Privacy policy
Introduction
This policy (together with our end-user license agreement as set out at www.jigsaw.co ("EULA") and any additional terms of use incorporated by reference into the EULA, together "our Terms of Use") applies to your use of Jigsaw mobile application software ("App") once you have downloaded a copy of the App onto your mobile telephone or portable device ("Device").
Jigsaw (Version 5.0.0 on iOS and 2.0.0 on Android as at 1 June 2020) mobile application software (App) App available for download in major application stores worldwide, once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device).
Any of the services accessible through the App (Services) App unless the EULA states that a separate privacy policy applies to a particular Service, in which case that privacy policy only applies. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. This App is not intended for children and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
Important information and who we are
Jigsaw Dating Limited ("Jigsaw", "us" or "we") is a company registered in England and Wales with company registration number: 09954196 is the controller and is responsible for your personal data (collectively referred to as "we", "us" or "our" in this policy).
We have appointed a data protection officer (DPO). If you have any questions about this privacy policy, please contact them using the details set out below.
Contact details
Our full details are:
Full name of legal entity: Jigsaw Dating Limited ("Jigsaw", "us" or "we") is a company registered in England and Wales with company registration number: 09954196.
Email address: privacy@jigsaw.co
Postal address: Jigsaw, 91 Great Titchfield Street, London, W1W 6RW
ICO registration number: ZA223641
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues or other competent supervisory authority of an EU member state if the App is downloaded outside the UK.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review.
This version was last updated on the 30th of November 2019. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you by email or when you next start the App. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or the Services.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.
Third-party links, plug-ins and sites
Our App or Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.[SC3]
The data we collect about you
We may collect, use, store and transfer different kinds of personal data about you as follows:
Relationship Data – Special Category / Sensitive data such as sexual preferences
Identity Data.
Contact Data.
Financial Data.
Transaction Data.
Device Data.
Content Data.
Profile Data.
Usage Data.
Marketing and Communications Data.
Location Data
We explain these categories of data in more detail here[SC4]
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We will collect certain Special Categories of Personal Data about you (this includes your sex life, sexual preferences and orientation and may also include details about your race or ethnicity, religious or philosophical beliefs, political opinions, trade union membership, information about your health, and genetic and biometric data).
We do not intentionally collect any information about criminal convictions and offences though if you include these details as part of your public profile then we will have to process this data although we won’t use it for any of our own purposes other than as set out in this policy.
How is your personal data collected?
We will collect and process the following data about you:
Information you give us. This is information (including Identity, Contact, Financial, and Marketing and Communications Data) you consent to giving us about you by filling in forms on the App and the Services Sites (together Our Sites), or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the App, download or register an App, subscribe to any of our Services, search for an App or Service, make an in-App purchase, share data via the App's social media functions, enter a competition, promotion or survey and when you report a problem with the App or our Services. If you contact us, we will keep a record of that correspondence.
Information we collect about you and your device. Each time you use one of our Apps we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies. Please see our cookie policy [LINK] for further details.
Location Data. We will use GPS technology to determine your current location. All of our Services require your personal data to work. You will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by selecting the settings button from the App’s main menu and turning off visibility (or by disabling location services on your Device), however, doing so will mean you will be unable to use the App or the Services. We need access to your location data because the services we provided are based and reliant upon your location in order to provide a service which is relevant and valuable. Without this, users would not be able to search for people within their own region. If you have background location services turned on, then the App will use this to determine if you have drastically changed your position. The App does this because it needs to know where you are in order for you to search for users in your area or for other users to see that you are in their area. You can turn this off by disabling background location services in your device’s settings, although this might restrict the effectiveness of the App.
Information we receive from other sources including third parties and publicly available sources.
We will receive personal data about you from various third parties as set out below:
Device Data from analytics providers such as Google based outside the EU;
Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Apple and Google outside the EU;
With third parties who provide targeted advertising using cookies and other tracking technologies for retargeting on third party websites and services such as Facebook, Google, Snapchat, Reddit, Pinterest.
Unique application numbers. When you want to install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.
Cookies
We use cookies and/or other tracking technologies to distinguish you from other users of the App, App, the distribution platform (Appstore) or Services Sites and to remember your preferences. This helps us to provide you with a good experience when you use the App or browse any of Our Sites and also allows us to improve the App and Our Sites. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy.[SC5]
How we use your personal data
We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:
· Where we need to perform a contract, we are about to enter or have entered with you.
· Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
· Where we need to comply with a legal or regulatory obligation.
To find out more about the types of lawful basis that we will rely on to process your personal data see the table below.
We will only send you direct communications by email, text messaging apps, or text in accordance with the law. You have the right to opt-out at any time by contacting us or following the unsubscribe instructions set out in the relevant message.
To estimate your liveness based on your facial image. This is so that we can ensure any verification images provided are not spoofed and all users are real. To do this we collect a selfie from you as part of our app onboarding process. We only share your selfie with our partner Yoti (Yoti USA Inc for US users and Yoti Limited for non-US users).
We will not allow third-parties to send you any direct marking and we will not share your personal data with third parties for the purpose of them sending you direct marketing unless you give your express consent for this.
Purposes for which we will use your personal data after receiving consent with you:
Purpose/activity
To install the App and register you as a new App user
Type of data
Identity
Contact
Financial
Device
Location
Lawful basis for processing
Necessary for our creation of your account.
Purpose/activity
To manage our relationship with you including notifying you of changes to the App or any Services
Type of data
Identity
Contact
Financial
Profile
Marketing and Communications
Lawful basis for processing
Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services)
Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)
Purpose/activity
To enable you to participate in a prize draw, competition or complete a survey
Type of data
Identity
Contact
Device
Profile
Marketing and Communications
Lawful basis for processing
Necessary for our legitimate interests (to analyse how customers use our products/Services and to develop them and grow our business)
Purpose/activity
To administer and protect our business and this App including troubleshooting, data analysis and system testing
Type of data
Identity
Contact
Device
Lawful basis for processing
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)
Purpose/activity
To deliver content to you
To make recommendations to you about goods or services which may interest you
To monitor trends so we can improve the App
Type of data
Device
Content
Usage
Marketing and Communications
Location
Lawful basis for processing
Necessary for our legitimate interests (to develop our products/Services and grow our business)
Purpose/activity
To deliver product updates and activity to you
To measure and analyse the effectiveness of the updates we serve you
To monitor trends and usage so we can improve the App
Type of data
Identity
Contact
Device
Content
Profile
Usage
Marketing and Communications
Location
Lawful basis for processing
Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services)
Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)
Purpose/activity
To process in-App purchases and deliver Services
Type of data
Identity
Contact
Transaction
Lawful basis for processing
Your consent through Apple Pay or Google Pay
Performance of a contract with you
Disclosures of your personal data
When you consent to provide us with your personal data, except where we say that we have a legitimate interest or other legal basis for sharing your data and you have not previously opted out of this data sharing (in which case your consent is not required), we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the table Purposes for which we will use your personal data:
·
· External Third Parties as set out in the Glossary.
· Specific third parties listed in the table Purposes for which we will use your personal data above or as listed in the Glossary.
· Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
· To a Supervisory Authority, or other properly authorised body such as the ICO in the uk, If and to the extent that we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request;
· Credit reference agencies and Fraud prevention organisations in order to protect the rights, property or safety of Jigsaw, our users, or others.
· HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
International transfers
Many of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
· We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
· Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
· Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, search for European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
Data security
All information you provide to us is stored on our secure servers. Any payment transactions [carried out by us or our chosen third-party provider of payment processing services] will be encrypted using Secured Sockets Layer technology. Where we have given you (or where you have chosen) a password or unque code that enables you to access certain parts of Our App, you are responsible for keeping this information confidential. We ask you not to share this information with anyone.
Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.
We will collect and store personal data on your device using application data caches encrypted through your device providers key chain.
Certain Services include social networking, chat room or forum features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users and be aware that the third party who operates that plug-in or functionality may collect further personal data about you.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.
We share nothing else other than the selfie you take for verification with Yoti and Yoti will have no way of linking your selfie to any other data about you. Yoti processes this data in its UK based servers to check liveness, and then returns an estimated liveness result to us. Yoti deletes your selfie immediately once the liveness detection is completed and does not use your selfie for any other purpose at all. We keep your image for a maximum of 24 hours after it is uploaded and it is deleted immediately if you pass Yoti's liveness check. Yoti's privacy centre is available here: https://www.yoti.com/privacy/.
Data retention
Details of retention periods for different aspects of your personal data are [available in our retention policy which you can request by contacting us.
By law, we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see Your legal rights below for further information.
In some circumstances, we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
In the event that you do not use the App for a period of 7 years [SC7] then we will treat the account as expired and your personal data may be deleted.
Your legal rights
Under certain circumstances, you have the following rights under data protection laws in relation to your personal data.
Please click on the links below to find out more about these rights:
· Request access to your personal data.
· Request correction of your personal data.
· Request the erasure of your personal data.
· Object to processing of your personal data.
· Request restriction of processing your personal data.
· Request transfer or your personal data.
· Right to withdraw consent.
You also have the right to ask us not to continue to process your personal data for marketing purposes.
You can exercise any of these rights at any time by contacting us at privacy@jigsaw.co
Glossary
Lawful basis
Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for specific purposes. Consenting through the ‘tick’ icon when signing-up to the application. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Third parties
External third parties
Service providers acting as processors based in the United Kingdom and the United States of America (subject to the EU-US Privacy Shield) who provide IT and system administration services.
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue and Customs, regulators and other authorities [acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.
Amazon Web Services (AWS), based in the United Kingdom, who act as a data processor under our instructions carrying out back-up and hosting services.
All submitted information and other information collected by the App is stored by AWS and Google, acting as a data processor under our instruction, on their secure servers in accordance with their privacy policy which can be viewed at https://policies.google.com/technologies/partner-sites
Kochava act as a data processor in providing services to us showing us insight into user behaviour and usage using cookies and other tracking technologies. Kochava’s privacy policy is available here: https://www.kochava.com/support-privacy/ and who can be contacted at privacy@kochava.com.
Segment act as a data processor in providing services to us showing us insight into our user’s behaviour and usage using cookies and other tracking technologies. Segment’s privacy policy is available here: https://segment.com/docs/legal/privacy/. Segment may process your data in the United Kingdom and transfer it within their organisation to the United States of America subject to the EU-U.S. Privacy Shield framework.
Your legal rights
You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
(a) if you want us to establish the data's accuracy;
(b) where our use of the data is unlawful but you do not want us to erase it;
(c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
(d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Description of categories of personal data[SC8]
Identity Data: first name, sexual preference, date of birth, gender, email address and telephone numbers.
Contact Data[SC9] : email address and telephone numbers.
Transaction Data: includes details about payments to and from you and details of in-App purchases.
Device Data: includes the type of mobile device you use, a unique device identifier (for example, your Device's IDFA, IMEA and UDID number or the mobile phone number used by the Device), mobile network information, your mobile operating system, time zone setting.
Content Data: includes information stored on your Device, name, photos, social media handles or other digital content including text.
Profile Data: includes your name, in-App purchase history, preferences, feedback, device, name, photos, social media handles or other digital content including text.
Usage Data: includes details of your use of any of our Apps or your visits to any of Our Sites including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access[SC10] .
Marketing and Communications Data: includes updates from us only and will only be shared with third parties with consent.
Location Data: includes your current or recent location disclosed by GPS technology.
Relationship Data - Special Categories (sensitive data) of Information you provide to us. Your personal description might include a special category of personal data such as your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data or any other information that you decide to submit. Any information that you provide as part of your personal description will be made generally available to the users of the service and therefore it will become public knowledge. You should consider very carefully what information you decide to disclose about yourself when using the service as you may be making that information available publicly.