Effective Date: May 14, 2018
This Policy explains how PairUP collects, uses, and discloses information through its Services, and your rights in relation to that information. By agreeing to this Policy when installing the Apps and/or using any of our Services, or the features made available to you through the Services, you are agreeing to the terms of this Policy and consenting to the collection, use, and sharing of information in a manner consistent with this Policy.
The information that we collect about you is controlled by PairUP, INC., which is headquartered in the United States. As described in the section below titled “Information for Users Outside the United States,” information that we collect through or in connection with our Services may be transferred to and processed in the United States.
Information that We Collect
We collect a variety of information through our Services, including:
- Registration and profile information. PairUP may request information from you when you register to use our Services or create an account profile, such as your name, username or avatar, email address, password, phone number, birthdate, gender, and photograph. If you register for a PairUP account using Google or another third-party service, we may receive your name and email address from that third-party service.
- Information you provide to us. We collect information that you provide to us directly through the Services, such as when you edit your account profile, upload a photograph, provide feedback on other users, post comments, chat with other users, respond to surveys or requests to rate the Apps, and correspond with us.
- Activity skill level. We may ask for your skill level (e.g., novice, intermediate, expert) for each type of activity that you participate in (e.g., tennis or rock climbing). Your skill rating is set initially for each activity type, and the Services may automatically upgrade or downgrade your skill depending on the results or scores of your activities.
- Information about users’ activities. We collect information about the activities you participate in when you join or complete an activity. For example, we may collect information about the type of activities that you participate in, the location where they take place, and the results or scores for a particular activity.
- Information about users’ interests and location. If you sign up for activity alerts, we may ask you to indicate the activities that you are interested in and to provide us with your home address or location. For example, we may ask you for permission to access your device’s location, such as by dropping a “pin” to indicate your precise location. This allows us to notify you about nearby activities that you may be interested in.
- Information collected automatically. When you use our Services, we or our third-party service providers may automatically receive and record certain information from your device or through the Services. For example, this may include your device’s IP address, user-agent, web pages you visit or features you use within the Services, the date and time of your activities on the Services, time since your last visit, links you click, searches conducted on the Websites, the website visited before visiting our Web sites, your software and hardware attributes (including browser and operating system type and version, App version, device type, and device identifiers), and your general location inferred from IP address. To obtain such information, we or our third-party service providers may use the following or similar technologies to recognize your device and collect information about your device and Services usage:
- Server Logs. When you use the Services, we automatically receive and record certain information from your computer (or other devices) and your browser. To obtain such information, we may use server logs or applications that recognize your computer and gather information about its online activity.
- Web beacons or tags. The Services or the emails that you receive from us may use an application known as a “web beacon” (also known as a “tag,” “clear gif,” or “pixel”). A web beacon is an electronic file that usually consists of a single-pixel image. It can be embedded in a web page or in an email to transmit information. For example, it allows an email sender to determine whether a user has opened a particular email.
We may combine information collected through the Services with information that we collect in other contexts, such as our email communications with you. We will treat such combined information in accordance with this Policy.
How We Use Information that We Collect
PairUP uses the information that we collect for a variety of purposes, including:
- Providing the Services to you. To provide our Services and its features to you, fulfill the terms of any agreement you have with us, and respond to your requests;
- Managing App users. To match users and activities through the Services, compile feedback regarding other users of the Services, adjust user skill levels based on the results of past activities, or lock user accounts;
- Notifying you of important information. To communicate with you regarding your account, feedback that you have provided, important updates regarding our Services, and other administrative messages;
- Sending PairUP promotional messages. To send promotional messages to you regarding current and new services or features offered by PairUP;
- Enabling chat features. To allow you to communicate with other users on the Services;
- Operating the Services. To help us efficiently operate the Services, count and recognize visitors to the Services, enable certain features on the Services, and for other purposes related to managing our business;
- Conducting analytics and improving our services. To analyze how individuals use the Services and its features, to improve the Services and enhance users’ experiences, to create new products and services, and to enable additional analytics and research concerning the Services, including as described below in the section titled “Third-Party Data Collection and Analytics”;
- Compiling aggregated and de-identified information. To compile aggregated and de-identified statistics or reports that we may share with our business partners or other third parties;
- Legal purposes. For legal or other necessary purposes, including as described below in the section titled “How We Share information with Third Parties.”
How We Share Information with Third Parties
We share information with third parties for a variety of purposes, including:
- With third-party service providers. PairUP uses third-party service providers to help us manage and improve the Services. These service providers may collect and/or use your information to assist us in achieving the purposes discussed in this Policy. For example, we may use third parties to perform data storage and processing services for us, perform analytics as described in the section below titled “Third-Party Data Collection and Analytics,” help us communicate with our users, or process payments on our behalf. We also may share your information with other third parties when necessary to meet the terms of any agreement that you have with us.
- With other users of the Services. The Services may enable you to share information with other users of the Services. For example, if you post comments to other users through the Services, add information to your profile, accept an invitation to join an activity, participate in local “Championship” challenges, respond to surveys or requests to rate the Services, or use other features of the Services, then your comments, profile information, location, or other information may be seen by other users of the Services. Please ensure when using these features that you do not submit any information that you do not want to be shared with other users or the public.
- For legal purposes. We also may use or share your information with third parties when we believe, in our sole reasonable discretion, that doing so is necessary:
- To comply with applicable law or a court order, subpoena, or other legal processes;
- To investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our terms and conditions, or situations involving threats to Services users, our property, or the property or physical safety of any person or third party;
- To establish, protect, or exercise our legal rights or defend against legal claims.
- For business transfers. We may share your information with third parties to facilitate the financing, securitization, insuring, merger, acquisition, sale, assignment, bankruptcy, or other disposals of all or part of our business or assets.
- Aggregated and de-identified information. We also may share aggregated and de-identified information about Services usages, such as by publishing or sharing reports with third parties about trends in the usage of the PairUP Services, activities that are popular in certain geographic areas, locations where activities frequently occur, or other similar information.
Third-Party Data Collection and Analytics
We may partner with certain third parties to collect, analyze, and use information to engage in analytics, auditing, research, and reporting. For example, we may allow third parties to use an application software development kit (SDK) or server-to-server connection to collect information. An SDK is a section of code that we embed in our Apps to allow third parties to collect information about how users interact with the Apps, and a server-to-server connection enables us to exchange data with third parties when an SDK integration is not feasible or practical. These third parties also may set and access cookies on your device and use web beacons, tags, or similar technologies. They also may collect information about your online activities across different websites or services over time, including on websites and mobile applications that are not owned or operated by PairUP. Like many other online services, the Services do not respond to “do not track” browser signals.
Third-Party Links, Web sites, and Apps
Data Retention and Security
PairUP uses reasonable physical, technical, and administrative safeguards to protect your information against loss or unauthorized access, use, modification, or deletion. However, no security program is 100% secure, and thus we cannot guarantee the absolute security of your information. PairUP retains your information for as long as your account is active (e.g., until you request that we delete your account) or as long as reasonably necessary for its legitimate business purposes, to provide the services to you, to fulfill the purposes described in this Policy, or as required by law.
Your Rights and Choices
PairUP provides you with choices to review, access, and update your information or to exercise your data protection rights, as follows:
- If you no longer want to receive marketing communications from PairUP, please follow the “unsubscribe” instructions that are included at the bottom of each message. Please note that if you unsubscribe from our marketing communications, you will still receive administrative messages.
- You may have rights under applicable laws to request access to, correction, deletion of, or restrictions on the processing of certain information. You also may have rights under applicable laws to opt out or withdraw consent to further processing, request copies of your data, or lodge a complaint with a data protection authority in your jurisdiction. To make such request and/or inquire about such rights, please send us an email at email@example.com with “Attn: Privacy” in the subject line. For your protection, we may only implement requests with respect to the information associated with the particular email address you use to send us your request, and we may need to verify your identity before implementing your request.
Information for Users Outside the United States
The information that we collect through or in connection with our Services may be transferred to and processed in the United States for the purposes described above. PairUP also may subcontract the processing of your data to, or otherwise share your data with, third parties in the United States or countries other than your country of residence. The data-protection laws in these countries may be different from, and less stringent than, those in your country of residence. To the extent that we engage in such cross-border transfers, we may implement standard contractual clauses, contractual arrangements, or other mechanisms, as appropriate, to safeguard information that is transferred to other countries. By agreeing to this Policy in the course of installing the Apps and/or using the Services or by providing any information to us, you expressly consent to such transfer and processing.
If you are an EU resident, our legal basis for processing information, as described above, will depend on the type of information at issue and the purpose for which it is collected and used. In many cases, we rely on your consent to process information, or we process information as necessary for the performance of our agreements with you. We also may rely on our legitimate interests to process your information, for the purposes described in this Policy, except where such interests are overridden by your data protection interests or fundamental rights and freedoms.
The Services are not directed to persons under the age of 18, and PairUP does not knowingly collect information from anyone it knows is under the age of 18.
We ask that you not send us, and you not disclose, any sensitive information (e.g., social security numbers, financial account information, information related to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data, health data, or sexual orientation) on or through the Services or otherwise to us.
Changes to This Policy