Seduct

PRIVACY POLICY

Last updated: 03/12/2023

1. About this Privacy Policy

This Privacy Policy explains how Seduct Pty Ltd (ACN 668 842 028) ("Seduct", "we", "us" or "our") collects, uses, discloses and protects personal information when you use the Seduct mobile application, our website at seduct.com.au and related services (together, the "Service").

We handle personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles. Seduct is a dating service, so some of the information you share with us is personal and sensitive. We take that seriously and aim to explain clearly what we do with it.

This Privacy Policy should be read together with our Terms and Conditions.

2. Information we collect

Information you give us

  1. Account details: your username, mobile number, email address, password, date of birth, gender and the gender or genders you are interested in meeting.
  2. Profile information: your photos, videos (including Flashes), bio, interests, relationship preferences, physical attributes (such as height and body type), your suburb, and any other details you choose to add to your profile or bio.
  3. Verification selfie: if you choose to verify your profile, the selfie you submit.
  4. Messages and communications: messages, photos, videos, voice messages, stickers and Presents you send or receive through the Service, and details of voice and video calls, such as the time, duration and participants. We do not record voice or video calls.
  5. Search and preferences: the filters and preferences you use to search for and discover other Members.
  6. Incognito mode: phone numbers or social media handles of people you choose to hide your profile from.
  7. Reports and support: information you provide when you report or block another Member, contact us, give feedback or take part in a survey.

Information we collect automatically

  1. Location: if you allow it, your device's location, which we use only to show you Members nearby. We never display your exact location or address to other Members. You can also choose to share your location with a Member in a chat. You can turn off location access in your device settings at any time, although some features may not work properly without it.
  2. Usage information: how you use the Service, such as log-in times, profiles viewed, likes, matches, Faves, features used and daily reward activity.
  3. Device and technical information: your device type, operating system, app version, IP address, device identifiers, language settings, crash reports and push notification tokens.
  4. Website information: when you visit our website, information collected through cookies and similar technologies (see section 11).

Information from others

  1. Other Members: information about you contained in reports, messages or Incognito lists submitted by other Members.
  2. App stores: Apple and Google process all payments. We receive confirmation of your purchases and subscription status, but we do not receive or store your full card or bank details.
  3. Service providers: information from providers that help us operate the Service, such as analytics and fraud prevention services.

3. Sensitive information

Under Australian privacy law, "sensitive information" includes information about a person's racial or ethnic origin, sexual orientation or practices, health, criminal record and biometric information. Because Seduct is a dating service, some information you provide may be sensitive. For example:

  1. the gender or genders you are interested in meeting may indicate your sexual orientation;
  2. your gender (including if you identify as transgender) and your interests, preferences and search filters may reveal information about your sexual orientation or practices; and
  3. any information about your cultural background, ethnicity, religion or similar matters that you choose to include in your bio.

We only collect sensitive information with your consent, or where the law otherwise permits it (for example, when investigating a report of harassment or abuse). By choosing to provide this information, you consent to us using it to operate the Service as described in this Privacy Policy, including to show your profile to compatible Members. Where information is optional, you do not have to provide it. Some information you add to your profile, such as your gender and interests, will be visible to other Members.

Verification selfies and face log-in. Verification selfies are reviewed by our team, who compare them with your profile photos. We do not use automated facial recognition to verify profiles, and your selfie is never shown to other Members. If you use Face ID or a similar feature to log in, this is handled by your device. We do not receive or store your facial data.

4. How we use your information

We use personal information to:

  1. create and manage your account, including verifying your mobile number;
  2. show your profile and Flashes to other Members and show you profiles that match your preferences, location and settings;
  3. enable messaging, calls, Presents and other features;
  4. verify profiles when you ask us to;
  5. keep Members safe, including reviewing reports, moderating content, detecting fake accounts, scams and other harmful conduct, enforcing our Terms and Conditions and preventing banned Members from returning;
  6. process subscriptions and in-app purchases and manage Coins, Presents and Hypes;
  7. send you service messages, such as account notices, security alerts, match and message notifications and updates to our terms;
  8. send you marketing emails, if you have agreed to receive them (you can unsubscribe at any time);
  9. understand how the Service is used, fix problems and improve and develop the Service;
  10. respond to your questions, requests and complaints; and
  11. comply with our legal obligations, respond to lawful requests and establish, exercise or defend legal claims.

We do not sell your personal information.

5. Automated processing

We use automated systems to operate parts of the Service. For example, our matching system uses your gender, the gender or genders you are interested in, your location, your settings and your activity to decide which profiles and Flashes are shown to you, and to whom your profile is shown. We may also use automated tools to help detect content or behaviour that may breach our Terms and Conditions. Decisions to suspend or ban an account are made by our team, not by automated systems. If you have questions about how these systems affect you, please contact us.

6. What other Members can see

Other Members can see your profile, including your username, photos, videos, Flashes, age, gender, bio, interests, verification status and suburb. They can also see messages and content you send them.

Other Members cannot see your mobile number, email address, date of birth, verification selfie, exact location or address, unless you choose to share these with them. Please think carefully before sharing personal details with someone you have not met. Once you send information to another Member, we cannot control what they do with it.

7. Who we share information with

We may disclose personal information to:

  1. other Members, as described in section 6;
  2. service providers who help us run the Service, such as cloud hosting and data storage providers, SMS verification providers, email service providers, analytics providers, customer support tools and our professional advisers. They may only use the information to provide services to us;
  3. Apple and Google, to process purchases and deliver the app and notifications;
  4. our staff and contractors, who need access to perform their roles, such as moderating content and verifying profiles;
  5. police, regulators, courts and government authorities (including the eSafety Commissioner), where required or authorised by law, or where we reasonably believe disclosure is necessary to prevent or lessen a serious threat to someone's life, health or safety, or to investigate unlawful activity;
  6. a buyer or successor, if all or part of our business is sold, merged or restructured, subject to them protecting your information in line with this Privacy Policy; and
  7. anyone else, with your consent.

8. Overseas disclosure

Some of our service providers store or process information outside Australia, including in the United States and other countries where they or their data centres are located. When we disclose personal information overseas, we take reasonable steps to ensure the recipient handles it in a way that is consistent with the Australian Privacy Principles, for example through contractual obligations.

9. How long we keep your information

  1. We keep your information for as long as your account is active and as needed to provide the Service.
  2. You can delete your account at any time in the app's Settings. When you do, your profile is removed from the Service straight away, and we delete or de-identify your personal information within a reasonable period, except as set out below.
  3. We may keep some information for longer where we need to, including:
    1. records relating to reports, moderation decisions and banned accounts, to protect Members and prevent banned Members from returning;
    2. purchase and transaction records, which we must keep for tax and accounting purposes;
    3. information we need to comply with the law, respond to lawful requests or resolve disputes; and
    4. copies held in backups for a limited period until they are overwritten.
  4. Content you delete, such as a Flash or photo, is removed from your profile straight away. We may keep a copy for a limited period for safety, moderation and legal purposes.
  5. Messages you have sent may remain visible to the Members you sent them to.

10. How we protect your information

We take reasonable steps to protect personal information from misuse, interference, loss and unauthorised access, modification or disclosure. These steps include encryption of data in transit, access controls that limit staff access to people who need it, and secure hosting. No system is completely secure, and we cannot guarantee the security of information sent over the internet.

If a data breach is likely to result in serious harm to you, we will notify you and the Office of the Australian Information Commissioner as required by the Notifiable Data Breaches scheme.

11. Cookies and similar technologies

Our website uses cookies and similar technologies to make the site work, understand how visitors use it and measure the effectiveness of our marketing. Some cookies are set by third parties, such as Google and Meta, and may be used to show you Seduct advertisements on other websites and social media. You can control or delete cookies through your browser settings, and you can manage advertising preferences through your Google and Meta account settings.

12. Your rights and choices

  1. Access and correction. You can view and update most of your information in the app. You can also ask us for access to the personal information we hold about you, or ask us to correct it. There is no charge to make a request. In limited cases permitted by the Privacy Act, we may refuse access, and we will tell you why.
  2. Deletion. You can delete your account in Settings at any time, as described in section 9.
  3. Location. You can turn off location access in your device settings.
  4. Notifications. You can manage push notifications in the app or your device settings.
  5. Marketing. You can unsubscribe from marketing emails using the link in any email or by contacting us. We will still send you service messages about your account.
  6. Blocking and Incognito mode. You can block Members and use Incognito mode to control who can see your profile.

13. Complaints

If you have a concern about how we have handled your personal information, please contact our Privacy Officer using the details below. We will acknowledge your complaint within 5 business days and aim to respond in writing within 30 days.

If you are not satisfied with our response, you can complain to the Office of the Australian Information Commissioner at oaic.gov.au or on 1300 363 992.

14. Age restriction

The Service is only for people aged 18 and over. We do not knowingly collect personal information from anyone under 18. If we learn that a user is under 18, we will close their account and delete their information, except where we need to keep it for safety or legal reasons. If you believe someone under 18 is using Seduct, please report it to us.

15. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. If we make a significant change, we will let you know through the app or by email before it takes effect. The date at the top of this page shows when it was last updated.

16. Contact us

Privacy Officer
Seduct Pty Ltd (ACN 668 842 028)
Email: admin@seduct.com.au

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