CUPID MEDIA PTY LTD PRIVACY POLICY

Last Updated: 24 September 2014

1. Preliminary

PinkCupid.com (the "Website") is owned and operated by Cupid Media Pty Ltd ACN 104 844 564, an Australian registered company ("Cupid Media", "we", "our", "us").

Our contact details are:

Name: Cupid Media Pty Ltd (ACN 104 844 564)
Address: PO Box 9304, Gold Coast MC Qld 9726
Phone: 61 7 5571 1181
Fax Number: 61 7 3103 4000
For Privacy Issues Email: privacy@cupidmedia.com
For Customer Service: team@PinkCupid.com

This privacy policy sets out Cupid Media's policies relating to the collection and use of your Personal Information whilst you use the Website and Cupid Media's related websites.

Cupid Media is committed to protecting user privacy. We understand that visitors and users of the Website are concerned about their privacy, and the confidentiality and security of any Personal Information that is provided.

We will only disclose Personal Information in accordance with the Privacy Act 1988 (Cth) (or other applicable law), the Australian Privacy Principles and this privacy policy. If there is any inconsistency, the Privacy Act 1988 (Cth) (or other applicable law) will prevail to the extent of any inconsistency.

Words that are capitalised, such as "Personal Information" and "Sensitive Information" are defined in clause 15 of this policy.

2. Anonymity

Due to the nature of the services provided by Cupid Media it is impractical for us to deal with you without knowing your full name. When you register for our services you are required to use truthful and accurate information and you will not have the option to use a pseudonym.

3. Collection of Information

3.1 All Users

Whenever users (including non-member users) visit the Website, our servers automatically record information for statistical purposes about your usage of the Website such as:

(a) the type of browser used;
(b) the referring URL;
(c) the IP address;
(d) the number and type of pages viewed;
(e) the date and time of visits; and
(f) the exit URL.

This information we collect about you is not Personal Information and, in any event, remains anonymous. We do not link the anonymous information to any other Personal Information unless you have either registered as a member or logged on as a member at the time of use. Accordingly, if you have not identified yourself on the Website, such as by registering as a member or logging on as a member, we will not link a record of your usage of our Website to you personally.

3.2 Members

Upon your registration as a member we collect information about you in order to provide you with the full benefits of membership. We collect non-identifying information as well as Personal Information from you directly when you first register and also from time to time thereafter if you provide us with additional information. Personal Information which may be collected by Cupid Media includes, without limitation:

(a) your full name;
(b) your email address;
(c) your residential address;
(d) phone number;
(e) a photograph of you;
(f) your credit card and billing information (if provided by you).

Other information collected by the Cupid Media, which may or may not be considered Personal Information includes, without limitation:

(a) your email address;
(b) your age;
(c) your occupation;
(d) a description of your appearance.

Sensitive Information which may be collected by Cupid Media includes, without limitation:

(e) your racial or ethnic origin;
(f) your political opinions;
(g) your religious beliefs or affiliations;
(h) your philosophical beliefs;
(i) your sexual preferences or practices;
(j) your criminal record and is only collected if you elect to provide that information to us.

3.3 Cookies

To improve your experience on our site, we may use 'cookies'. Cookies are an industry standard and most major web sites use them. A cookie is a small text file that our site may place on your computer as a tool to remember your preferences.

You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website.

Our website uses Cookies to support Google Analytics for:

(a) DoubleClick Platform integrations.
(b) Demographic and Interest Reporting.
(c) Display Advertising including Remarketing and Google Display Network Impression Reporting to advertise our services online.
(d) Optimizing and personalizing ad service based on your past visits to our website.
(e) Reporting the use of ad services, and interactions with ad impressions and how they are related to visits to our site.

You can customize or opt out of Google Analytics for Display Advertising using the Ads Settings for your Google account.

3.4 Third Parties

We may allow third-parties, including authorised service providers, advertising companies, data management platforms and ad networks to serve advertisements on our sites. Any information that these third-parties collect via cookies is completely anonymous and is non-identifiable.

You may refuse the use of third party data collection by selecting the appropriate settings on your browser or by using the Online Choices Opt-Out Tool provided at this link.

3.5 Use of Google Analytics

Our website uses Google Analytics, a service which transmits website traffic data to Google servers in the United States. Google Analytics does not identify individual users or associate your IP address with any other data held by Google. We use reports provided by Google Analytics to help us understand website traffic and webpage usage. Please be advised that to avoid personal data being collected through IP addresses, we use Google Analytics ad-on "anonymized".

By using this website you are deemed to have expressly consented to the use and processing of your data by Google in the manner described in Google's Privacy Policy and for the purposes set out in Clause 3.3. You can opt out of Google Analytics if you disable or refuse the cookie, disable JavaScript, or use the opt-out service provided by Google.

Cupid Media also uses interfaces with social media sites such as Facebook, LinkedIn, Twitter and others. If you choose to "like" or “share” information from this website through these services, you should review the privacy policy of that service. If you are a member of a social media site, the interfaces may allow the social media site to connect your visits to this site with other Personal Information.

3.6 Promotion to you

(a) In order to promote our products and services to you, we may provide a hash of your email address (and no other personal data) to third parties such as Facebook in order to better target our advertising to you by using products such as Facebook's Custom Audiences.

(b) A comparison of your hashed email address will only be for the purpose of promoting our goods and services to you, and will not be used by that third party for any other purpose. The comparison of the hash of your email address will not be used to identify you or your email address, and no further information about you will be provided by us to that third party.

4. Purposes of collecting, holding, using and disclosing Personal Information

4.1 Collect from you only

Where it is reasonable or practical to do so, we will endeavour to only collect Personal Information about you from you.

4.2 Purposes of collecting Personal Information

(a) We will only collect Personal Information that is reasonably necessary for:

(i) enabling us to process your application for membership and enabling us to provide services to you (including creating your publically viewable profile, allowing members to search for suitable members, providing mechanisms for communication between members);
(ii) our internal research and statistical purposes (including market segmentation and customer value analysis);
(iii) enabling us to forward to you other information or material which we believe may be of interest to you; and
(iv) enabling the payment processor to process the payment of subscription fees,(the "Primary Purpose").
(v) any other purpose specified in our Website Terms of Use located at http://www.PinkCupid.com/en/general/termsofuse

4.3 Holding of Personal Information

(a) Security

We will take reasonable steps to protect Personal Information that we hold from:

(i) misuse, interference and loss; and
(ii) unauthorised access, modification or disclosure.

(b) Destruction of Personal Information

If:

(i) We hold Personal Information about you; and
(ii) We no longer need the Personal Information for any purpose for which the information may be used or disclosed by us under the Privacy Act 1988 (Cth) or other applicable law; and
(iii) We are not required by or under an Australian law, other applicable law or a court/tribunal order, to retain the information,
We will take reasonable steps in the circumstances to destroy the information or to ensure that the information is de identified.

4.4 Use and disclosure of Personal Information

(a) We will only use or disclose Personal Information for the Primary Purpose where it is reasonably necessary.
(b) We will not use or disclose any Personal Information about you for any purpose other than the Primary Purpose (the "Secondary Purpose") unless:

(i) both of the following apply:

(A) the Secondary Purpose is related to the Primary Purpose and if the Personal Information is Sensitive Information, the Secondary Purpose is directly related to the Primary Purpose; and
(B) you would reasonably expect us to use or disclose the Personal Information for the Secondary Purpose; or
(ii) you have consented to the use or disclosure; or
(iii) The use or disclosure of the Personal Information is required or authorised by or under an Australian law, other applicable law or a court/tribunal order.

4.5 Disclosure to overseas recipients

Any profile information that you have provided to us will be publically viewable on your profile, irrespective of the location of the viewer. By creating a profile you acknowledge that overseas recipients will be able to view your profile.

In order to provide customer support, perform back office functions, fraud prevention tasks or provide services to you we may need to allow our staff or suppliers (who are located or whose resources are located Overseas) to access your profile information, billing information or other personal information that you have supplied.

In all other circumstances we will only disclose Personal Information to an Overseas recipient if:

(a) you consent to the transfer (please note the consent you have given in clause 12 of our terms of use); or
(b) the disclosure of the information is required or authorised by or under an Australian law, other applicable law or a court/tribunal order.

4.6 Unsolicited Information

If we collect Personal Information, which we have not sought or requested, and if we determined that we are otherwise permitted to collect that information in compliance with the Australian Privacy Principles or other applicable law, that information will be dealt with in accordance with the terms of this privacy policy. If however, we determine that the collection of your Personal Information is not permitted under the terms of the Australian Privacy Principles or other applicable law, then we will destroy or de-identify that Information as soon as practicable, where it is lawful and reasonable to do so.

4.7 Information Not Confidential

You agree that any material or information provided by you, save and except for any Personal Information (which may include your full name, postal address, telephone number etc.) the use of which is governed by this Privacy Policy, will be treated as non-confidential and non-proprietary and we may use such material or information without restriction. Specifically, you consent to Cupid Media using such material or information (including any profile information, photographs, video or audio recordings) that you have provided to us) in order to copy your profile into any other relevant dating site owned and operated by Cupid Media. You acknowledge that any such material or information provided by you will be available for other members or users of the Website to read.

4.8 Communication

The Company reserves the right to send electronic mail to you regarding recommended matches, notification alerts of activity such as interest alerts or email alerts, for promotions or offers, changes or additions to the Service, or any products and services of the Company and its affiliated businesses. Members may manage their email preferences by using the "Settings / Notifications" function to customize what type of email communications they wish to receive.

5. Access and Correction

5.1 Access to Personal Information

We will provide you with access to the Personal Information held by us in relation to you except to the extent that:
(a) giving access would be unlawful; or
(b) denying access is required or authorised by or under an Australian law, other applicable law or a court/tribunal order.

5.2 Request for Access

To request access to the Personal Information held by us about you, you must contact us using the contact details provided in clause 1, following which we will contact you within a reasonable time from our receipt of your request and either provide you with that Personal Information, or notify you when we will provide you with the Personal Information. In any event the Personal Information requested will be provided not more than 30 days after our receipt of your request unless we decide not to provide you with access to the Personal Information in which case we will advise you of the reasons for such decision.

5.3 Commercially Sensitive Information

Where providing access to the Personal Information would reveal evaluative information generated by us in connection with a commercially sensitive decision making process we will give you an explanation for the commercially sensitive decision rather than direct access to the Personal Information.

5.4 Use of Intermediaries

Where because of any of the reasons described in 5.1 above we are not required to provide you with access to the Information then we will, if it is reasonable to do so, give consideration to whether the use of mutually agreed intermediaries would allow sufficient access to meet our respective needs.

5.5 Costs

We reserve the right to charge you for providing access to your Personal Information. Those fees and charges will not be excessive, and will be determined by us from time to time and we will notify you of those costs prior to providing you with access to the Personal Information. We may require those costs to be paid prior to providing you with access.

5.6 Correction of Personal Information

(a) It is your responsibility to ensure that the information you provide to us is accurate and to update your Personal Information as necessary.

(b) If at any time you wish to correct any Personal Information held by us, please contact us as specified in clause 1 and we will correct this record, having regard to the purpose for which it is held, to ensure that the information is accurate, up to date, complete, relevant and not misleading. If we elect not to correct your information, we will notify you, within a reasonable time, of the reason for our refusal, the mechanisms available for you to complain about our refusal and such other matters as required by the Privacy Act 1988 (Cth) or other applicable law.

(c) If:

(i) we correct Personal Information about you that we previously disclosed to another entity to which the Australian Privacy Principles apply; and
(ii) you request us to notify that other entity of the correction, we will take reasonable steps in the circumstances to give that notification unless it is impracticable or unlawful to do so.

(d) If we are not satisfied that the Personal Information is not accurate, complete or up to date, we will, at your request, keep with your Personal Information a statement noting your claim that the Personal Information is not accurate, complete or up to date.

(e) If you wish to have your Personal Information deleted, please let us know and we will take all reasonable steps to delete it, unless we need to keep it for legal reasons.

5.7 Refusal to Correct

If at any time we refuse or deny access to Personal Information to you or refuse to correct Personal Information we will provide you with reasons for such denial or refusal.

6. Complaints

6.1 Complaint

If you believe that we have used or disclosed your Personal Information in a manner which is contrary to this policy or otherwise breaches an applicable law, then you should email us at privacy@cupidmedia.com

6.2 Our Response

Within 30 days of receipt of your complaint we will notify you in writing as to what action we propose to take in relation to your complaint and will provide you with details of what further action you can take if you are not satisfied with our response.

7. Definitions

"Act" means the Privacy Act 1988 (Cth);

"Australian Privacy Principles" means the Australian Privacy Principles specified in the Act;

"Information" means Personal Information collected about an individual and includes Sensitive Information;

"Overseas" means outside the boundaries of the Commonwealth of Australia;

"Personal Information" means Information or opinion whether true or not and whether recorded in a material form or not about an individual whose identity is apparent or can reasonably be ascertained from the Information or opinion;

"Purposes" means the Primary and Secondary purposes;

"Sensitive Information" means Information or opinion about any individual's racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual preferences or practices, criminal record or Health Information about an individual;

"you" means the individual about whom we are collecting Information.

Cupid Media, the Cupid Media Logo and PinkCupid.com are registered trademarks of Ecom Holdings Pty Ltd and used with permission by Cupid Media Pty Ltd.