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.
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 email@example.com.
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:
If you log into or access Chappy through your Facebook profile, you may appear on your friends’ Facebook apps as a Chappy user. Remember also to log off Facebook when you leave a device in order to prevent other users from accessing your account.
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.
For users who are California residents, the data we may collect falls within the following categories of “personal information,” as defined by the California Consumer Privacy Act (CCPA):
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.
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.
In practice, we delete or anonymise your information upon deletion of your account (following the safety retention window), unless:
Where Chappy uses machine learning, for example, to help us detect and prevent spam communications on the App (as explained further below), we may need to keep personal information for a longer period than the retention periods explained above, to enable the machine learning to work properly. Where this is the case, we always seek to minimise the amount of personal information that is used and we ensure that it is ring-fenced and kept securely from other user personal information. We regularly review the period for which personal information is required for machine learning purposes and delete any identifiable information when it is no longer required.
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.
We may share aggregated information with third parties 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:
|Third party||Disclosed data|
|Information technology companies (hardware and software) which provide services to support our products||This could include all data, including all CCPA Categories listed above|
|Fraud prevention and anti-spam providers to protect the service from criminal activity||Transaction and payment data (CCPA Categories B and D)|
|Moderators to monitor activity on the site/apps and approve content||Name and user registration details, profile information, content of messages and photographs (CCPA Categories A, B, C, E, and H)|
|Advertising partners||Device ID, geolocation data, demographic data (CCPA Categories C, F, and G)|
|Law enforcement agencies, where we are required to by law or to protect the vital interests of a person||This could include any personal data that Chappy holds about you, depending on the nature of the request or the issue that we are dealing with, including all CCPA Categories listed above|
|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 to a purchaser of all or part of the business or to an insolvency practitioner||This could include all personal data that Chappy holds about you, including all CCPA Categories listed above|
|Your data may be shared with other Chappy group companies, for example, to block accounts and suspected fraudulent payment transactions as part of our anti- spam and anti-fraud procedures||This could include CCPA Categories A, B, D and F.|
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.
Chappy does not sell your data and has not sold your personal data in the previous 12 months.
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. It is also your responsibility to ensure that your account details are kept up to date. If, for example, you provide your phone number and your phone number changes, please ensure that you update this in your account.
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.
To prevent abuse of the app/site, Chappy uses automated decisions to block accounts as part of its anti-spam procedures. In order to do this, our systems check accounts and messages for content that indicates breaches of our Terms and Conditions of Use. If an account or message meets certain criteria that demonstrate that the Terms and Conditions of Use are likely to have been breached, the relevant account will automatically be blocked. All users of accounts that have been blocked will be notified that their account has been blocked and affected users can contact Chappy to contest the decision.
Please note that if your account is blocked, any account(s) that you have on our other group platforms/applications may also be blocked as part of our anti-spam and anti-fraud procedures.
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:
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).
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.
We may collect information about your device when you use Chappy, including the unique device identifier, device model, operating system, and MAC address.
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:
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||Source||Legal basis|
|To provide you with the Chappy social networking service||Name, email address, date of birth, location (CCPA Categories A and B)||You provide your name, email address and date of birth to us. We obtain location data from the device that you use to access the service||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. (CCPA Categories C, H, I, J)||You provide this information to us||Consent|
|To personalise the Chappy service for you||Information about your location and your activities on Chappy (CCPA Categories A and G)||We obtain location data from the device that you use to access the service||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 (CCPA Category B)||You provide this information to us||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 (CCPA Categories A, C and G)||We obtain demographic data from you, and location data from the device that you use to access the service||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 (CCPA Category B)||You provide this information to us||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 (CCPA Category G)||We obtain this information from the device that you use to access the service||Legitimate interests – it is in our legitimate interests to provide this functionality as part of the services|
|To serve advertisements through the Chappy mobile app||Device ID (CCPA Category F)||We obtain this information from the device that you use to access the service||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 (CCPA Category F)||We obtain this information from your interaction with our service||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 (CCPA Categories B and F)||You provide your email address to us when you contact us and we obtain your IP address from the device that you use to contact us||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 (CCPA Categories A, B, C, I and J)||You provide this information to us||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|
|To block accounts as part of our anti-spam procedures||Email address, phone number, IP address and IP session information, social network ID, username, user agent string (CCPA Categories B and F)||You provide your email address, phone number and username to us. We obtain the other information from the device that you use to access the service||Legitimate interests – it is in our legitimate interests to prevent unauthorised behaviour and to maintain the safety and security of our services|
You can use Chappy to find someone to date or to just make friends with. 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.
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.
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.
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
We use the following types of cookies:
|Cookie Functions||Cookie Purpose|
Analytics and research
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 login attempts to your Account and accessing any hacked accounts.
Site features and services
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!
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:
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.
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:
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.
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 as detailed below. These rights apply to all of our user.
For users who are California residents, you also have the following rights (in addition to those listed above) under the California Consumer Privacy Act, and you have the right to be free from unlawful discrimination for exercising your rights under the Act:
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 our Feedback page.
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 – please note that Chappy is not Privacy Shield certified but we may pass information to third party service providers or advertising partners who are based in the US and who are Privacy Shield certified); 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.
If you contact our Customer Support team via our 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.
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:
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.
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 firstname.lastname@example.org. We will process all requests we receive in line with any local laws and our policies and procedures.
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: 18 February 2020