Soul to Soul

Privacy Policy

Effective from: 24 October 2024

Summary

Your privacy and security is very important to us. The following summary outlines key points regarding your data and how we use it. Please note, you may only use the service if you agree to be bound by the full Privacy Policy (shown below) and our Terms of Use.

Who are we?

The service is run by Dating Lab Limited ("DL"). Please see the service's Terms of Use for our full corporate details.

Who will process my data?

DL will process your data.

On what legal basis do you process my data?

Your data will be processed on the basis of the consents you give us when you join the service.

Data provided by you about third parties will be processed on the basis of Legitimate Interest.

What type of data do we collect from you?

We collect information you voluntarily provide to us. We also keep details of any customer support queries you may have, as well as your visits to our services including IP addresses, web logs of your activities and messages you send.

How will my data be used?

DL uses your data solely to enable us to provide the service.

Your data will never be passed on or sold to any third parties unless you explicitly grant such consent.

Third party data provided by you as part of the 'Tell a Friend' or 'Recommendation' features will only be used for the provision of those features.

How long will my data be kept?

We will keep your personal data until you or we delete your profile. Once deleted, it will be archived for a further 3 years and then permanently erased. Please see section 8 below for more details on data retention and deletion.

Security

DL actively works to protect the security of your personal data. In addition to the security we apply to our core systems, your data is encrypted during transmission over the Internet. To further ensure your privacy your password is not stored in plaintext. Your password is hashed using a one-way hashing algorithm which means it cannot be recovered (or disclosed) by anyone, including ourselves, it can only be reset.

To protect the confidentiality of your personal data, you must keep your password confidential at all times.

Full Privacy Policy

1. Information collected

We collect information you voluntarily provide to us when you create and complete your profile, including personally identifiable information such as your name and email address. This information is stored on our systems, but no personal contact information is ever displayed in your public profile or included in any communication we may send to other members.

If you choose to pay for the Services by card you will be required to provide additional information related to your payment card details. This information will be passed to our payment provider via a secure link and at no point will your card number be known to, or retained by us.

We also keep details of your visits to our service including, but not limited to IP addresses, web logs of your activities, other connection information including the URL of any service from which you clicked through to the service. We also keep details of any messages you send and receive through the services as well as records of your member support queries and correspondence, in the event you contact us. In common with most Internet based services, we also use make use of small files we store on your device called cookies. Further information relating to our use of cookies can be found in section 7 below.

All of this data is referred to as personal data.

2. Legal basis

Personal data is processed on the basis of one or more of the following:

• The consent you give us when you join the service. If you wish to withdraw that consent, please delete your profile as we are unable to provide the service without your ongoing agreement.
• If you provide us with personal data about a third party (for example when using the 'Tell a Friend' or 'Recommendation' features), you warrant that you have obtained the express consent from the third party for the disclosure and use of their personal data. We will then process their data on the basis of Legitimate Interest and guarantee that we will only use it to provide the service requested by you.
• If you contravene our Terms of Use, then we additionally reserve the right to process your personal data on the basis of Legitimate Interest, to help prevent or detect fraud and to help us protect other members.

3. Control and disclosure of your personal data

When you sign up for the Services you agree that DL may disclose your data (including personal data) in accordance with any consents you may actively give.

Except as otherwise stated in this Privacy Policy or as you separately and expressly agree (by ticking a box or by some other similar means of giving your consent), DL will be the sole controllers of any personal data you provide to us while using the Services.

DL is registered under the Data Protection (Jersey) Law 2018 as data controller and will comply with that Law in their dealings with your personal data.

Unless you give us your express consent to do so (by ticking a box or otherwise) neither we nor anyone else to whom we do pass your personal data with your agreement will:

• disclose any of your information without your permission.
• sell or rent or give your information to any third party (other than to our service providers or agents for processing or storage on our behalf as described in section 4 below).
• disclose your information at all unless we are required to do so by law or regulation.

4. How do we use personal and other data?

By providing us with your personal data and agreeing to the Terms of Use and this Privacy Policy you are giving your consent:

• for us to process your personal data (including any sensitive personal data such as your sexual orientation) for the purposes of providing the Services and for any other purposes which you have given your express consent to; and
• to the transfer and processing of your information in countries outside the European Economic Area which may not provide the same level of data protection as the UK. If we do make such a transfer or if your personal information will be processed outside the European Economic Area, we will put a contract in place to ensure your information is protected or where applicable covered by the US 'Privacy Shield Program'.

We may also use your information to help us to analyse use of the service and the Services and to improve the Services and their content or to troubleshoot problems and implement the Terms.

Your personal data will only be processed by authorised staff members (or by such third parties as we may use from time to time to store and process data for us).

5. Updating your information

You should keep the information about you on the service up to date. You can update all of your personal information including username, email address, location, password, consents and all profile details at any time by clicking here.

6. Your password

You can only access your account information and our service through the use of your username and password. To protect the confidentiality of your personal data, you must keep your password confidential and not disclose it to any other person. As it is not stored in plaintext, your password is hashed using a one-way hashing algorithm which means it cannot be recovered (or disclosed) by anyone, including ourselves, it can only be reset. Please notify us immediately if you believe your password has been misused.

Please note, we will never ask you to disclose your password.

7. Cookies and IP Addresses

When you visit the service, we may send you a cookie. A cookie is a small file that can be placed on your computer's hard disk for record keeping purposes and we may use them to do a number of things:

• Cookies help us to recognise you when you next visit the service and note any advertisements displayed to you. This allows us to tailor the advertisements we provide to your preferences. We may use the services of third party ad servers for this purpose.
• Cookies may be used to compile anonymous statistics related to the take up or use of services, or to patterns of browsing. A third party collects such data on our behalf to measure the performance of our services. Information collected is aggregated for reporting purposes. No personally identifiable information is collected by this service. The use of this service assists us in measuring and improving the structure and ease of use of our services.
• We may also track IP addresses. An IP Address is a number that can identify an Internet Service Provider, country location etc. It cannot provide personal information. We will not use the IP Address to build a profile on users, we only use the information for demographic, statistical and security purposes.

Cookies cannot be used by themselves to identify you. You are not obliged to accept cookies and may modify your browser so that it will not accept cookies. If you configure your browser to reject cookies, you may still use some, but not all, portions of the service. For example, the login process and all member functionality requires your browser to accept cookies.

If you would like to disable "third party" cookies generated by advertisers, providers of targeted advertising or behavioural analysis services, you can turn them off by going to the third party's service and getting them to generate a one-time "no thanks" cookie that will stop any further cookies being written to your machine. Here is a link to the main service analytics platform that we use where you will find instructions on how to do this:

www.google.com/intl/en/policies/technologies/ads

You can also visit the trade body representing the advertising companies for more information on how to opt out of all such cookies:

www.youronlinechoices.com

8. Data retention and deletion

Provided you have been a member for 30 days or more, you have the option to hide your profile at any time, which will withdraw it from public view in connection with the Services. You can also permanently delete your profile whenever you wish, as described below.

As long as you are a Member or Subscriber (i.e. your profile has not been deleted either by you or by us), it is your responsibility to either delete your profile or ask us to do so when you no longer wish to use the Services. If we can no longer contact you via the email address you have given us, then we reserve the right to delete your profile without further warning. Additionally, if you do not log in to your profile for 7 years, we will assume you no longer wish to use the service and it will be deleted.

Please note, we will retain your personal data (together with any third-party data you provide under the 'Recommendation' feature) until your profile has been deleted. It will then be archived (including any photographs you may have uploaded) for a period of 3 years from the deletion date, at which time it will be erased.

Personal data provided as part of the 'Tell a Friend' feature will be retained for a maximum of 12 months. It will never be used for any other purposes, nor will it be shared with or provided to any third parties unless we are required by law to do so.

Personal correspondence sent to other members through the service will be archived for a maximum of 12 months from the date sent, then erased.

To enable us to respond to any queries or complaints you may subsequently have, any correspondence or member support enquiries sent through the in-built member support system will be kept for a maximum of 5 years from the date the support thread is closed.

If your profile has been deleted because you have contravened our Terms of Use, we reserve the right to keep some or all of your personal data for up to 10 years from the date of deletion, in order to help protect other members, prevent fraud and to enable us to assist the Police or other law enforcement authorities if legally required to do so.

How do I delete my profile?

Go to the My Account page of your profile, click the 'Delete My Profile' link at the bottom of the page. NB: If you are a subscriber and have time left on your subscription, it will be deleted with your records and will only be refunded in accordance with our Refund Policy. If you are not sure about this, we recommend that you simply hide your profile.

9. No Spam policy

We will not send you spam emails.

While you are a Member or Subscriber, you will receive essential service related emails from us and you may receive emails via the service from other members. You can control most of these emails via the settings page on your profile, however if you want to opt out of all service emails from us, then you must delete your profile.

Unless you expressly agree that we may do so, we will never supply, sell or rent your email address to any third party.

Our service includes 'tell a friend' and 'Recommendation' features. Your friends will never receive unsolicited email from us. Once a 'tell a friend' email is sent, they will not hear from us again unless they choose to become Members themselves. You may not use the 'tell a friend' services to send spam. If you use the 'Recommendation' feature, then your friend will only receive an email from us if you instruct us to do so, for example by clicking the 'Send reminder' button.

10. Network Sharing

DL operates a network of services. Profiles may be shared across this network with similar services. Therefore as well as seeing profiles from the service you join, you may also be able to see profiles from some of our other services and vice versa. For a complete list of the services that your profile may appear on, please see our Network Services page.

11. Signing up with Social Network Accounts

We provide a quick and easy method for members to join or log in with a social network accounts, e.g. Facebook. This is for the sole purpose of speeding up the join process and no references will be posted to your social network account or timeline. Refer to the 'Social Network Sharing' section for occasions where you may give permission to post updates on your social network account or timeline.

12. Social Network sharing

Our members and service visitors have the option to share a profile they like with their friends on social networks such as Facebook, X (Twitter), etc. We will never disclose any personal details supplied by members that are not publicly displayed on the member's profile.

13. Security

DL is committed to protecting the security of your personal data. However, while we take reasonable precautions to guard the personal data we collect, no security system is impenetrable.

We have a number of precautionary measures in place to help prevent information about you from loss, theft, misuse and unauthorised access, disclosure, alteration and destruction. For example, we store the personal data you provide on computer systems that have limited access and that are in controlled facilities. We also ensure that our third-party data centre vendors provide adequate security measures. Additionally, your data is protected with encryption, such as Transport Layer Security (TLS), during transit over the Internet.

In the event a security breach, we are legally obliged to notify the authorities within 72 hours and would endeavour to react as fast as possible to resolve the problem. We cannot however accept responsibility for Member details that are lost or compromised in the event of a security breach.

14. Your rights

You have the right to object to our use of your personal data, or ask us to erase, remove or stop using it if there is no need for us to keep it. This is known as your right to be forgotten.

Your data will normally be erased in accordance with our data retention and deletion clause as stated above. If you want us to delete it in advance of our normal timescales, then please contact our support team. However, if you have contravened our Terms of Use, then we reserve the right to retain and process your data on the basis of legitimate interest in order to help us protect other members by assisting us with the prevention & detection of fraud and other illegal activities.

You can view, edit or delete your personal data by editing your profile. You also have the right to ask us not to process your personal data for marketing purposes by ticking the relevant boxes on the settings page of your profile.