WeAre PRIVACY AND COOKIE POLICY

Welcome to WeAre’s Privacy Policy. This explains how WeAre (“WeAre”) uses, collects, processes, and shares information, including information obtained through the website at https://WeAreapp.tk (“WeAre Site ”), the WeAre mobile application (“WeAre App ”).

Use the links below to jump to specific information concerning our privacy practices. As a gay social networking application, the WeAre App collects and shares sensitive information concerning its members including their sexual orientation and location. This policy also explains how you can control your personal information.

What We Collect.

We collect personal data and non-personal data about you. “Personal Data” means any data that allows someone to identify or contact you.

The following provides examples of the types of data that we collect, and how we collect them. Note that not all of the WeAre Services collect all of the data listed below. By agreeing to our privacy policy, you consent to the collection of the information indicated below. In addition to consent, the information is collected to perform a contract, to comply with obligations, or for the legitimate interests of WeAre or a third party as described below. Note that some WeAre Services collect only some of the data listed here.

  • Account Credentials. We require you to provide an email address and password to use the WeAre App or other WeAre Services. In the future, we may also ask you to provide your phone number for account authentication purposes.
  • Device Information. We collect certain software and hardware information about your Device. For example, we collect an ID that is unique to the device or browser on which you install and/or access the WeAre Services (“Device ID” and “Device,” respectively).
  • Location and Distance Information. When you use the WeAre App, we will collect your location to determine your distance from other users (“Distance Information”) through the GPS, Wi-Fi, and/or cellular technology in your Device. Your last known location may be stored for the purpose of calculating Distance Information between you and other users.
  • Cookies and Log Files. We collect information from you, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit. We also use cookies and URL information to gather information regarding the date and time of your visit and the information for which you searched and which you viewed. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing a web site. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your Device until you delete them) to provide you with a more personal and interactive experience on the WeAre Services and to improve our marketing efforts, including through the use of targeted advertising. Persistent cookies we place may be removed by following instructions provided by your browser. If you choose to disable cookies, some areas or features of the WeAre Services may not work properly. WeAre has an interest in the collection of such information for fraud monitoring and analytics purposes.
  • Messages. When you send a message (which could include photos, location, audio, or video) to other users of the WeAre Services, we may retain the message as necessary under applicable law.
  • Profile Information. We collect Personal Data from you. For example, in the WeAre App, we collect information that you voluntarily provide, such as your photo, display name, relationship status, ethnicity, age or date of birth, geo-location data, email address, password for the WeAre Services, height, weight, social network link, “Looking For,” “About Me,” “Favorites,” “Blocks,” and any other information that you add to your profile on the WeAre App or that is generated through your use of the WeAre Services. As a result, you should carefully consider what information to include in your profile.

WeAre does not receive or process credit card information directly. We currently use Google Play for purchases on Android devices. Please review their privacy policies at , https://www.google.com/policies/privacy/ respectively, to better understand their practices. The WeAre Services include links to purchase WeAre merchandise from our third party service provider. If you purchase such merchandise, the third party service provider’s terms of use and privacy policy apply.

Note that our third party service providers may provide certain information to us (e.g., your name, phone number, partial credit card number, and email address).

  • Feedback/Support. If you provide us feedback or contact us for support we will collect your name and e-mail address and possibly other Personal Data, as well as any other content that you send to us in order to reply and address any issue. If you contact us for support, we may also collect and retain certain technical diagnostic data, such as your phone model.
  • Mailing List. When you sign up for the WeAre Services, we collect your email address to send you WeAre news, WeAre Services updates, the latest information on products and services, and third party offers.
  • Surveys. When you participate in a survey, we collect additional information that you provide through the survey. If the survey is provided by a third party service provider, the third party’s privacy policy applies to the collection, use, and disclosure of your information. Unless noted otherwise, we use Survey Monkey for surveys.
  • Partner Promotion. We collect information that you provide as part of a Partner Promotion (defined below).
  • Third Party Platforms. If you use or connect to the WeAre Site or download the WeAre Services through a third party platform, such as Facebook, you allow us to access and/or collect certain information from your third party platform profile/account. We may also access information contained in cookies placed on your Device by the third party platform. Note that we may share this information with the third party platform for their use.

How We Use Your Information.

In addition to the uses described above, we use your Personal Data in the following ways:

  • Identify You. To identify you as a user on the WeAre Services.
  • Provide Products and Services. To provide the products and services you request, including the WeAre Services.
  • Improve Services. To improve the WeAre Services.
  • Communicate with you. To respond to your inquiries related to support, employment opportunities, or other requests, and to send Promotional Emails to those users that request or authorize them.
  • Partner Promotions. To conduct a Partner Promotion that you request.
  • Marketing and Advertising. For marketing and promotional purposes, including to inform you of products, services or offers of WeAre, our related companies or business partners that may be of interest to you. Marketing and advertising material provided by WeAre may appear within our App, on our website, on Apps owned by third parties, or on websites controlled by third parties. The marketing and advertising may relate to WeAre’s products or services, or may relate to the products or services of companies that have asked us to advertise to you.
  • Administration. For internal administrative purposes, as well as to administer or manage our relationship with you, including to communicate with you regarding your use of WeAre Services.
  • Employment. If you apply for employment with WeAre or currently work for WeAre, to manage your employment application, assess your qualifications, and manage your employment with us (applies solely to the WeAre Site).

Where We Share.

In addition to the specific situations discussed above, we disclose Personal Data in the following situations:

  • User Profiles. The WeAre App is a social networking platform that is designed to allow users to share information. When you use the WeAre App, your Profile Information is public, and other users of the WeAre App can see your Profile Information and other Personal Data (including sensitive personal data) posted by you. For example, other users can search for you, search for your profile characteristics, or see you listed as being in their vicinity. Do not include information in your profile that you want to keep private. For example, if you do not want your HIV status to be known, you should not include that information in your WeAre profile. While the WeAre App permits you to make certain items (e.g., Profile Information, preferences, opinions of other users, or other information) non-public, sophisticated users who use the WeAre App in an unauthorized manner may nevertheless be able to obtain this information and may be able to determine your identity.
  • Distance Information. The WeAre App is designed to allow users to share Distance Information. As a result, Distance Information is public, and other users of the WeAre App can see your Distance Information (including how many feet or meters you are from them). WeAre App users can use the search feature in the WeAre App to search for other users by distance or in a particular geographic vicinity. Your Distance Information will be used for these searches. Sophisticated users who use the WeAre App in an unauthorized manner, or other users who change their location while you remain in the same location, may use this information to determine your exact location and may be able to determine your identity. Please note: even if you choose to hide your Distance Information, the WeAre App will continue to sort and display your profile based on your relative distance from other users, so your Distance Information may still be approximated by other users. Thus, even if you choose to hide your Distance Information, others may nevertheless be able to determine your location.
  • Third Party Advertising Companies. We share your hashed Device ID, your device's advertising identifier, a portion of your Profile Information, Distance Information, and some of your demographic information with our advertising partners. These third parties may also collect information directly from you as described in this Privacy Policy through technology such as cookies. The privacy policy of these third party companies applies to their collection, use and disclosure of your information. One of these advertising partners is MoPub that helps WeAre deliver personalized advertising. You can follow the links to MoPub’s privacy notice and partner page. See the YOUR CHOICES section of this policy for information on your ability to opt-out of interest based advertising. Note that we do not sell your personal user information to third parties for advertising purposes. Also note that we do not share information about your Tribe, or about your HIV status, with any advertising companies.
  • Third Party Service Providers. We share your Personal Data with third party service providers to: provide you with the WeAre Services; conduct quality assurance testing; provide technical support; and/or to provide other services to WeAre. Except as otherwise stated in this Privacy Policy, these third party service providers are required by contract not to use your Personal Data other than to provide the services requested by WeAre. We do not, however, provide HIV status to our third party service providers, other than companies that host data on our behalf (e.g., Amazon Cloud).
  • Other Disclosures. WeAre may disclose Personal Data in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws; to establish or exercise our rights to defend against legal claims; if we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, safety of person or property, violation of our policies, or as otherwise required by law.

Your Choices.

You can make the following choices regarding your Personal Data:

  • Promotional Emails. You may choose during the registration process to provide us with your email address for the purpose of allowing us to send free newsletters, surveys, offers, and other promotional materials related to WeAre and/or the WeAre Services, as well as targeted offers from third parties. You can stop receiving promotional emails by following the unsubscribe instructions in e-mails that you receive. If you decide not to receive promotional emails, we may still send you service related communications, and our applications may deliver notifications directly to your mobile device in the WeAre App.
  • Effect Of Opting Out Of Behavioral Advertising. Please note that opting-out of behavioral advertising does not mean that you will not receive advertising while using the WeAre Services. It will, however, exclude you from interest-based advertising conducted through participating networks, as provided by their policies and choice mechanisms.
  • Changes To Your Personal Data. WeAre relies on you to update and correct your Personal Data. You can modify or delete your profile within the WeAre Services. Please note that WeAre may keep historical information and content in our backup files and archives as permitted by law and to the extent we anticipate that the information may be required in connection with the original purpose of the collection, or as otherwise permitted or required by law.
  • Deletion Of Your Personal Data. Typically we retain your Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required for the operation of the WeAre Services or permitted by law. You can, however, request that we delete your Personal Data. All requests must be directed to the contact in the “Contact Information” section of the WeAre Services. We can also decide to delete your data at any time if we believe that the data is incomplete, inaccurate, or that our continued use and storage are contrary to our obligations to other individuals or third parties. In addition, we may keep your Personal Data and usage history (which includes a history of profile text or photos that have been censored, banned) as needed to comply with our legal obligations, resolve disputes, and/or enforce any of our agreements.
  • Revocation Of Consent. The WeAre Services relies on the processing of Personal Data that you have provided. If you revoke your consent for the processing of Personal Data, in accordance with this Privacy Policy and applicable Terms and Conditions of Service, then you must discontinue all use of the WeAre Services and delete any accounts that you created, as we will no longer be able to provide the WeAre Services. In some cases, we may limit or deny your request if the law permits or requires us to do so, or if we are unable to adequately verify your identity.
  • Access To Your Personal Data. If required by law, upon request, WeAre will grant a user reasonable access to the Personal Data that WeAre holds about the user. All requests must be in accordance with the applicable Terms and Conditions of Service and be directed to the contact in the “Contact Information” section of the WeAre Services.

How We Protect Personal Information

WeAre takes steps to help protect your Personal Data from unauthorized access, use, or disclosure. That said, no method of transmission over the Internet, or method of electronic storage, is fully secure, and WeAre cannot guarantee the security of your Personal Data. In the event that we are required by law to inform you of any unauthorized access to your Personal Data, we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

Miscellaneous Information

The following additional information relates to our privacy practices:

  • Permissible Age. The WeAre Services are intended for users 18 years of age and older only (twenty-one (21) years of age in places where eighteen (18) years is not the age of majority). We do not intentionally gather Personal Data about visitors who are under the age of majority. If you are aware that a child or minor has submitted Personal Data on the WeAre Services, please contact us using the information provided below so that we can take appropriate action.
  • Transmission Of Data To Other Countries. Your Personal Data may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding Personal Data may be less stringent than the laws in your country. Therefore, in some circumstances, you might be left without a legal remedy in the event of a privacy breach. By submitting your Personal Data, you agree to this transfer, storage and/or processing, including all associated risks.
  • Third Party Applications/Websites. We have no control over, do not review, and cannot be responsible for other websites or applications. If you click on a link to another website or third party application, the terms of this Privacy Policy do not apply.
  • Contact Information. WeAre welcomes your comments or questions regarding this Privacy Policy. Please contact us at the following:

contact@svtweb.it

WeAre will also initiate an investigation if you contact us with a complaint against our privacy practices or a concern that our practices do not conform to the requirements in your jurisdiction. We will attempt, where practical, to ensure ongoing compliance with any legal obligations.

  • Changes To This Privacy Policy. If we make a material change to this policy we will, at a minimum, attempt to notify you of that change either by sending an e-mail to the last e-mail address that you provided to us (if any) or by notifying you when you log into the WeAre Services.

Effective Date: 15/11/2018, or user acceptance.