Chappy Privacy Policy

Welcome to the Chappy Privacy Policy (“Policy”). This explains exactly how your information is looked after by Chappy. Here are the topics that this Policy covers:

        
  1. What information we collect and how we collect it.
  2.     
  3. How we use the information and who we share it with.
  4.     
  5. How you can access and update such information.
  6.     
  7. How we protect the information we store about you.

Who operates Chappy?

Chappy is operated by Chappy Limited, a company registered in England at The Broadgate Tower, Third Floor, 20 Primrose Street, London EC2A 2RS. Chappy is registered with the Information Commissioner’s Office under registration number ZA221292.

Chappy has designated a Data Protection Officer and they can be reached by emailing DPO@chappyapp.com or by post at the address above.

1. What information does Chappy process?

Chappy is a meeting place for adults, and we provide that service by operating a social network site offering users the opportunity to connect to our global community of users. By joining Chappy, you enter a legal agreement with us and we process your data in order to provide your service under the terms of that agreement. We suggest you read this in conjunction with our Terms and Conditions of Use.

If you have any questions or comments about this Policy, please feel free to contact us at hello@chappyapp.com.

IF YOU DO NOT WANT YOUR DATA TO BE USED AS EXPLAINED IN THIS PRIVACY POLICY YOU MUST NOT ACCESS OR USE CHAPPY OR OUR SITE.

2. What information does Chappy collect about me?

Account Creation Data

Chappy is a meeting platform for gay men. To access and use Chappy, you will need to create an account (“Account”). You can do this by logging into your Facebook account, which will allow us to receive certain information about you, such as your:

        
  • name;
  •     
  • gender;
  •     
  • photographs;
  •     
  • email address;
  •     
  • date of birth;
  •     
  • Facebook friend list;
  •     
  • work history;
  •     
  • education history;
  •     
  • location; and
  •     
  • the pages that you have “liked” on Facebook.

During the Account creation process, you will be able to select the information that Facebook shares with us, and you can decide not to provide some of the information listed above. There is some basic information that we need to collect from you to make sure that you are not a robot, including your name, photograph, age and gender.

The information we collect about you when you create an Account will be used to create your profile (“Profile”). You also have the opportunity to provide other details about yourself, but these are optional. Your Profile will be available to all users of Chappy. You control your user Profile, and you can edit it at any time by accessing the “Profile” section of Chappy.

Finally, we want to keep in touch with you to make sure you know about the great promotions and offers we have available. If you’ve told us it’s OK, we will use your email address to send you information on these. You can withdraw this consent at any time via Settings in the App.

3. How long will Chappy keep my data?

We keep your personal information only as long as we need it for legitimate business purposes (as set out below) and as permitted by applicable law. To protect the safety and security of our users on and off our services, we implement a safety retention window of three months following account deletion. During this period, account information will be retained although the account will of course not be visible on the services anymore.

In practice, we delete or anonymise your information upon deletion of your account (following the safety retention window), unless:

  1. we must keep it to comply with applicable law (for instance, some “traffic data” is kept for one year to comply with statutory data retention obligations);
  2. we must keep it to evidence our compliance with applicable law (for instance, records of consents to our Terms and Conditions of Use, Privacy Policy and other similar consents are kept for five years);
  3. there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or
  4. the information must be kept for our legitimate business interests, such as fraud prevention and enhancing users’ safety and security. For example, information may need to be kept to prevent a user who was banned for unsafe behaviour or security incidents from opening a new account.

4. What information does Chappy collect about me if I’m under 18?

You can only use Chappy if you are aged 18 or over or the age of majority in the country in which you reside if that happens to be greater than 18. That means we do not knowingly collect any information about children, minors or anyone under the age of majority. Nor do we knowingly market to children, minors or anyone under the age of 18. If you are under 18 years old, we request that you do not upload any photos. If we become aware that a child, minor or anyone under the age of 18 has registered with us and provided us with personal data, or is included in an uploaded photo we will take steps to terminate that person’s registration and delete their Profile information from Chappy. If we do delete an Account because you violated our no children rule, we may retain your email and IP address to ensure that you do not try to get around our rules by creating a new Profile.

5. Who does Chappy share information with?

We may share aggregated information with such parties as Foursquare that includes your personal data (but which doesn’t identify you directly), together with other information including log data with third parties for industry analysis and demographic profiling and to deliver targeted advertising about other products and services.

We share your data with the following categories of third-parties:

        
  • Information technology companies (hardware and software) which provide services to support our products
  •     
  • Fraud prevention and anti-spam providers to protect the service from criminal activity
  •     
  • Moderators to monitor activity on the site/apps and approve content
  •     
  • Advertising partners
  •     
  • Law enforcement agencies, where we are required to by law or to protect the vital interests of a person

We ensure these parties must adhere to strict data protection and confidentiality provisions that are consistent with this Policy. Measures are taken to ensure that the data shared is non-attributable to the greatest extent possible.

In the event that Chappy or any of its affiliates undergoes a business transition or change of ownership, such as a merger, acquisition by another company, re- organisation, or sale of all or a portion of its assets, or in the event of insolvency or administration, we may be required to disclose your personal data.

6. Additional Information

Chappy offers a number of features, and if you choose to use these we may collect additional information about you. This could include information that you send to other users when using Chappy’s chat functions, or when you invite other people to view a user profile or download Chappy.

When you review the profiles of other guys, you will generate certain information such as a list of those you “Like”, “Spark” or “Block”. We store this information to ensure that Chappy remembers your preferences and works efficiently for you.

If you contact our Customer Support team by email or other platforms (such as Facebook), we will receive your email address, and may track your IP address as well as the information you send to us to help resolve your query. We will keep records of our communications with you, including any complaints that we receive from you about other users (and from other users about you).

We encourage you to think about your privacy and safety when using Chappy. We do not recommend that you share information such as your email address, URL, phone number, full name, address, credit card details or other sensitive information which could be abused or misused. Please remember that photographs you upload to Chappy may reveal information about you as well.

Where you do upload and choose to tell us sensitive information about yourself, you are explicitly consenting to our processing of your information and making this public to other users.

When you post information about yourself or use the messaging function, the amount of personal data you share is at your own risk. Please see section 11 below for more information on who can access what you post on Chappy. If you post anything that is inconsistent with our Terms and Conditions of Use, we reserve the right to terminate your Account.

7. Geolocation Information

We want to show you the profiles of guys who are around you. To do this, and to enable other Chappy functions to work, we may collect your device’s geolocation data and save your device’s coordinates, WiFi access points as well as other location information about your longitude and latitude. We may also use your device’s geolocation information to personalise Chappy and make it easier for you to interact with other users. If you have enabled location services but wish to turn them off, you can do so by the following methods:

        
  1. iPhone – settings, location services, off.
  2.     
  3. Android – profile, privacy, on.

Even if you have disabled location settings, we may still determine your city, state, and country location based on your IP address (but not your exact location).

8. Log and Usage Data

Our servers will automatically record information (“Log and Usage Data”) created by your use of Chappy, which again helps us to improve our service. Log and Usage Data may include information such as your IP address, access times and your mobile carrier.

Other actions, such as interactions with Chappy and advertisements, may also be included in Log and Usage Data.

9. Device Information

We may collect information about your device when you use Chappy, including the unique device identifier, device model, operating system, and MAC address.

10. Use of Information

Our main goal is to ensure that your experience on Chappy is an enjoyable one. To provide you with an enjoyable experience, we may use your Account and other information to:

        
  • create and maintain your Account and provide you with access to Chappy;
  •     
  • respond to any customer support queries you submit to us;
  •     
  • offer you services and features;
  •     
  • contact you with information about Chappy (e.g. updates and new offerings);
  •     
  • personalise Chappy and the content we deliver to you;
  •     
  • conduct research and analytics about how you use and interact with Chappy and any related services that we provide to you;
  •     
  • resolve disputes between you and other users;
  •     
  • investigate fraud, protect our legal rights and enforce our Terms and Conditions of Use.

Under EU and UK data protection laws, we are only permitted to use your data when we have a lawful basis to do so. The table below provides an overview of the legal bases that we rely on to use your data. Where the legal basis is consent, you can withdraw consent at any time. Where the legal basis is legitimate interests, you have a right to object to our use of your data. We explain in the relevant sections in this Policy how you can withdraw consent or opt-out of certain data uses (where applicable).

Purpose for which data is used Data Legal basis
To provide you with the Chappy social networking service Name, email address, date of birth, location Contractual necessity
To facilitate networking opportunities on the Chappy site Optional information that you choose to provide in your profile, which may include information about your sexual preferences, religion, ethnic background, photos etc. Consent
To personalise the Chappy service for you Information about your location and your activities on Chappy Legitimate interests – it is in our legitimate interests to tailor the service to your requirements to encourage users to continue using Chappy
To verify your identity and prevent fraud and to ensure the safety and security of Users Phone number Legitimate interests – it is in our legitimate interests to ensure that accounts are not set up fraudulently and to safeguard Users of the site
To serve targeted advertisements to Users of the App Demographic and location information Legitimate interests – it is in our legitimate interests to target advertisements so that users see relevant advertisements and to allow us to generate income from advertising revenue
To send you marketing information about our offers and services Email address and mobile phone number Legitimate interests – it is in our legitimate interests to promote our products and services
To show “nearby” location information to you and other users of the site Wifi access points and location data when you use the App Consent
To serve advertisements through the Chappy mobile app Device ID Legitimate interests – it is in our legitimate interests and the interests of third party advertisers to deliver advertisements to you to promote their products
To carry out research and analysis to help us improve the App Log and usage data, including IP address, browser type, referring domain, pages accessed, mobile carrier and search terms Legitimate interests – it is in our interests to analyse the way in which Users are accessing and using our services so that we can further develop the App and improve the service
To respond to correspondence and queries that you submit to us Email address and IP address Legitimate interests – it is in our legitimate interests to respond to your queries to ensure that we provide a good service to Users and troubleshoot problems
To resolve disputes between you and other App users Email address, messages and profile information Legitimate interests – it is in our legitimate interests to resolve disputes between users quickly and effectively to retain App users and ensure that App terms are being complied with

11. Interacting with other Chappy users

How does Chappy work?

You can use Chappy to find your Cute, Sexy, or both. When you open Chappy, you will be shown the profiles of other Chappy users. You can swipe right on a user’s profile to indicate that you like them, or left if you do not. If you and another guy both swipe right, you will be able to message each other using the chat function.

What information can other Chappy users see about me?

Other Chappy users will be able to see your Profile as a default, including your photographs, age, work and education details, and any information you enter into the “About Me” section. You can add, update or remove information from your Profile at any time through the settings in Chappy.

Who else can see my information?

Other Chappy users may recommend you as a match to their friends on social media by sharing your picture, regardless of whether such friend(s) are also users of Chappy.

When using Chappy, you should assume that anything you post or submit may be publicly viewable and accessible, both by users of Chappy and non-users. Before you post this information, be aware that this content may be searchable by search engines.

12. Cookies and similar technologies

We collect information by placing cookies on your mobile. A cookie is a piece of text stored on your mobile by your web browser. They are basically a tool that stores information about website visits, recognises you and your preferences each time you visit Chappy, and ensures site functionality and enables us to provide the services our members request.

When you visit the publicly available sections of Chappy, a session ID cookie is placed on your mobile that only lasts while you’re visiting. We also place persistent cookies (also known as local storage devices) on members’ mobiles, so that Chappy remembers them and makes their login experience faster and easier. We may use persistent tracking cookies on your mobile device, mainly for security protection purposes, such as to prevent phishers, scammers, unauthorised log in attempts, and to help you access your hacked account. We do not use any information whilst you are logged off.

You may set your browser and your mobile settings to block cookies and local storage devices, but if you do so, you may not be able to access the features that Chappy offers

Chappy’s use of cookies and local storage devices basically falls into the following categories:

        
  • those that are strictly necessary to deliver the services and products you have requested
  •     
  • cookies related to the performance of Chappy’s App, such as analytics that help us determine how our App is performing and ensuring a smooth and trouble free experience for our members and visitors;
  •     
  • cookies related to the functionality of Chappy’s App, such as remembering your preferences at log in or your preferred language or allowing you to chat, add photos and instant message Chappy members;
  •     
  • third party cookies which link to other social networks and which you request via social plugins; and
  •     
  • cookies used to improve and target advertising to you based on what’s relevant to you, to improve reporting on any advertising campaign and to avoid showing you ads you have already seen.

We use the following types of cookies:

Cookie Functions Cookie Purpose

Analytics and research

We use Google Analytics to collect information about how visitors use the App. We use the information to compile reports and to help us improve the App. The cookies collect information in an anonymous form, including the number of visitors to the App, where visitors have come from and the pages they visited. For more information about Google's Privacy Policy, please visit http://www.google.com/intl/en/policies/.

Authentication

These cookies help us identify our Users so that when you're logged in you can enjoy our offerings, experiences and various features, such as uploading photographs and chatting. You can even localise your experience, such as when you've requested to view the App in your local language or when you ask Chappy to 'remember me'. These cookies also help us to remember who invited you to join Chappy. We also use cookies and other web technologies, such as CAPTCHAs, to help keep Chappy and our members safe and secure.

Security and site integrity  

We may use persistent cookies, which will help us to ensure we have identified the same device is logging into the correct account. These cookies help us combat the bad guys - they help with our anti-spam measures and may help us to prevent phishers, scammers, unauthorised log-in attempts to your Account and accessing any hacked accounts.

Site features and services 

These cookies and local storage devices provide functionality such as uploading photographs, chat, instant messaging, and using your Account settings. They also help provide experiences, such as links to other social media sites, social plugins and video content, including making it easier for you to share content between Chappy and your other favourite social networks. In some cases, we may allow a third party to place cookies or save data to your local storage devices on your mobile device – this is where Chappy’s Privacy Policy ends and theirs begin. The third party who places cookies on your device is responsible for how they process their data so you should read their privacy policies and make sure you're okay with them before you start sharing. Examples of such policies are available at the following links:

Twitter: https://twitter.com/privacy
Facebook: https://www.facebook.com/policy.php
YouTube: http://www.google.co.uk/intl/en/policies/privacy/
AddThis: http://www.addthis.com/privacy

Performance

We need to use certain cookies and save data to your local storage devices to ensure our members have the best possible experience. They assist with your navigation of our App, ensuring pages load quickly and respond promptly to your requests – no one likes snail pace technology!

Our use of cookies and local storage devices, including the specific cookie names, may change over time, but will generally fall into the above categories. Please visit this page regularly so that you are aware of any changes.

We use pixels or other tracking methods to track the actions of our users across platforms. This allows us to optimise our services and measure the efficiency of advertising campaigns. The data we receive through the use of pixels is anonymous, Facebook stores the data and may be able to connect this data to your Facebook account for advertising purposes. If you would like to opt out of the use of pixels please visit https://www.facebook.com/ads/website_custom_audiences/.

If you would like to know more about cookies and similar technologies, including flash cookies/local storage devices, the following websites provide useful information:

13. Data storage

The data that we collect from you may be stored in the European Union as well as being transferred to, and stored at, a destination outside the European Economic Area ("EEA") such as the United States. It will also be processed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

14. Security

We take commercially reasonable security measures to help protect your information against loss, misuse and unauthorised access or disclosure. We use reasonable security measures to safeguard the confidentiality of your personal data such as secured servers using firewalls.

Unfortunately no website or Internet transmission is ever 100% secure and even we cannot guarantee that access, hacking, data loss or other breaches will never occur, but here are some handy tips to keep your data secure:

        
  1. Please make sure you log out of your Account after use.
  2.     
  3. Please don’t share your social media password with anyone else.
  4.     
  5. Change your social media password periodically.

If you ever think someone has had access to your social media password, report it to the relevant platform and change your password immediately. We cannot guarantee the security of your personal data while it is being transmitted to our site and any transmission is at your own risk.

15. Your rights

Under UK and EU law, you have the right to lodge a complaint with data protection regulators. Chappy has its main office in the UK and the Information Commissioners’ Office (ICO) is our lead regulator. You can find out how to raise a concern with the ICO by visiting their website at www.ico.org.uk. If you’re within the EU, you may also get in touch with your local Data Protection Regulator who may liaise with the ICO on your behalf.

You have a number of rights under European Data Protection law if you are an EU citizen.

        
  • Right to be informed: what personal data an organisation is processing and why (this notice).
  •     
  • Right of access: you can request a copy of your data.
  •     
  • Right of rectification: if the data held is inaccurate, you have the right to have it corrected.
  •     
  • Right to erasure: you have the right to have your data deleted in certain circumstances.
  •     
  • Right to restrict processing: in limited circumstances, you have the right to request that processing is stopped but the data retained.
  •     
  • Right to data portability: you can request a copy of your data in a machine-readable form that can be transferred to another provider.
  •     
  • Right to object: in certain circumstances (including where data is processed on the basis of legitimate interests or for the purposes of marketing) you may object to that processing.
  •     
  • Rights related to automated decision making including profiling: there are several rights in this area where processing carried out on a solely automated basis results in a decision which has legal or significant effects for the individual. In these circumstances your rights include the right to ensure that there is human intervention in the decision-making process.     

If you want to exercise any of your rights listed above please visit Feedback Page or email us at DPO@chappyapp.com

How does Chappy protect my personal data?

Chappy has implemented appropriate security measures to protect and prevent the loss, misuse, and alteration of the information under our control, including your personal data. Our technical experts at Chappy work hard to ensure your secure use of our site.

While we take reasonable precautions against possible security breaches of our App, member database and records no website or internet transmission is completely secure and we cannot guarantee that unauthorised access, hacking, data loss, or other breaches will never occur. We urge you to take steps to keep your personal data safe (including your password) and to log out of your account after use. If you lose your password or give it out, or another service provider that you use suffers a data breach and you have used the same credentials with that service provider as you have with Chappy, your personal data may be compromised. If that happens, please report it to Support via Feedback page.

16. Where is my personal data kept?

We want you to be able to access Chappy wherever you happen to be in the world. To enable us to provide that service, we operate a global network of servers including in the US, Hong Kong, Czech Republic and Russia. The hardware is located in third-party data centres but is owned by Chappy Group Companies. Data collected by advertising partners may also be held outside the European Economic Area. We ensure that the data is adequately protected by ensuring that valid, legal mechanisms are in place such as: EU approved model clauses (which can be found here), US privacy shield certification (more information can be found here); and implementing robust contractual standards. If you want more information relating to the nature of the safeguards we have in place please email DPO@chappyapp.com.

17. Does Chappy collect any other personal data about me?

If you contact our Customer Support team via Feedback page, we will receive your email address, and may track your IP address, as well as the information you send to us to help resolve your query. We will keep records of our communications with you, including any complaints that we receive from you about other users (and from other users about you) for 6 years after deletion of your account.

18. Changing your Profile

You can review and revise your Profile at any time. Once you register, you will be able to review and change your personal data including:

        
  • Your photos;
  •     
  • Your “About Me” information;
  •     
  • Your occupation;
  •     
  • Your education.

19. Deleting your Account

You can delete your Account at any time by going into the “Settings” section of Chappy and clicking the “Delete Account” link.

To prevent abuse and/or misuse of Chappy by a user following termination or deletion of a Profile/Account, we shall retain such information as we deem in our sole discretion may be necessary to ensure that the user does not open a new account and profile in breach of our Terms and Conditions of Use and to ensure compliance with all laws and regulations.

Warning: Even after you remove information from your Profile or delete your Account, copies of that information may still be viewable and/or accessed on the Internet to the extent such information has been previously shared with others, or copied or stored by other users. We cannot control this, nor do we accept any liability for this.

20. Your rights of erasure, rectification and access

You may have the right to request that we provide you with information about your stored personal data, including its origin, any recipients or categories of recipients of your personal data, as well as the purpose of storage. You may also revoke your consent to processing of your personal data, request that inaccuracies are corrected, or request its deletion. In order to make a request, please contact us at hello@chappyapp.com. We will process all requests we receive in line with any local laws and our policies and procedures.

21. Changes to this Policy

We may make changes to Chappy from time to time (such as by adding new features or addressing security issues) or there may be changes in law or best practice which require changes to this Policy. We therefore reserve the right to modify, amend or change this Policy at any time and without prior notice when the change is related to legal or regulatory changes, reflects technological advancements, or is designed to clarify them, but in each case where we don’t actually change our practices as set out in this Policy. Where we make a material change to these Terms, we will notify you either via email or in-App notification. Where you do not agree to the changes, you should delete your account.

You can always access the current version of the Policy at https://chappyapp.com/privacy.

Effective Date: 11 October 2018