United States
Privacy Policy
1. Introduction
This privacy notice informs you as to how we collect, process and look after your personal data in the course of interacting with us, whether by visiting this website or otherwise, and tells you about your privacy rights and how the law protects you. This website is not intended for children and we do not knowingly collect data relating to children.
We are Enjoy The Web OÜ, based in Tallinn, Estonia, henceforth referred to as "we" or "our" in this privacy policy. In respect of your personal data, we are the data controller, in accordance with the (EU) Regulation 2016/679 regarding the protection of personal data. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact dpo@best.dating. This is your email contact in respect of all queries relating to your data protection rights and we aim to respond promptly to all such emails.
We are Enjoy The Web OÜ, based in Tallinn, Estonia, henceforth referred to as "we" or "our" in this privacy policy. In respect of your personal data, we are the data controller, in accordance with the (EU) Regulation 2016/679 regarding the protection of personal data. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact dpo@best.dating. This is your email contact in respect of all queries relating to your data protection rights and we aim to respond promptly to all such emails.
2. Cookies
This website does not use cookies except for enabling / disabling the dark mode styling. The session cookie dark_mode is used in this case with values either 'on' or 'off'.
3. Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit as well as their cookie policy.
4. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous or anonymized data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Technical Data: includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website
- Usage Data: includes information about your use of our website, products including the full Uniform Resource Locators (URL) clicked, through and from our website (including date and time); elements you viewed or words you searched for; page response times; download errors; length of visits; interaction information (such as scrolling, clicks, and mouse-overs)
- Contact Data: email address
- Communications Data: includes emails and notes of conversations, if you choose contact us and provide information for us to reply
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
5. How is your personal data collected
We use different methods to collect data from and about you including through:
Direct interactions: you may give us contact information when submitting information through the website or by corresponding with us email or otherwise. This includes personal data you provide when you contact us.
Automated technologies or interactions: As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns.
Direct interactions: you may give us contact information when submitting information through the website or by corresponding with us email or otherwise. This includes personal data you provide when you contact us.
Automated technologies or interactions: As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns.
6. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- where we need to comply with a legal or regulatory obligation.
Your data is never used for marketing purposes or transferred to a third party, unless you provide explicit consent. Your data is never sold to a third party, under any circumstances except the acquisition of Enjoy The Web OÜ by another company.
Purposes for which we will use your personal data
A description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so can be found below. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
1. To manage our relationship with you (for example, sending you notifications about new available apps in a region, if and only if you choose to receive them)
Data processed: Contact Data
Lawful basis: performance of a contract, legitimate interest
2. To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Data processed: Technical Data, Usage Data
Lawful basis: lawful obligation, legitimate interest
3. To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
Data processed: Usage Data
Lawful basis: legitimate interest
4. To use data analytics to improve our website
Data processed: Technical Data, Usage Data
Lawful basis: legitimate interest
Disclosures of your personal data
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
- where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- where we need to comply with a legal or regulatory obligation.
Your data is never used for marketing purposes or transferred to a third party, unless you provide explicit consent. Your data is never sold to a third party, under any circumstances except the acquisition of Enjoy The Web OÜ by another company.
Purposes for which we will use your personal data
A description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so can be found below. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
1. To manage our relationship with you (for example, sending you notifications about new available apps in a region, if and only if you choose to receive them)
Data processed: Contact Data
Lawful basis: performance of a contract, legitimate interest
2. To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Data processed: Technical Data, Usage Data
Lawful basis: lawful obligation, legitimate interest
3. To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
Data processed: Usage Data
Lawful basis: legitimate interest
4. To use data analytics to improve our website
Data processed: Technical Data, Usage Data
Lawful basis: legitimate interest
Disclosures of your personal data
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances you can ask us to delete your data: see “request erasure” below for further information.
In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances you can ask us to delete your data: see “request erasure” below for further information.
In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. Specific legal rights for users located in the EEA region (GDPR)
You may contact our data protection officer at dpo@best.dating for more information or to exercise any of these rights:
1. Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
2. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
3. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
4. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
5. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
6. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Exercising these rights
Use our DSR (data subject request) form or send an email to dpo@best.dating
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights).
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
1. Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
2. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
3. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
4. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
5. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
6. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Exercising these rights
Use our DSR (data subject request) form or send an email to dpo@best.dating
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights).
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10. Specific legal rights for users located in California, United States of America (CCPA)
The California Consumer Privacy Act, Cal. Civ. Code §1798.100 et. seq. (“CCPA”), grants residents of California certain rights with respect to their Personal Information and requires us to provide such individuals with certain information, described below.1. California residents may exercise the following rights by contacting our Privacy Policy Coordinator by email at dpo@best.dating:
Know the ways in which we acquire, use, share, disclose and otherwise process your Personal Information;
Know the specific pieces of your Personal Information that we hold;
Request the deletion of your Personal Information, subject to several exceptions;
Not to be denied goods or services for exercising these rights
2. California residents also have the right to opt-out of the “sale” of their Personal Information. We put “sale” in quotation marks because the CCPA considers some transfers of Personal Information to third parties in exchange for value as “sales,” even if no money changes hands, such as when online identifiers, Device IDs, and other information is shared with Third Party Businesses to further their own commercial purposes such as generating profiles about individuals. . If we have actual knowledge that a California resident is younger than 16, we will request opt-in consent before selling their Personal Information. Note that we can still share Personal Information with third parties if those transfers aren’t “sales,” such as with our Service Providers.
3. Depending on the circumstances and which Service you use, we have disclosed the following categories of your Personal Information for a “business purpose” (as defined in the CCPA) in the preceding twelve (12) months:
Identifiers
Commercial information
Geolocation data
Internet or other electronic network activity information
Professional information
Inferences drawn from any of the above information categories.
4. Depending on the circumstances and which Service you use, we have “sold” (as defined in the CCPA) the following categories of your Personal Information in the preceding twelve (12) months:
Identifiers
Commercial information
Geolocation data
Internet or other electronic network activity information
Professional information
Inferences drawn from any of the above information categories.
5. You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly.
6. You have the right not to receive discriminatory treatment by us for the exercise of any of your rights.
7. California's "Shine the Light" law permits customers who are California residents to request certain details about how a business shares their personal information as defined by "Shine the Light" with third parties (and in some cases affiliates) for those third parties' or affiliates' own direct marketing purposes. California customers may request information
about our compliance with this law by contacting us by e-mail at dpo@best.dating or by mail at the address set forth in Section 11 above. Any such mail inquiry must include "California Privacy Rights Request" in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this email or mail address.