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GLEEDEN’S Privacy Policy

(Effective Date: May 24th, 2018)


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Gleeden is committed to preserve and secure the Privacy of its Members. This privacy policy, effective as of May 24, 2018, applies to https://www.gleeden.com as well as the Gleeden mobile application, both of which are owned and operated by BlackDivine LLC dba Gleeden (“The Company” or “We”). This privacy policy describes how we collect and use the personal information users (“Members” or “you”) provide on our web site: https://www.gleeden.com and on our mobile application (together, “Gleeden”). It also describes the choices available to you regarding our use of your personal information and how you can access and update this information.


We will abide by seven Principles:


Notice – We inform our Members that their data is being collected and about how it will be used.


Choice – We give our Members the ability to opt out of the collection of data and forward transfer of the data to third parties.


Onward Transfer - Transfers of data to third parties may only occur to other organizations that follow adequate data protection principles.


Security – We undertake reasonable efforts to prevent loss of collected information.


Data Integrity – We represent that the collected data is relevant and reliable for the purpose it was collected for.


Access – We provide our Members to access information held about them, and respect their right to correct or delete that data if it is inaccurate.


Enforcement – The present Privacy Policy informs our Members of their rights and how to exercise their rights.


What information will Gleeden collect ?


When you use Gleeden, you may set up your personal profile, form relationships, send messages, perform searches and queries, send virtual gifts, and transmit information through various channels (the “Services”). In order to facilitate your use of Gleeden and its Services, we collect personal information from you, including your age, email address, login name, password, profession, sex, gender, language, physical description, photos, marital status, sexual preferences, location, and education level so that we can provide you the Services, allow our search engines to generate the best results for prospects who may be of interest, and offer personalized features. We also keep the photos, saved searches, private messages, and IP address that you use or enter when you make use of the Services.


Some of the information you choose to provide when you register, update, or modify your account is considered “sensitive” or “special” data (for instance, your sexual preferences, sexual activities, or racial/ethnic background). Because you voluntarily share this information when your register for your account or share it through the Service, you are freely consenting to our processing of that information.


When you register for an account with our service, we will send you a welcoming confirmation email, based upon the personal information you provide us, to verify your account. We will also communicate with you in response to your inquiries, to provide the services you request, and to manage your account. We will communicate with you by email, in accordance with your wishes.


We will send you strictly service-related announcements on rare occasions when it is necessary to do so. For instance, if our service is temporarily suspended for maintenance, we might send you an email. Generally, you may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your account.


We will occasionally send you information on products, services, special deals, promotions. Out of respect for your privacy, we present the option not to receive these types of communications. Please see the “Opt-out” section below.


If you wish to subscribe to our newsletter(s), we will use your user name and email address to send the newsletter to you. Out of respect for your privacy, we provide you a way to unsubscribe. Please see the “Opt-out” section below.


We will save your personal information (email address), and demographic data (such as your city, your age, your gender) on our servers. Gleeden may share only general demographic data not associated with any users’ profile with our consultants to improve our Service, but we do not sell or transfer this information with others.


How will Gleeden use my personal information ?


Gleeden will use your personal information to process your purchase transactions, to send you marketing and promotional materials by e-mail, to keep you apprised of updates, and to help us improve our services for you, including by creating a log file to ensure the security of the site. Any notifications will be sent by email or push notifications for the mobile app. For more information on how to ‘opt-out’ of this type of communication, please see our “Opt-out” section below.


Why does Gleeden collect information on me ?


We need your personal information to provide a high quality service. Your profile information (your username, preferences, age, sex ) enables Gleeden to provide you with a personalized environment, and allow other members to find you through our advanced search monitor. Other information (including without limitation, your name, e-mail address, and credit card number) will be used in order to process transactions on the site, although we will not store your name or credit card information. We also retain details of your specific product purchases and transactions, interests or preferences. We may collect non-personal information about how Members navigate through the site.


We use third parties to facilitate certain transactions. Three companies, Payvision, Paysafecard, Paypal and Skrill, allow us to process your credit card payments, and so they have access to your payment information. Two other third party companies, Mailgun and Smartfocus, allow us to send you emails, and so they have access to your email address, gender, and user name. Finally, Rollbar allows us to monitor and log technical issues, like crashes or errors, by logging IP address, user agent, and unique identifier of the member; those logs are kept for a maximum of 6 months. These companies are authorized to use your personal information only as necessary to provide these services to us. We will share your personal information with third parties only in the ways that are described in this privacy policy. We do not sell your personal information to third parties.


We shall not sell or provide any personal data to anyone except in the following circumstances: (1) to financial institutions providing financial or related services (to process payment), (2) to governmental authorities (for data protection), (3) in connection with a corporate re-organization, a merger or an amalgamation of the Company with another company or a sale of all or a substantial portion of our assets, provided that the information disclosed continues to be used for the purposes permitted by this Privacy Policy by the entity acquiring the information, (4) to a third party without your consent if we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other website users or anyone else that could be harmed by such activities, or (5) if required by law and when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or legal process served on our Company.


We do not intentionally collect any information from children under the age of 18, who are not permitted to access or use Gleeden.


Where does Gleeden collect information ?


Gleeden’s servers are located in the United States. Gleeden Members understand that, in order to receive the Services, Gleeden Members must provide certain Personal Data By providing any Personal Information to Gleeden, all Members, including, without limitation, Members in Canada and in the European Union, fully understand and unambiguously consent to this Privacy Policy and to the transfer of such Personal Information across international borders in accordance with Gleeden’s standard operations, including the collection, storage, and processing of such information in the United States of America.


How secure is my personal information on Gleeden ?


Your personal information is very important to us. Gleeden uses various technical and management practices to help protect your confidentiality, security and integrity of the information you share with us.


Your credit card number and other personal information are protected during payment by our use of secure socket layer (SSL) technology that allows for the secure transmission of information from your computer to our servers. Our payment process is PCI compliant.


We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Web site, you can contact us at privacy@gleeden.com


When you register your profile, you may use a pseudonym for username, indicate the city where you live and provide a description of yourself and of your preferences. Your real name never appears on the website, but be aware that some material that you post (for example, personal pictures) may identify you.


How long will Gleeden keep my personal information?


We will keep your personal information as long as your profile remains active. Once you cease to be a Member, Gleeden will not archive your personal information on our servers but will automatically delete all your personal information from our servers. We may keep, however, a record of the country of origin for the account, the language for the account, and login activity based on your IP address and/or user agent for up to one year after your account has been deleted, as well as any information that you have voluntarily transferred to another member.


How can I access my personal information and manage it ?


You can access and manage your information from the page “manage my profile” or “my account” while you are a Member. When you cease to be a Member, you may contact us at any time to access the non-personal information in our possession, to the extent that it exists, but we will need you to provide information sufficient to verify your identity.


If your personal information changes, or if you no longer desire our service, you may correct, update, amend, delete and/or deactivate your account by emailing us at info@gleeden.com. We will respond to your request to access within 30 days.


Can I Opt Out of the Collection of Data ?


You may do so at any time by contacting us at info@gleeden.com. However, if you choose not to provide requested personal information, you may not be able to use certain features of the Service and you will not be able to use the Service. This may cause us to stop offering you the Service and terminate your member account.


Gleeden does not send unsolicited marketing mail. Gleeden will send you marketing e-mails only if you consent to receiving such e-mails. You can disable this function in your account settings.

We may send you emails to provide you updates about your account to or notify you about activity (if, for example, another Member has viewed your profile). If you have any questions or requests about the privacy of your information, please contact us at info@gleeden.com


What information do you gather from visitors ?


Gleeden may share non-personal information (including but not limited to hits to our server, the types of browsers used to access our Site, page views, and navigational patterns) with consultants for statistical reasons, or to enhance the Service. The information that is collected in this manner does NOT provide us with any personal information about our Members. It helps us track “where” our Members come from, allows us to identify high traffic areas and determine the most effective ways to communicate with our Members. Gleeden may also uses devices called “web beacons” to help us identify when emails sent to you have been received and read.


We use your IP address to maintain our site and be able to react quickly to any problem with our server.


We use cookies to identify traffic generated and to provide you with a very personal environment. Cookies are pieces of information placed on your hard drive so we can recognize you when you visit us. Cookies enable us to provide you with a friendly environment and a very personalized access. Using cookies is very common. If you are not comfortable with this, you can disable the cookies through your Internet browser options. Gleeden will not function at all if you disable cookies.


We use Google Analytics, a third-party tracking service, which uses cookies to track non-personal information about our visitors to our site in the aggregate to capture usage and volume statistics. Some of our business partners (e.g., Google Analytics) use cookies on our site. We have no access to, or control over, these cookies. This privacy policy covers the use of cookies by Gleeden only and does not cover the use of cookies by any third-party.


Clear Gifs (Web Beacons/Web Bugs/Tracking Pixel)


We employ and our third party advertising partner employs a software technology called clear gifs (a.k.a. Web Beacons/Web Bugs/Tracking Pixel), that help us better manage content on our site by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. We do not tie the information gathered by clear gifs to our customers’ personal information.


Opt Out of Cookies and Tracking


As mentioned you may not wish to allow the placement of cookies or other tracking software. However, should you do so, the functioning of the services will be impaired such that it will not function at all, and you will not be able to use the Services. If you wish to opt out of the use of cookies or other tracking technologies, please do not use the service.


Links to Other Web Sites


Our Site includes links to other Web sites whose privacy practices may differ from those of Gleeden. If you submit personal information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any Web site you visit.


Business Transitions


In the event the Company goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, your personal information will likely be among the assets transferred. You will be notified via email or prominent notice on our Web site for 30 days of any such change in ownership or control of your personal information.


Changes in this Privacy Policy


If we decide to change our privacy practices, we will post those changes to this privacy policy, the home page, and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. We reserve the right to modify this privacy policy at any time, so please review it frequently. If we make any material changes, we will notify you here, by email, or by means of a notice on our home page prior to the change becoming effective.


Disputes


In the event that a dispute cannot be rectified in house, we will use the services of PrivacyTrust.


Contact Us


If you have any questions or suggestions regarding our privacy policy, please contact us at:


Or at privacy@gleeden.com


If you reside in California


Pursuant to California Civil Code Section 1798.83, a California resident who has provided Personal Information to a business with whom he/she has established a business relationship for personal, family, or household purposes (“California Customer”) is entitled to request information about whether the business has disclosed Personal Information to any third parties for the third parties’ direct marketing purposes. In general, if the business has made such a disclosure of Personal Information, upon receipt of a request by a California customer, the business is required to provide a list of all third parties to whom Personal Information was disclosed in the preceding calendar year, as well as a list of the categories of Personal Information that were disclosed.


However, under the law, a business is not required to provide the above-described lists if the business adopts and discloses to the public (in its privacy policy) a policy of not disclosing customer’s Personal Information to third parties for their direct marketing purposes unless the customer first affirmatively agrees to the disclosure, as long as the business maintains and discloses this policy. Rather, the business may comply with the law by notifying the customer of his or her right to prevent disclosure of Personal Information and providing a cost free means to exercise that right.


As stated in this Privacy Policy, we do not share information with third parties for their direct marketing purposes unless you affirmatively agree to such disclosure -- typically by opting in to receive information from a third party that is participating in some activity describes on our site. If you do ask us to share your information with a third party for its marketing purposes, we will only share information in connection with that specific activity, as we do not share information with any third party on a continual basis. To prevent disclosure of your Personal Information for use in direct marketing by a third party, do not opt in to such use when you provide Personal Information on our site. Please note that whenever you opt in to receive future communications from a third party, your information will be subject to the third party's privacy policy. If you later decide that you do not want that third party to use your information, you will need to contact the third party directly, as we have no control over how third parties use information. You should always review the privacy policy of any party that collects your information to determine how that entity will handle your information.


California customers may request further information about our compliance with this law by emailing info@gleeden.com. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this email address.


EU-U.S. Privacy Shield


The Company is a participant in the U.S. Department of Commerce's EU-U.S. Privacy Shield and has certified that we adhere to the EU-U.S. Privacy Shield Principles. The Company is subject to the jurisdiction of the Federal Trade Commission, including the Commission’s investigatory and enforcement powers. For more information about the EU-U.S. Privacy Shield Framework, visit the U.S. Department of Commerce's Privacy Shield website at https://www.privacyshield.gov If you do not receive timely acknowledgement of your complaint, or if your complaint is not satisfactorily addressed, you can also submit your complaint to Privacy Trust, an independent third party. Visit https://www.privacytrust.com/drs/gleeden to file a complaint. In addition, if you are unhappy with how we deal with your complaint, or the outcome, you may invoke binding arbitration or refer your complaint to a data panel. In cases of onward transfer to third parties of data of EU individuals received pursuant to the EU-US Privacy Shield, the Company remains liable.


DPO


The Data Protection Officer for the Company is James J. Ward, who can be reached at :

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