Privacy Policy

This is the Privacy Policy for Sugar.ie, accessible from here.

1. Definitions

• The Website: Sugar.ie

• The Service Provider:

  
• The User or You: The individual using or registering on the Website
• Account: A registered user dating profile on the Website
• Personal Data: Any information that identifies or can identify an individual, including names, emails, IP addresses, and payment information.
• Cookies: Small files stored on a User’s device to enhance functionality or track Website usage.
• Third-Party Services: External services used by The Service Provider to operate and improve the Website, including analytics providers, payment processors, and email services.

This Privacy Policy outlines how The Service Provider collects, uses, and protects Personal Data in compliance with UK GDPR and EU GDPR where applicable. By using the Website, you agree to the terms of this Privacy Policy. If you do not agree, you must stop using the Website immediately.

2. Purpose of Collecting Personal Data

2.1 Service Delivery

We collect Personal Data to:

• Enable account creation and management.
• Facilitate safe and consensual communication between Users.
• Provide paid services, such as subscriptions and profile boosts.

• Analyze trends to enhance User experience.
• Develop new features and services.
• Monitor Website security and prevent fraudulent activities.

• Anti-money laundering regulations.
• Tax and financial reporting requirements.

3. Categories of Data Collected

3.1 Data Provided by the User

• Account Data: Name, email, gender, date of birth, location, and profile information (e.g., photos and preferences).
• Payment Data: Billing details, payment method, and transaction records.
• Communications: Messages sent via the Website or customer support channels.

3.2 Data Collected Automatically

• Device Information: IP address, browser type, device type, and operating system.
• Usage Data: Pages visited, clicks, session durations, and navigation patterns.

3.3 Sensitive Data

• Certain sensitive information (e.g., sexual orientation) may be processed if voluntarily provided by you in your profile.

3.4 Cookies and Similar Technologies

• We use Cookies for essential functionality, performance tracking, and personalized advertising.
• You can manage Cookies through your browser settings. (See Section 10 for more details.)

4. Legal Basis for Processing

We process your Personal Data under the following lawful bases:

• Contractual Necessity: To fulfill the services you request.
• Consent: For non-essential activities such as marketing.
• Legitimate Interests: To improve Website performance and ensure security.
• Legal Obligations: To comply with applicable laws and regulations.

• Consent: To verify age and identity before allowing Adult Content uploads.
• Legal Obligation: To comply with record-keeping requirements under 18 U.S.C. § 2257.

5. How We Use Your Data

5.1 Service Management

Your data is used to:

• Facilitate account registration and profile creation.
• Enable communication features such as private messaging.
• Process payments for premium services.

• Track and fix technical issues.
• Optimize user experience.
• Identify and prevent unauthorized activities.

• Verify identities and detect fraud.
• Respond to legal requests or enforce Terms and Conditions.

6. Sharing Personal Data

6.1 Third-Party Services

We share data with the following third-party service providers to enhance the functionality and security of the Website:

• Google Analytics: For tracking user interactions and improving the Website’s functionality. Data is anonymized or pseudonymized where possible.
• Datafy.ai: For click tracking and behavioral analysis to improve user experience.
• Payment Processors: To securely process transactions, including credit card payments and subscriptions.
• Email Service Providers: To send notifications, transactional emails, and marketing communications.

All third-party providers are contractually required to handle your data in compliance with applicable data protection laws, including UK GDPR and EU GDPR.

7. Data Retention Policy

7.1 Retention Periods

• Account Data: Retained for six years after account deletion unless required for legal compliance.
• Payment Records: Retained for seven years in accordance with tax regulations.
• Messages: Retained for one year post-account deletion to resolve disputes.

7.2 Deletion Requests

• Users can request data deletion. Certain data may be retained to comply with legal obligations or to enforce bans on re-registration.

8. Security Measures

The Service Provider uses industry-standard measures to protect your data:

• Encryption: Data transmitted over the Website is encrypted using SSL.
• Access Controls: Only authorized personnel can access sensitive data.
• Regular Audits: Security systems are regularly tested to identify vulnerabilities.

No system is completely secure. Users are advised to take precautions, such as using strong passwords and avoiding sharing sensitive data in messages.

Personal data collected during age verification for Adult Content uploads is stored securely and only accessed for compliance or regulatory purposes.

The Service Provider implements encryption and restricted access controls to ensure the protection of this data.

9. International Data Transfers

9.1 Data Transfers Outside the UK and EEA

Your Personal Data may be transferred and processed in countries outside the United Kingdom (UK) or the European Economic Area (EEA).

• Standard Contractual Clauses (SCCs) approved by the UK or European Commission to ensure your data is handled in compliance with applicable laws.
• Transfers only to countries with an adequacy decision by the UK or European Commission, where data protection laws are deemed equivalent.
• Contractual obligations for third-party service providers to adhere to UK GDPR and EU GDPR standards.

By using the Website, you consent to these international transfers where necessary.

10. Cookies and Tracking Technologies

10.1 What Are Cookies?

Cookies are small files placed on your device when you access the Website. They allow us to recognize your device, improve functionality, and provide personalized services.

10.2 Types of Cookies We Use

• Essential Cookies: Required for the Website to function (e.g., account login).
• Performance Cookies: Collect anonymized data to analyze Website usage and improve user experience.
• Targeting Cookies: Used to deliver personalized advertising based on your browsing habits.

11. Your Rights Under Data Protection Laws

Under UK GDPR and EU GDPR (for EEA users), you have the following rights:

To exercise these rights, contact [email protected]. You may be required to verify your identity to prevent unauthorized access to your data.

12. Marketing Communications

12.1 Opt-In and Opt-Out Options

We will only send you marketing emails if you have opted in. You can opt out of marketing communications by:

• Updating your preferences in your account settings.
• Clicking the “unsubscribe” link in any marketing email.

13. Data Breaches and Security Notifications

13.1 Incident Response

In the unlikely event of a data breach, we will:

• Notify affected users without undue delay if their rights or freedoms are at risk.
• Report the breach to the relevant supervisory authority (e.g., the UK Information Commissioner’s Office or EEA equivalent) within 72 hours if required.

14. Updates to This Privacy Policy

14.1 Notification of Changes

We may update this Privacy Policy periodically to reflect changes in our practices, legal obligations, or Website functionality.

15. Contact Information

For privacy-related inquiries or to exercise your rights, please contact:

• UK Information Commissioner’s Office (ICO): www.ico.org.uk
• Your local Data Protection Authority in the EEA, if applicable.

Last updated: 27/11/2024