Down provides services to users throughout the world. However, Down processes personal data inside of the United State only. Down does not transfer data of its users outside of the United States.
Down’s data controller is:
2212 Queen Anne Ave N 710
Seattle, Washington 98109
Questions, comments and complaints about Down’s data practices can be submitted to Down by emailing firstname.lastname@example.org.
Regardless of your location, Down is the only controller of your personal data all your data is located within the United States, and none of it is transferred outside of the United States.
In order for you to utilize our Services, including but not limited to, creating a user account and being matched with other users, we collect the following data from you:
When you access or use our Services, we automatically collect data about your use of the Services, including:
We use the data that we have about you to provide to personalize our Services so that they can be more relevant and useful to you and others. We collect, store and use your personal data to provide our Services to you as follows:
Your personal data is necessary to allow you to utilize the basic functionality of the Services, which includes: (i) creating and updating your user account; (ii) verifying your identity; (iii) processing payments; (iv) providing you notices about your account, such as for renewal and expirations; (v) notifying you about changes to our Services; (vi) providing customer support, such as responding to emails, questions, comments, requests and/or complaints sent by you to Down; (vii) performing internal operations necessary to provide our services, including to troubleshoot software bugs and operational problems; (viii) investigating or addressing claims or disputes relating to your use of the Services, or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries; (ix) storing information about your preferences so that we may customize our Services according to your individual interests; and (x) recognizing you when you return to our Services.
When both you and your match explicitly express mutual interest by both clicking the “LIKE” button within the Services, we will seek to connect you with him/her by sending you a notification through the application. However, note that your match will now be aware of your actual phone number you provided to us as we do not share your phone number with your match during this process; all match communications are kept within the application for your protection. We will also share your first name at this time with your match. Your use of Down is not contingent upon agreeing to receive text messages.
We will contact you through email, mobile phone, notices posted on our websites or applications, messages to your account, and other ways through our Services, including text messages and push notifications. We will send you messages about the availability of our Services, security, or other service-related issues. We also send messages about how to use the Services, network updates, reminders, matches and promotional messages. You may change your communication preferences at any time. However, please be aware that you cannot opt-out of receiving service messages from us, including service announcements, security alerts, update notices, or other administrative messages.
We may send emails to you for marketing and advertising purposes, such as for newsletters, new product offerings, special discounts, event notifications, and special third-party offers. You may opt-out of receiving promotional emails and other promotional communications from us at any time via the opt-out links provided in such communications, by e-mailing email@example.com or by visiting https://downapp.com/manage-my-data.
We may periodically contact our users to conduct voluntary user surveys. We encourage our members to participate in such surveys because they provide us with important information regarding the improvement of Down. We do not link the survey responses to your name or email address, and all responses are anonymous.
We use the private data we receive, including feedback, to: (i) monitor and analyze trends; (ii) further develop our Services in order to provide you and others with a better, more intuitive and personalized experience; (iii) drive membership growth and engagement on our Services; (iv) to better help match users to each other; (v) to speed up your searches; and (vi) to estimate our audience size and usage patterns.
We use the data gathered from you and about your use of our Services to continue our research into successful relationships, including how to create and foster these relationships, so that we may continue to improve our Services.. However, all of your responses will be kept anonymous, and we assure you that no personal data will be published. We may combine non-personally identifiable information (“non-PII”) we collect with additional non-PII collected from other sources for our blog. You can opt out of this at any time by emailing us at firstname.lastname@example.org or by visiting https://downapp.com/manage-my-data.
We use your data to help provide the Services to you, to further develop and personalize the Services, to be able to match you with other users, to be able to communicate with you, to conduct services, to conduct research, and to send you marketing communications. You have a right to opt-out of any marketing communications by clicking the link in the email to unsubscribe or by emailing us directly at email@example.com or by visiting https://downapp.com/manage-my-data.
Down only retains user profile and other data as long as you have a user account and utilize the services. You may request deletion of your account at any time by emailing Down at firstname.lastname@example.org and making such request. Upon receipt of a request to delete your account and data, Down will delete your account within forty-eight (48) hours after request.
However, since we are subject to compliance with different laws in place around the world relating to regulatory, tax, insurance or other requirements in the field in which it operates, Down will maintain data related to the foregoing, which may include transaction history, for seven (7) years. Thereafter, Down will delete such data in accordance with applicable laws.
We maintain your personal data as long as you have an active user account. We can delete your user account upon request, but will still be required to maintain certain personal data to comply with legal obligations for a period of seven (7) years after removal of your account.
We at Down want you to have complete control of your data, and therefore, you always have the right to:
You may review or edit your profile as you wish by logging into your Down account. If you would like to have us delete your account information, we may do so by deactivating your account first and then permanently deleting your account – to do so, please email us at email@example.com or please visit https://downapp.com/manage-my-data to exercise the rights discussed above. If your account is deactivated or you ask to close your account, you will no longer be able to use the Services. We will use commercially reasonable efforts to honor your request; however, certain data may persist internally or for our administrative purposes subject to the records retention policy discussed in Section 5.
You can access, update and/or delete your personal data by visiting your account, emailing us at firstname.lastname@example.org or visiting https://downapp.com/manage-my-data. You have many choices about how your data is collected, used and shared and we will help facilitate any of those choices you wish to pursue. Even if you delete your account, however, certain personal data may be kept for record retention purposes as previously discussed in Section 5.
We use Secure Sockets Layer (SSL) software to encrypt the data you enter on our Services in order to protect its security during the transmission of data. When storing data, we protect its security by encryption and pseudonymization of critical data. When our payment processor process credit card data and payments, the credit card is subject to tokenization and strong security measures.
We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personally identifiable customer data. Our security procedures require us in some cases to request proof of identity before disclosing personal data to you. To protect against unauthorized access to your account and data, we implement session management and login expiration mechanisms. As an additional safety measure, be sure to sign off when you finish using your account and your computer.
Although we use reasonable organizational, technical and administrative measures to protect your personal data, it is unfortunately true that no data transmission over the Internet can be guaranteed to be 100% secure. Consequently, please note that while we do our best to protect your personal data, we cannot fully guarantee the security of any personal data you transfer over the Internet. Any transmission of personal data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained in our Services.
If you believe that your interaction with us is no longer secure or that your account has been otherwise compromised, please contact us immediately at email@example.com.
Our data transmissions are secured through encryption, and we also monitor for and try to prevent security breaches. However, no data transmissions over the Internet can ever be guaranteed to be 100% secured. Please use the security features available through our Services and do not hesitate to email us at firstname.lastname@example.org if you believe your account security has been compromised.
Beginning May 25, 2018, the processing of personal data of users within the European Economic Area (EEA) is subject to the EU General Data Protection Regulation (“GDPR”). This section summarizes Down’s grounds for processing personal data under the GDPR, and the rights of such users as it relates to Down’s handling of personal data.
If you are located within the EEA, you have the following rights with respect to how Down handles your data:
In order to allow you to easily exercise any of your rights, we have created a page where you can submit any of the above request. The page can be found by visiting https://downapp.com/manage-my-data.
The GDPR requires that companies processing the personal data of EEA users do so on the basis of specific legal grounds. As such, Down will only process your personal data in the following situations:
You have a right to: (i) requesting explanations of what data of yours down stores and how it is used; (ii) request copies of your personal data; (iii) request your data to be deleted; (iv) file a complaint about the use of your data; or (v) request your data to be transferred. Our legal basis for collecting, using and sharing your data include consent, contract and legitimate interest. If the legal basis is consent, then you may withdraw your consent at any time. If you wish to exercise any of your rights relating to control of your data, please email us at email@example.com or visit https://downapp.com/manage-my-data.
The personal data we collect may be transferred to, and processed and stored in, countries outside of the jurisdiction you are located in. For example, if you are located in a country with the EEA, your personal data may be processed in the United States. All international transfers of your personal data are made:
If you wish to enquire further about these safeguards used, please send us an email at firstname.lastname@example.org.
All of our data is processed in the United States. If you are located outside of the United States, then your data is safely transferred to our processors located within the United States in accordance with all applicable laws
Our Services are not intended for individuals under 18 years of age. No one under age 18 may provide any data to or on the Services. We do not knowingly collect personal data from individuals under 18. If you are under 18, do not use or provide any data on our website or on or through any of Services or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal data from a person under age 18 without verification of parental consent, we will delete that information. If you believe we might have any data from or about a person under the age of 18, please contact us at email@example.com.
Our Services are not for individuals under the age of 18.
We do not sell your personal information so no opt-out choice is necessaryWhat this means is that we do not sell, rent, release, disclose, disseminate, make available, transfer, or otherwise communicate in any way your personal information to another company for monetary or other valuable consideration.
You have the right to request, twice in a 12-month period, the following information about the personal information we have collected about you during the past 12 months:
You have the right to request that we delete the personal information we have collected from you. If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment.
To submit an access or deletion request,contact us as firstname.lastname@example.org.To help protect your privacy and maintain security, we take steps to verify your identity before granting you access to your personal information or complying with your request.
When you submit a selfie for photo verification, we use computer vision technology to compare the face in the selfie with the faces in the profile photos you uploaded. During this process, data about your facial geometry is temporarily generated for comparison.
Face data is only used to verify that the user is the same person as shown in the profile photos they upload.
Face data is not shared with any third parties beyond the image verification & recognition services we utilize.
Face data is deleted once verification is complete, typically within a few minutes. We only retain a copy of your verification photo on our servers for keeping our network safe from malicious accounts and to ensure you don’t have to re-verify in the future.
You can request deletion by sending an email to email@example.com