COOKIES & PRIVACY - Chapter One

PRIVACY POLICY:

We are Chapter One Dating, a UK Dating Agency changing the way you meet new people. We take your privacy very seriously. In order for us to provide our match making service, we collect and are responsible for certain personal information about you.

Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.

We collect, use and are responsible for certain personal information about you. When we do so we are subject to the General Data Protection Regulation, which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.

1. Key terms

It would be helpful to start by explaining some key terms used in this policy:

We, us, our	Chapter One Dating Ltd (trading as Chapter One Dating) a company registered in England and Wales under company number: 13035853 Our registered office is at: Unit 14 Elgar Business Centre Moseley Road, Hallow, Worcester, Worcestershire, England, WR2 6NJ
Our data protection officer	Ella Stearn Unit 14 Elgar Business Centre Moseley Road, Hallow, Worcester, Worcestershire, England, WR2 6NJ hello@chapteronedating.com
Personal information	Any information relating to an identified or identifiable individual
Special category personal information	Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership Genetic and biometric data Data concerning health, sex life or sexual orientation

2. Personal information we collect about you

We may collect and use the following personal information about you:

your name and contact information, including email address and telephone number
Information to enable us to check and verify your identity, eg your date of birth
your gender information, if you choose to give this to us
location data, if you choose to give this to us
your billing information, transaction and payment card information
your personal or professional interests
your professional online presence, eg LinkedIn profile
your contact history, purchase history and saved items
information from accounts you link to us, eg Facebook
information to enable us to undertake credit or other financial checks on you
Information about how you use our website, IT, communication and other systems
your responses to surveys, competitions and promotions

Special category person Information

It is important to note that some of the information you choose to provide us may be considered “special”, this can be information about sexual orientation, race, religion, political beliefs. If you choose to provide this information, you consent to our processing of that information

COLLECTING DATA TO PROVIDE YOU WITH OUR MATCHMAKING SERVICES

In most instances the information we collect about you is to establish enough information to try and match you with the right person. This information is required to provide services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing services to you.

The information we collect, both as a free or premium member, will enable us to help tailor our own searches when we are trying to match you with a member in our database. Naturally, and as you will expect, this information will be passed through to potential matches to review (and hopefully accept a date with you!) Please note that if you do not wish us to disclose any information both person or special category, please let us know and we not disclose such details.

When you choose to participate in our any promotion or events we will use, collect and process that information which you have submitted to register and enter.

As part of our tailored match making service, you will often be speaking with your matchmaker from Chapter One Dating. When you speak to our team we collect any information which we receive during those calls.

Not forgetting, we will also process interactions with other members as well as the content you publish, which all helps us provide our service to you.

OTHER MEMBERS

It important that we get to know as much about you to help you with your next match (this is of course unless you ask us not to). Other members may provide information as part of using the service. For instance and fingers crossed, we may collect information about you from other users if they contact us about you.

By providing us with all this information, you understand and agree this information and data will be stored by us to help fulfil our matchmaking services to you

Other information with your consent

Often you may ask us to only look for matches within your own location, with your permission we then collection information in respect of your geolocation. You may not want to share these details with us, if so, we will not collect it.

You may want to publish a photo of yourself, in this instance we will collect your photo and publish it.

3. How your personal information is collected

We collect most of this personal information directly from you—in person, by telephone, text or email and/or via our website. However, we may also collect information:

from publicly accessible sources, eg Companies House
sanctions screening providers;
credit reference agencies;
customer due diligence providers;
from a third party with your consent, eg insert example, eg your bank or building society
from cookies on our website—for more information on our use of cookies, please see our cookie policy
via our IT systems, :
communications systems, email and instant messaging systems;
social media channels.

How and why we use your personal information

Under data protection law, we can only use your personal information if we have a proper reason for doing so, eg:

to comply with our legal and regulatory obligations;
for the performance of our contract with you or to take steps at your request before entering into a contract;
for our legitimate interests or those of a third party; or
where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

Naturally, our main purpose for using your information is to provide our matchmaking services. Additionally, we may use your information to update you on new services or events.

The table below explains other instances where we use (process) your personal information for and our reasons for doing so:

What we use your personal information for	Our reasons
To provide matchmaking services to you	For the performance of our contract with you i.e to provide you with our matchmaking services or to take steps at your request before entering into a contract
Register your profile and details To help you match you with other members Analyse your profile and that of other users to recommend meaningful connections Provide you with customer support and respond to your requests To show different member profiles to other members users’ When you interact with your Chapter One Dating matchmaker over telephone, email or letters.	For the performance of our contract with you i.e. to provide you with our matchmaking services or to take steps at your request before entering into a contract
To prevent and detect fraud against you or Chapter One Dating Ltd	For our legitimate interests or those of a third party, ie to minimise fraud that could be damaging for us and for you
Conducting checks to identify our members and verify their identity Screening for financial and other sanctions or embargoes Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, eg under health and safety regulation or rules issued by our professional regulator	To comply with our legal and regulatory obligations
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies	To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, eg policies covering security and internet use	For our legitimate interests or those of a third party, ie to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training and quality control	For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service for you at the best price
Ensuring the confidentiality of commercially sensitive information	For our legitimate interests or those of a third party, ie to protect trade secrets and other commercially valuable information To comply with our legal and regulatory obligations
Statistical analysis to help us manage our business, eg in relation to our financial performance, customer base, services or other efficiency measures	For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service for you at the best price
Preventing unauthorised access and modifications to systems	For our legitimate interests or those of a third party, ie to prevent and detect criminal activity that could be damaging for us and for you To comply with our legal and regulatory obligations
Updating and enhancing member records and our data-base	For the performance of our contract with you or to take steps at your request before entering into a contract To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, eg making sure that we can keep in touch with our members about new matches.
Marketing our services and those of selected third parties to: —existing and former members; —third parties who have previously expressed an interest in our services; —third parties with whom we have had no previous dealings.	For our legitimate interests or those of a third party, ie to promote our business to existing and former customers
Credit reference checks via external credit reference agencies	For our legitimate interests or those of a third party, ie to ensure our members are likely to be able to pay for our products and services

5. Promotional communications

We may use your personal information to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new services.

We have a legitimate interest in processing your personal information for promotional purposes (see above ‘How and why we use your personal information’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal information with the utmost respect and never share it with other organisations outside the Chapter One Dating Ltd group for marketing purposes.

You have the right to opt out of receiving promotional communications at any time by:

contacting us at hello@chapteronedating.com
using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts

We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

6. Who we share your personal information with

The reason you are using our services and providing us with your information is because it is likely that you are looking for a relationship with another member (hopefully!) Therefore the main sharing of a member’s information is of course, with other members. However we also may share personal information with:

third parties we use to help deliver our services to you, e.g. payment service providers
other third parties we use to help us run our business, eg marketing agencies, website agencies or website hosts;
third parties approved by you, eg social media sites you choose to link your account to or third party payment providers;
our bank.

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

7. Where your personal information is held

Information may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal information with’).

Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: ‘Transferring your personal information out of the UK and EEA’.

8. How long your personal information will be kept

We will keep your personal information while you have an account with us or we are providing services to you. Thereafter, we will keep your personal information for as long as is necessary:

to respond to any questions, complaints or claims made by you or on your behalf;
to show that we treated you fairly;
to keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this policy.

When it is no longer necessary to retain your personal information, we will delete or anonymise it.

In practice, we remove your records after you have deleted your account and therefore cancelled your membership. For how to do that, click here.

9. Transferring your personal information out of the UK and EEA

To deliver services to you, it is sometimes necessary for us to share your personal information outside the UK and/or European Economic Area (EEA), eg:

with your and our service providers located outside the UK/EEA;
if you are based outside the UK/EEA;

These transfers are subject to special rules under European and UK data protection law. This means we can only transfer your personal information to a country or international organisation outside the UK/EEA where:

the European Commission has issued an ‘adequacy decision’ in relation to that country or international organisation; or
there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for data subjects; or
a specific exception applies under data protection law

These are explained below.

10. European Commission adequacy decision

The European Commission has the power to determine whether a country or international organisation provides an adequate level of protection for personal information and, if it does, to issue an ‘adequacy decision’. The effect of such a decision is that personal information can flow from the UK/EEA to that country without any further safeguards being necessary.

It can take several years for the European Commission to issue an adequacy decision and only a small number of countries currently benefit from one.

11. Transfers with appropriate safeguards

We may transfer your data to a third country on this ground where we are satisfied the transfer complies with data protection law, appropriate safeguards are in place, and enforceable rights and effective legal remedies are available for data subjects.

The safeguards will usually include using standard data protection contract clauses approved by the European Commission

12. Transfers under an exception

In the absence of an adequacy decision or appropriate safeguards, we may transfer personal information to a third country or international organisation where an exception applies under relevant data protection law, eg:

you have explicitly consented to the proposed transfer after having been informed of the possible risks;
the transfer is necessary for the performance of a contract between us or to take pre-contract measures at your request;
the transfer is necessary for a contract in your interests, between us and another person; or
the transfer is necessary to establish, exercise or defend legal claims

We may also transfer information for the purpose of our compelling legitimate interests, so long as those interests are not overridden by your interests, rights and freedoms. Specific conditions apply to such transfers and we will provide relevant information if and when we seek to transfer your personal information on this ground.

13. Further information

If you would like further information about data transferred outside the UK or EEA, please contact our Data Protection Officer (see ‘How to contact us’ below).

14. Your rights

You have the following rights, which you can exercise free of charge:

Access	The right to be provided with a copy of your personal information (the right of access)
Rectification	The right to require us to correct any mistakes in your personal information
To be forgotten	The right to require us to delete your personal information—in certain situations
Restriction of processing	The right to require us to restrict processing of your personal information—in certain circumstances, eg if you contest the accuracy of the data
Data portability	The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
To object	The right to object: —at any time to your personal information being processed for direct marketing (including profiling); —in certain other situations to our continued processing of your personal information, eg processing carried out for the purpose of our legitimate interests.
Not to be subject to automated individual decision making	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please:

email, call or write to us or our Data Protection Officer—see below: ‘How to contact us’; and
let us have enough information to identify you (eg your full name, address and customer or matter reference number);
let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
let us know what right you want to exercise and the information to which your request relates.

15. Keeping your personal information secure

We have appropriate security measures to prevent personal information from being accidentally lost, or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

[If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

16. How to complain

We hope that we OR our Data Protection Officer can resolve any query or concern you may raise about our use of your information.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.

17. Changes to this privacy policy

This privacy notice was published on 24 November 2020 We may change this privacy notice from time to time—when we do we will inform you via our website.

18. How to contact us

Please contact us and/or our Data Protection Officer by post or email if you have any questions about this privacy policy or the information we hold about you.

Our contact details are shown below:

Our contact details	Our Data Protection Officer’s contact details
Unit 14 Elgar Business Centre Moseley Road, Hallow, Worcester, Worcestershire, England, WR2 6NJ hello@chapteronedating.com	Unit 14 Elgar Business Centre Moseley Road, Hallow, Worcester, Worcestershire, England, WR2 6NJ hello@chapteronedating.com

COOKIES POLICY:

Our Use of Cookies

A cookie is a small file of letters and numbers that we store on Your browser or the hard drive of Your computer if you agree. Cookies contain information that is transferred to Your computer’s hard drive.

Our Site may place and access certain first party Cookies on Your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve Your experience of Our Site and to provide and improve Our services. We have carefully chosen these Cookies and have taken steps to ensure that Your privacy and Personal Data is protected and respected at all times.

All Cookies used by and on Our Site are used in accordance with current Cookie Law.

Before Cookies are placed on Your computer or device, You will be shown a pop-up requesting Your consent to set those Cookies. By giving Your consent to the placing of Cookies You are enabling Us to provide the best possible experience and service to You. You may, if You wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended.

Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”.

Your consent will not be sought to place these Cookies, but it is still important that You are aware of them. You may still block these Cookies by changing Your internet browser’s settings as detailed below, but please be aware that Our Site may not work properly if You do so. We have taken great care to ensure that Your privacy is not at risk by allowing them.

Our Site uses analytics services provided by Google Analytics. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling Us to better understand how Our Site is used. This, in turn, enables Us to improve Our Site and the services offered through it. You do not have to allow Us to use these Cookies, however whilst Our use of them does not pose any risk to Your privacy or Your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for You.

The analytics service(s) used by Our Site use(s) Cookies to gather the required information.

In addition to the controls that We provide, You can choose to enable or disable Cookies in Your internet browser. Most internet browsers also enable You to choose whether You wish to disable all cookies or only third party cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in Your internet browser or the documentation that came with Your device.

You can choose to delete Cookies on Your computer or device at any time, however You may lose any information that enables You to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.

It is recommended that You keep Your internet browser and operating system up-to-date and that You consult the help and guidance provided by the developer of Your internet browser and manufacturer of Your computer or device if You are unsure about adjusting Your privacy settings.