with your
Account or by posting a notice within Golovefy.
Effective date
This Privacy Policy was last updated 16 May, 2022.