PRIVACY POLICY

This Privacy Policy has been updated on february 21, 2024

Welcome to our Privacy Policy!

At Lynq, operated by 3LLD Ltd (Legal address: Agias Faneromenis, 143-145 PATSIAS COURT, Flat/Office 201, Larnaca, Cyprus, 6031, registration number: НЕ 451313), your privacy is a top priority. Your privacy is at the core of how we design and build the Services and products you know and love so that you can fully trust them and focus on building meaningful connections.

3LLD Ltd acts as the data controller and processor of the Personal Information collected and processed through Lynq`s Application.

We appreciate that you put your trust in us when you provide us with your Personal Information, and we do not take this lightly.

This Privacy Policy (the “Privacy Policy”) explains Lynq`s (“we”, “us”, or “our”) online privacy practices for Personal Information collected through the Application. This Privacy Policy governs how we use, collect, and disclose the Personal Information gathered from or provided by Users of these Services worldwide. Your use of the Services is evidence of your Consent to the collection and use of Personal Information in accordance with this Privacy Policy.

This Privacy Policy should be read in conjunction with Lynq`s Terms of Use, incorporated herein by reference. Capitalized terms used and not otherwise defined in this Privacy Policy shall have the meaning given to them in the Terms of Use.

AGREEMENT AND YOUR CONSENT

Please read this Privacy Policy carefully. By using the Services, you are acknowledging that you have read and understood this Privacy Policy and you are agreeing to be legally bound by it, and you are consenting to the use, collection, transmission, and disclosure of your Personal Information as provided in this Privacy Policy.

If you are using Lynq`s App Store application, in addition to this Privacy Policy you shall read and agree to Apple Privacy Policy.

If you are using Lynq`s Play Market application, in addition to this Privacy Policy you shall read and agree to Google Privacy Policy.

If you do not Consent to the collection of Personal Information in accordance with the Privacy Policy or if you do not agree with all of the terms of this Privacy Policy, you should not use the Services.

PRINCIPLES OF DATA PROCESSING

We adhere to the following principles in order to protect your privacy:

2.1.1.principle of purposefulness — we process Personal Information fairly and in a transparent manner only for the achievement of determined and lawful objectives, and they shall not be processed in a manner not conforming to the objectives of data processing;

2.1.2.principle of minimalism — we collect Personal Information only to the extent necessary for the achievement of determined purposes and do not keep Personal Information if it is no longer needed;

2.1.3.principle of data quality — we update Personal Information shall be up-to-date, complete, and necessary for the achievement of the purpose of data processing;

2.1.4.principle of security — security measures shall be applied in order to protect Personal Information from unauthorized or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical and organizational measures;

2.1.5.principle of individual participation — the persons shall be notified of data collected concerning him or her, the persons shall be granted access to the data concerning him or her and the persons have the right to demand the correction of inaccurate or misleading data.

Lynq does not sell Your Personal Information to third parties. A “sale” of Personal Information under the California Consumer Privacy Act (“CCPA”) is defined broadly to include the “selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means” the Personal Information of a User to another business or third party “for monetary or other valuable consideration.” 

THE INFORMATION WE COLLECT

Depending on how you use our Services, we may collect Personal Information.

"Personal Information" means any information by which an individual can be identified or information that can directly or indirectly identify or relate to any individual. Personal Information includes:

3.1.1.full name (name and surname);

3.1.2.email address;

3.1.3.gender;

3.1.4.date of birth;

3.1.5.geolocation;

3.1.6.family status;

3.1.7.purpose of dating;

3.1.8.interests;

3.1.9.lifestyles;

3.1.10.photos;

3.1.11.debit or credit card number or other financial information.

Personal Information which is obligatory for the Account registration on Lynq and further use of the Service: 

3.2.1.full name (name and surname);

3.2.2.email address;

3.2.3.gender;

3.2.4.date of birth.

Personal Information which you can share with us for full use of the Service and which is not obligatory:

3.3.1.geolocation;

3.3.2.family status;

3.3.3.interests;

3.3.4.lifestyles;

3.3.5.purpose of dating;

3.3.6.photos.

To achieve the purposes of our Application and provide you with the Service, we need to show a part of your Personal Information to other Users. By using and providing your Personal Information to us, you agree that after registering the Account in Lynq, other Users can view such Personal Information from your Account:

3.4.1.full name (name and surname);

3.4.2.gender;

3.4.3.age;

3.4.4.geolocation;

3.4.5.family status;

3.4.6.purpose of dating;

3.4.7.compatibility of zodiac signs;

3.4.8.detail information about another user's zodiac sign;

3.4.9.predictions;

3.4.10.interests;

3.4.11.lifestyles;

3.4.12.photos.

We, as the data processor, reserve the right to process Personal Information and, based on it, obtain new information, including but not limited to:

3.5.1.compatibility of zodiac signs;

3.5.2.detail information about another user's zodiac sign;

3.5.3.predictions.

Information automatically collected through your use of our Services:

When you use our Services, this generates technical data about which features you’ve used, how you’ve used them, and the devices you use to access our Services. See below for more details:

3.7.1.Usage Information. Using the Services generates data about our activity on our Services, for instance how you use them (e.g., when you logged in, features you’ve been using, actions taken, the information shown to you, referring webpages addresses and ads that you interacted with) and your interactions with other members (e.g., members you connect and interact with, when you exchanged with them, number of messages you send and receive).

3.7.2.Device information. We collect information from and about the device(s) you use to access our Services, including hardware and software information such as IP address, device ID and type, app settings and characteristics, app crashes, advertising IDs (which are randomly generated numbers that you can reset by going into your device’s settings), identifiers associated with cookies or other technologies that may uniquely identify a device or browser.

3.7.3.Other information with your Consent. If You give us permission, we can collect your precise geolocation (latitude and longitude). The collection of your geolocation may occur in the background even when you aren’t using the Services if the permission you gave us expressly permits such collection. If You decline permission for us to collect your precise geolocation, we will not collect it. Similarly, if you Consent, we may collect photos and videos (for instance, if you want to publish a photo or video or participate in streaming features on our Services).

You may decide to share information with us through your social media account, for instance, if you decide to create and log into your Account via your social media or other account (e.g., Facebook, Google, Instagram, or Apple) or to upload onto our Services information such as photos from one of your social media accounts.

OUR USE OF THIS INFORMATION

The main reason we use your Personal Information is to deliver and improve our Services. Additionally, we use your info to help keep you and our community safe and to provide you with advertising that may be of interest to you, including but not limited to. 

To provide our Services to you:

4.1.1.create and manage your Account;

4.1.2.provide you with customer support and respond to your requests;

4.1.3.personalize pricing, offer discounts and other promotions, and complete your transactions;

4.1.4.administer contests.

To help you connect with other Users:

4.2.1.recommend you to other Users and recommend other Users to you;

4.2.2.show Users profiles to one another;

4.2.3.enable Users to search for and connect with Users.

To provide offers and operate advertising and marketing campaigns;

4.3.1.perform and measure the effectiveness of advertising campaigns on our Services and marketing our Services off our platform;

4.3.2.communicate with you about products or Services that we believe may interest you.

To improve our Services and develop new ones:

4.4.1.administer focus groups, market studies, and surveys;

4.4.2.review interactions with customer care teams to improve our quality of Service;

4.4.3.understand how Users typically use the Services to improve them (for instance, we may decide to change the look and feel or even substantially modify a given feature based on how Users react to it);

4.4.4.develop new features and Services (for example, we may decide to build a new interests-based feature further to requests received from Users).

To ensure legal compliance:

4.5.1.comply with legal requirements;

4.5.2.assist law enforcement.

To prevent, detect, and fight fraud and other illegal or unauthorized activities:

4.6.1.find and address ongoing, suspected, or alleged violations of our Terms of Use, notably through the review of reports and interactions between members;

4.6.2.better understand and design countermeasures against violations of our Terms of Use;

4.6.3.retain data related to violations of our Terms of Use to address the violation and prevent recurrences;

4.6.4.enforce or exercise our rights, for example, our rights set out in our Terms of Use;

4.6.5.communicate to individuals who submit a report, including what we’ve done as a result of their submission.

To process your Personal Information as described in this Privacy Policy, we rely on the following legal bases:

Provide our Service to you: The reason we process your Personal Information for purposes from provisions 4.1 and 4.2 above is to perform the contract that you have with us. For instance, as you go about using our Service to build meaningful connections, we use your Personal Information to maintain your Account and your profile, make it viewable to other Users and recommend other Users to you, and otherwise provide our free and paid features to you and other Users.

Legitimate interests: We process your Personal Information for purposes from provisions 4.3, 4.4, and 4.6 above, based on our legitimate interest. For instance, we analyze User`s behavior on our Services to continuously improve our offerings, we suggest offers we think might interest you and promote our own Services, we process Personal Information to help keep our Users safe and we process data where necessary to enforce our rights, assist law enforcement and enable us to defend ourselves in the event of a legal action.

4.10.Comply with applicable laws and regulations: We process your Personal Information for purpose from provision 4.5 above where it is necessary for us to comply with applicable laws and regulations and evidence our compliance with applicable laws and regulations. For example, we retain traffic data and data about transactions in line with our accounting, tax, and other statutory data retention obligations and are able to respond to valid access requests from law enforcement. We also keep data evidencing Consents Users give us and decisions they may have taken to opt out of a given feature or processing.

4.11.Consent: From time to time, we may ask for your Consent to collect specific information such as your precise geolocation, or use your Personal Information for certain specific reasons. In some cases, you may withdraw your Consent by adapting your settings (for instance in relation to the collection of your precise geolocation) or by deleting your Content (for instance where you entered information in your profile that may be considered “special” or “sensitive”). In any case, you may withdraw your Consent at any time by contacting us at this address - [email protected].

LAWFUL BASIS OF DATA PROCESSING

If you are located in the European Union (EU) privacy rights are granted and all processing of Personal Information is performed by regulations and rules following Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons concerning the processing of Personal Information and on the free movement of such data, known as the General Data Protection Regulation (“GDPR”). 

5.1.1.Under Art. 6 of the GDPR, we only process Personal Information, where we have a lawful basis for doing so.

5.1.2.The processing of Personal Information, described in p. 4.1 of this Privacy Policy is based on contract obligations (Art. 6 (1) lit. (b) GDPR) and is performed only for the purposes specified in this Privacy Policy — to meet your request concerning the Service, to formalize the development of the contractual relationship.

5.1.3.The processing of Personal Information, described in p. 5.1.1 and 5.1.2 of this Privacy Policy is based on a legitimate interest (Art. 6 (1) lit. (f) GDPR) and is performed only for the purposes specified in this Privacy Policy.

If you are located in California, all processing of Personal Information is performed in accordance with regulations and rules following the California Consumer Privacy Act, Cal. Civ. Code § 1798.100 et seq. (“CCPA”).

If you are located in the United Kingdom, all processing of Personal Information is performed in accordance with regulations and rules following the Data Protection Act 2018 and the UK General Data Protection Regulation.

If you are located in Australia, all processing of Personal Information is performed in accordance with regulations and rules following the Privacy Act 1988.

If you are located in Canada, all processing of Personal Information is performed in accordance with regulations and rules following the Personal Information Protection and Electronic Documents Act (S.C. 2000, c. 5).

If you are located in New Zealand, all processing of Personal Information is performed in accordance with regulations and rules following the Privacy Act 2020.

If you are located in Brazilia, all processing of Personal Information is performed in accordance with regulations and rules following the Lei Geral de Proteção de Dados.

If you are located in Ukraine, all processing of Personal Information is performed in accordance with regulations and rules following the Law of Ukraine "On Personal Data Protection".

If you are located in other countries, that are not mentioned above, all processing of Personal Information is performed in accordance with regulations and rules of the following countries. 

CONSENT TO PERSONAL INFORMATION PROCESSING

EU Persons Consent to Personal Information processing

6.1.1.If you are an EU Person and to process your Personal Information we need to receive your Consent, as it is prescribed by GDPR, we will process your Personal Information only in the case we have received from you a freely given, specific, informed, and unambiguous indication of your wishes by which you signify agreement to the processing of your Personal Information (“Consent”).

6.1.2.You have the right to withdraw your Consent at any time. You can submit such a request by sending us an email to [email protected]. Your withdrawal of Consent shall not affect the lawfulness of your Personal Information processing based on Consent before it's withdrawal.

6.1.3.Except as required or enabled by law we will not use or disclose your Personal Information for any purpose for which you refuse Consent or later withdraw your Consent. If You withdraw Consent, you agree that in spite of this withdrawal, we may continue to use the Personal Information previously provided to us to the extent that we are contractually or otherwise legally obliged to do so and to the extent necessary to enforce any contractual obligation.

Non-EU Persons Consent to Personal Information processing

6.2.1.If you are not an EU Person, by transferring to us your Personal Information via the Services or otherwise, you irrevocably and unconditionally Consent and agree that the Lynq shall be entitled, in accordance with this Policy: to process in any manner, including to collect, store and use your Personal Information provided to us.

HOW WE SHARE INFORMATION

You share Personal Information with other users when you voluntarily disclose Personal Information on the Service, and you agree that the list of information from your Account specified in condition 3.3 under this Privacy Policy will be visible to other Users. Please be careful with your Personal Information and make sure that the Content you share is stuff that you’re comfortable being visible. If you choose to limit the audience for all or part of your profile or for certain Content or Personal Information, then it will be visible according to your settings. If someone submits a report involving you (such as a claim that you violated our Terms of Use), we may communicate to the reporter actions, if any, we took as a result of their report.

We use vendors to help us operate, distribute, market, and improve our Services, such as data hosting and maintenance, analytics, customer care, marketing, advertising, payment processing and security operations. We also share information with vendors who distribute and assist us in advertising our Services. For instance, we may share limited information on you in hashed, non-human readable form to advertising vendors. We follow a strict vetting process prior to engaging any vendor or working with any partner. Our vendors and partners must agree to strict confidentiality obligations.

Some third-party companies, such as Firebase Analytics or Appsflyer provide us with web analytics and intelligence about our Website which may also be used to provide measurement services and target ads. These companies use programming code to collect information about your interaction with our Website, such as the pages you visit, the links you click on, and how long you are on our Website.

We can share your information with our Affiliates for limited legitimate business purposes allowed under applicable law.

We may transfer your information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy, or other change of ownership or control.

We may disclose your information if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government/law enforcement investigation, or other legal requirements; (ii) to assist in the prevention or detection of crime (subject in each case to applicable law); or (iii) to protect the safety of any person. 

We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and the legal rights of our users, business partners, or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.

We may use and share non-personal information (meaning information that, by itself, does not identify who you are such as device information, general demographics, general behavioral data, location in de-identified form), as well as Personal Information in hashed, non-human readable form, under any of the above circumstances. We may also share this information with other third parties (notably advertisers) to develop and deliver targeted advertising on our Services and on websites or applications of third parties, and to analyze and report on advertising you see. We may combine this information with additional non-personal information or Personal Information in hashed, non-human readable form collected from other sources.

HOW LONG WE RETAIN YOUR INFORMATION

We keep your Personal Information only as long as we need it to provide you with our Services. 

If you decide to stop using our Services, you can close your Account and your profile will stop being visible to other users. Note that we will delete your Account automatically if you are inactive for a period of six months. 

EU Territory. We store Personal Information as long as it is needed for the provision of our Services. This Section shall not prevent any technical storage or access to the Personal Information for the sole purpose of carrying out the transmission of a communication or as strictly necessary in order for us to provide the Service you requested.

As explained in the GDPR statement, we strive to anonymize the data when possible. If you decide to exercise your right to erasure we will also inform our Affiliates to delete all your data.

US Territory. We will retain collected Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by applicable legislation.

Storing might be different depending on the territory of collecting the Personal Information and the applicable legislation, but we always strive to store the Personal Information only as long as it is needed for the purposes of providing, improving, or personalizing our Services.

SECURITY

We have implemented reasonable administrative, physical, and technical security controls designed to prevent unauthorized disclosure of the information you provide to us. These systems are structured to deter and prevent hackers and others from accessing this information. Due to the nature of Internet communications and evolving technologies, however, we cannot guarantee that the information you provide us will remain free from loss, misuse, or alteration by third parties who, despite our efforts, obtain unauthorized access.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your information, we cannot guarantee the security of your Personal Information transmitted to our Application. Any transmission of Personal Information is at your own risk. We are not responsible for circumventing any privacy settings or security measures contained in the Application.

PROTECTION OF THE PERSONAL INFORMATION SHARED WITH THIRD PARTIES

10.1.We will obtain assurances from any third party to whom we disclose Personal Information that such third party will safeguard Personal Information consistently with this Privacy Policy. Applicable third-party agreements will provide at least the same level of protection as is required by this Privacy Policy and as may be required by applicable privacy legislation. Where we have knowledge that a third party is using or disclosing Personal Information in a manner contrary to this Privacy Policy, we will take reasonable steps to prevent or stop the use or disclosure of the Personal Information and/or to obtain the third party’s deletion, destruction, anonymization or return of the Personal Information. 

10.2.Your location will never be disclosed to a third party, except with your Consent or in accordance with this Privacy Policy.

CHILDREN

11.1.We understand the importance of protecting children's privacy, especially in an online environment. The Services are not designed for or directed at children under the age of 18 years old. We do not knowingly collect personal data from such people. If a parent or guardian becomes aware that their child has provided us with personal data, they should contact us using the details provided above to delete it.

11.2.We also recommend that parents monitor their children’s internet activities and learn and employ software or other tools that can help their children enjoy their online experience without compromising their personal safety or allowing them to use the Internet in a manner inconsistent with their parent/guardian’s preferences.

11.3.We do not intentionally collect or maintain information from persons under the age of 18, however, according to each country and its laws, the processing of the personal data of a child will be lawful where the child is at another age.

11.4.If you believe that we might have any information from or about a child under 18 years of age please contact us at [email protected].

11.5.If we determine upon collection that a user is under this age, we will not use or maintain his/her Personal Information without the parent/guardian’s Consent. If we become aware that we have unknowingly collected personally identifiable information from a child under the age of 18, we will make reasonable efforts to delete such information from our records.

PRIVACY POLICY CHANGES

12.1.From time to time, we may change this Privacy Policy. For substantive changes, we will make reasonable efforts to notify you of these changes. We may provide you with notice of substantive changes through the App, send you an email, or inform you through another method of communication.

CONTACT US

If you have questions about this Privacy Policy, please send an email to [email protected].