Last updated: April 12, 2018
(1) In order to provide its services, Interdate S.A. must collect certain personally identifiable information and data from you (the “Personal Data”). Personal Data includes, but is not limited to, information such as age, gender, zip code, telephone number, e-mail addresses, and evaluation results of the answers to the questionnaire, and personal statements and pictures you post on our Website/App. Personal Data may be collected, stored, processed, and used by Interdate S.A. for the purpose of providing its services.
(2) Interdate S.A. treats all of your Personal Data with the utmost care for your privacy and security. Interdate S.A. does not sell, trade, or otherwise disclose customer lists or Personal Data to unaffiliated third parties without your permission. However, for purposes of providing its services to you, Interdate S.A. may store your Personal Data on servers of third parties or disclose your Personal Data to third parties who provide products or services to you or us (e.g. our credit card processing company or third party vendors accessible through our Website/App). These third parties are not permitted to use your personal information for any purpose unrelated to providing their products or services to you or us.
(3) In the event that Interdate S.A. is acquired or substantially all of its assets are transferred as part of a sale of the company or its parent or otherwise, your Personal Data could be transferred to a third party. By accepting the Terms, you have expressed your consent to such a transfer of your Personal Data. Further, in the event we make a material change in the way we collect Personal Data, use Personal Data, or change our e-mail policies, we will notify you in accordance with Section 4 below.
(5) Use of the Website/App is reserved for persons who are 13 years of age or older. Use of the Website/App by persons under the age of 13 is prohibited. Interdate S.A. complies with the Children’s Online Privacy Protection Act (“COPPA”) and all other laws and regulations pertaining to the business of Interdate S.A.. Even though COPPA only applies to children under the age of 13 and the Website/App is for persons who are over 18, in order to fully comply with the provisions of COPPA, Interdate S.A. hereby states affirmatively that (a) the Website/App is not intended for children under 13 years of age; (b) no one under age 13 may provide any personal information to or on the Website/App, and (c) Interdate S.A. does not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website/App or on or through any of its features, do not register on the Website/App, do not make any purchases through the Website/App, do not use any of the interactive or public comment features of this Website/App or provide any information about yourself to Interdate S.A., including your name, address, telephone number, e-mail address or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child fewer than 13, please contact us at: email@example.com.
(7) Interdate S.A. may use your Personal Data for the purposes of advertising, market research and for research and analysis to enhance or modify our Website/App and services. Furthermore, by registering and using the Website/App and services, you give your explicit consent to receive e-mail newsletters from Interdate S.A. about Interdate S.A. and Interdate S.A.’s advertising partners’ products. This consent may at any time be cancelled by you by clicking on the unsubscribe link in any newsletter.
(8) We may use the information we have collected from you to enable us to display advertisements to our advertisers' target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
(10) Disclosure of Your Information: We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
· To our subsidiaries and affiliates.
· To contractors, service providers and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
· To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of Interdate S.A.'s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by Interdate S.A. about our Website/App users is among the assets transferred.
· To third parties that market their products or services to you if you have consented to these disclosures.
· To fulfill the purpose for which you provide it.
· For any other purpose disclosed by us when you provide the information.
· With your consent.
We may also disclose your personal information:
· To comply with any court order, law or legal process, including to respond to any government or regulatory request.
· To enforce or apply our Terms and other agreements, including for billing and collection purposes.
· If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Interdate S.A., our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction and preventing resp. opposing misuse of the service
(12) Your California Privacy Rights:California Civil Code Section § 1798.83 permits users of our Website/App that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an e-mail to firstname.lastname@example.org.
(13) Interdate S.A. may transmit data on an anonymous basis to other vendors or service providers in connection with the products or services provided by them to you or us for conducting research or analysis related to their products or services. If you wish to object to the transmission of anonymous data to these vendors or service providers, send an e-mail to email@example.com stating your user name and full name and the purpose of your objection.
(14) Interdate S.A. will at any time upon request provide you with full and free information on the stored data files that are related to your account on the Website/App.
(15) We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted using SSL technology.
(16) The safety and security of your information also depends on you. Where we have given you or where you have chosen a password for access to certain parts of our Website/App, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website/App like message boards. The information you share in public areas may be viewed by any user of the Website/App.
(17) Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website/App. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website/App.
Privacy Statement Lisa18
(Effective from: 25.05.2018)
Data protection is an important concern of Interdate S.A., 13 rue du Commerce L-1351 Luxembourg Luxembourg ("Interdate S.A."). For this reason, we process our customers' data solely in compliance with valid regulations relevant to data protection (GDPR).
We collect and process personal data if you make this data available to us in the framework of registering on our website for using Lisa18 services ("Lisa18"), and we are entitled to collect, use and process the data on the basis of consent that you issued.
Personal data is all information that refers to an identified or identifiable natural person ("data subject"). We differentiate between personal data in the framework of a free profile and a Premium membership.
In the case of free registration we collect and process the personal data:
Master data: nickname, email address, password, gender, gender wanted, date of birth, relationship status
Personal characteristics: characteristics, height, colour of eyes and hair, length of hair, figure, ethnicity, occupation, education, drinking and smoking habits, body decoration, sexual preferences, erotic type (using images chosen by users)
Search profile and other information: state, region, county/town, postcode, personal welcoming message, profile images
Your transaction data: customer ID, messages, date of first registration, activity on our website, access type (mobile/desktop), internal tracking code, date and time of access, browser type and version, operating system, IP address, device ID, mobile service provider
In the framework of Premium membership we collect in addition:
Home address, first and family name, telephone number and payment data. We forward credit card data to our contractual Payment Service Providers via a secure connection and store them in an anonymised form only.
Purpose of data processing
We use the above-mentioned personal data for the following purposes:
- Providing the services you request as well as the customer service that you request;
- Carrying out and managing the business relationship between us and you; e.g. in order to handle the provision of services, collect payments, settlements and debt collection, for accounting purposes;
- Reviewing customer communication between customers and customer support staff;
- Information on new or supplementary products from Interdate S.A., and from cooperation partners of Interdate S.A., as well as for preparing a newsletter;
- Carrying out customer surveys, marketing campaigns, market analyses;
- Compliance with statutory requirements (e.g. obligations under tax and commercial law to preserve records);
- Maintaining and protecting the security of our products and services and of our websites by preventing and detecting security risks, fraudulent behaviour or other criminal activities or activities carried out with the intent to cause damage;
- Settling disputes, enforcing existing contracts and for claiming, exercising and defending legal rights.
Processing personal data is necessary to achieve the above-mentioned purposes, including the implementation of the (contractual) business relationship with you. Unless otherwise expressly stated, the legal basis for the data processing is Article 6 (1) (b) and (f) of the General Data Protection Regulation, or your expressly issued consent in accordance with Article 6 (1) (a) of the General Data Protection Regulation.
If the above-mentioned data are further processed for a purpose other than the original collection purpose, we are obliged to inform you of this before further processing and of the new purpose. In this way, you have an opportunity to object to the processing of your data for the other purpose.
Transfer of data
All data that you transmit to us will be treated in confidence. We will not sell your personal data to third parties.
You data will, in principle, not be made available for use to third parties, unless you have declared your agreement or we are entitled and/or obliged by law to transfer this data.
We transfer personal data to courts, tax authorities, supervisory authorities if this is legally permissible and necessary to comply with current law, or to enforce, exercise or defend legal rights. We take all steps to ensure suitable and reasonable guarantees to safeguard your personal data.
Insofar as this is necessary for the provision of the service, we forward personal data for the above-mentioned purposes to the following companies or categories of companies:
- insparx GmbH, Erika-Mann-Straße 63, 80636 Munich, Germany. Our service provider is responsible for operating our platform, software further development, for customer support, and for marketing and sending newsletters.
- Payment service providers, acquirer/executing banks for the purpose of payment processing.
- On non-payment, to collection agencies to safeguard our business interests.
- To cooperation partners / marketing and email newsletter partners.
- Data may be transferred to specialised service providers to prevent or combat cases of abuse by customers and/or third parties.
Transmission to addressees outside the EU takes place only if the predefined purpose requires this and only on the basis of EU standard contract provisions, or if a company in the USA is certified in accordance with the EU/US Privacy Shield (http:// www.privacyshield.gov). This guarantees that your data is processed in conformity with data protection provisions in the USA as well (adequacy decision of the EU Commission of 12.07.2016, ref. C(2016) 4176 final, Official Gazette L 207/1 of 01.8.2016).
If an explicit storage period is not indicated on collection (e.g. in the framework of a declaration of consent), personal data will be deleted if they are no longer required to fulfil the purpose of storage, unless statutory obligations to keep records prevent deletion (e.g. obligations under tax and commercial law to preserve records).
We take technical and organisational security measures to protect your data that we store and process in our company against manipulation, loss of confidentiality, destruction and against access by unauthorised persons. Our company's security measures are constantly improved in accordance with technological developments.
Rights of data subjects: right to information, correction, deletion or restriction of processing of their personal data, right to object and right to data portability
We will inform you in writing on request in accordance with current law whether and which personal data we store in our company. If you, yourself, are registered as a user, we provide you with an opportunity to inspect these data yourself and, where applicable, to amend and delete them. If false information has been stored in spite of our company's efforts with regard to data security and data correctness, and you as user are unable to correct your data, we will correct them at your request.
You also have the right to demand restriction of the processing of personal data by our company. In addition, you may demand that you are given data that you provided to our company in a structured, standard and machine-readable form. You may also object to the processing of personal data by our company.
In addition, you have the right to demand that your personal data be deleted, unless statutory obligations to keep records prevent this. We delete data when we no longer require it for the purpose for which it was collected and processed, or if you revoke your consent and there is no other legal basis for the further processing of your data. In addition to this, we delete data if processing was illegal for reasons that are unknown to us, or if you have filed an objection to the processing and there are no prior legitimate interests for processing. Your data will also be deleted if we are obliged by law to do this. Our company has also implemented technical measures to make all recipients of your data aware of your demand for deletion or correction. This applies only for cases in which we disclosed or made these data public. All links, copies and replications of your personal data will be deleted.
If you consented to the processing of your personal data, you have the right to revoke the consent at any time, with effect for the future. Revocation of consent does not make data processing in the past unlawful.
Data transmission to our company is done voluntarily. However, these data are necessary for the further conclusion of the contract or to reply to your queries. If you do not wish to make your data known, the contract may in certain circumstances not take effect, or your queries may not be answered. Providing data is necessary for concluding the contract.
The contact data of our company's data protection officer are:
firstname.lastname@example.org or by post to
Lisa18 Data Protection Officer
13 rue du Commerce
You also have the right to complain to the competent data protection supervisory authority about data processing by our company.
The data protection supervisory authority responsible for our company is:
Commission nationale pour la protection des données
1, avenue du Rock’n’Roll
Tel.: (+352) 26 10 60 -1 www.cnpd.lu
As a data subject, you have the possibility to approach the data protection supervisory authority in your country: (https://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080).
If you register for a subscription to our newsletter, the data you provide will be used solely for this purpose.
Your name and a valid email address are required for effective registration. For this purpose, your opt-in to the newsletter subscription is logged. The data is used solely for sending the newsletter.
You may revoke your consent to storage of your data and their use for sending the newsletter at any time. Each newsletter contains a link for this purpose. Apart from this, you may unsubscribe the newsletter at any time directly by email to email@example.com or by post to the following address:
Lisa18 Customer Support
13 rue du Commerce
When you access our company's homepage, for technical reasons your Internet browser automatically transmits the following data ("log data") to our company's web server, which our company records in log files:
- date and time of access, URL of the referring website, file requested, transmitted data volume, browser type and version, operating system, IP address, domain name of your Internet access provider
This is solely information that does not permit any conclusions with regard to the natural person. This information is technically necessary in order to display the website content that you requested correctly and is mandatory for use of Internet offers. Log data is evaluated purely for statistical purposes, in order to optimise our company's web presence and the underlying technology, and are then deleted.
Log data is stored separately from other data that our company collects in the framework of use.
Pseudonymised or anonymised usage profiles
Lisa18 has analyses carried out of customer behaviour in the framework of use of Lisa18 services and prepares anonymised or pseudonymised usage profiles for this. Usage profiles are evaluated anonymised or pseudonymised and not in relation to persons. The analyses are intended to improve our services.
Tracking-based analyses and remarketing tools
We use so-called tracking technologies in order to continuously improve and optimise our offer. We use the services of Google Analytics, Google AdSense, Google DoubleClick, Google AdWords (Remarketing), Adjust, Crashlytics, Kenshoo.
Lisa18 also uses Google Analytics, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on customers' computers, to help the website analyse how they use the site. The information generated by the cookie about use of this website (including the IP address) will be transmitted to a Google server in the United States and stored there. Google will use this information to evaluate customers' use of the website, to compile analyses of website activities for website operators and to provide other services associated with website and Internet use. Where applicable, Google will also transmit this information to third parties, insofar as this is prescribed by law, or if third parties process these data on its behalf. Google will not associate the IP address with any other data that it holds. Customers may prevent the installation of cookies by selecting the appropriate settings on their browsers; however, please note that if this is done, it may not be possible to use all the functions of this website in their full capacity. By using this website, customers declare their agreement with the processing of collected data by Google in the manner described above and for the above-mentioned purpose. For detailed information on Google Analytics and data protection go to https://tools.google.com/dlpage/gaoptout.
Lisa18 also uses Google AdSense, a service provided by Google Inc. 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google") for integrating ads. Google AdSense uses so-called "cookies", which are text files that are placed on the customer's computer and enable an analysis of the customer's use of the website. Google AdSense also uses so-called web beacons (invisible graphics). Information such as visitor traffic on these sites can be evaluated through these web beacons. Information generated by cookies and web beacons about use of this website (including the IP address) and delivery of web formats will be transmitted to a Google computer in the United States and stored there. Google may forward this information to its contract partners. However, Google will not associate the IP address with any other data that it holds. The customer has the right to prevent installation of cookies by selecting the appropriate settings on their browser; however, please note that if this is done, it may not be possible to use all the functions of this website in their full capacity. By using this website, customers declare their agreement with the processing of collected data by Google in the manner described above and for the above-mentioned purpose.
Lisa18 also uses Google DoubleClick, a service provided by Google Inc. 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"). Google DoubleClick uses so-called "cookies" in order to present advertising to the customer that is relevant for them. In this, a pseudonymous identification number (ID) is assigned to the customer's browser to check which ads were displayed in the browser and which ads were requested. The cookies do not contain any personal information. Use of DoubleClick cookies merely enables Google and its partner websites to place ads on the basis of previous visits to our or other websites in the Internet.
Information generated by the cookies and web beacons about use of this website (including the IP address) and delivery of web formats will be transmitted by Google to a server in the United States for evaluation and stored there. Google will only transmit the data to third parties on the basis of statutory provisions, or in the framework of contract data processing. Google will not associate the customer's data with any other data that it holds. The customer has the right to prevent installation of cookies by selecting the appropriate settings on their browser; however, please note that if this is done it may not be possible to use all the functions of this website in their full capacity. In addition, customers can prevent the recording of data generated by cookies and related to their use of the websites and the processing of these data by Google by downloading and installing the browser plugin available through the following link https://tools.google.com/dlpage/gaoptout?hl=de under the item DoubleClick deactivation add-on. Alternatively, customers can deactivate DoubleClick cookies on the website of the Digital Advertising Alliance by clicking the following link https://adssettings.google.com/?hl=en. By using this website, customers declare their agreement with the processing of collected data by Google in the manner described above and for the above-mentioned purpose.
In addition, Lisa18 uses the analytics programs of various other providers, in order to use findings acquired here – in an anonymised or pseudonymised manner and in the framework of statutory requirements – for the demand-oriented design and improvements of services provided by Lisa18 and for the purposes of advertising and market research.
Google AdWords (remarketing)
Lisa18 also makes use of the remarketing function within the Google AdWords service. Google AdWords is an online advertising program provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google”). With the remarketing function we can present advertising based on their interests to users of our website on other websites in the Google display network (on Google itself, so-called "Google ads" or on other websites). For this purpose, the interaction of users on our website is analysed, e.g. what offers are users interested in, in order to be able to display targeted advertising on other websites after they visit our website as well. To do this, Google saves a number in the browsers of users who visit specific Google services or websites in the Google display network. This number, referred to as a cookie, is used to record the users' visits. The number serves the unambiguous identification of a web browser on a specific computer and not for identifying a person. Information on use of our website collected through the cookie (including your IP address) is usually transmitted to a Google server in the United States and stored there. Please note that on this website Google AdWords (Remarketing) was extended by the code "gat._anonymizeIp()", in order to guarantee anonymised collecting of IP addresses (so-called IP masking). For this reason, at our instance Google collects your IP address in an abbreviated form only, which guarantees anonymisation and does not permit any conclusions regarding your identity. In the event that IP anonymisation is activated on this website, Google will abbreviate your IP address beforehand within a member state of the European Union or in other signatory states of the Treaty on the European Economic Area. The full IP address will only be transmitted to a Google server in the USA and abbreviated there in exceptional cases.
You have the right to prevent installation of cookies by selecting the appropriate settings in your browser software; however, please note that if you do this, you may not be able to use all the functions of this website in their full capacity. In addition to this, you can deactivate interest-based ads on Google and interest-based Google ads in the web (within the Google display network) in your browser by following the link "Deactivate" at https://adssettings.google.com/?hl=en in the submenu "Deactivation settings". Furthermore, you can deactivate interest-based ads at http://www.networkadvertising.org/choices/?partnerId=1/ cookies by means of opt-out; an opt-out cookie is set on your computer for this purpose.
Lisa18 also uses the "adjust" analytics technology provided by adjust GmbH, Saarbrücker Str. 37A, 10405 Berlin ("adjust”). adjust uses IP and Mac addresses for the analysis, whereby these addresses are only used in an anonymised form. In this way, conclusions regarding a natural person are not possible.
The smartphone apps from Lisa18 use the Crashlytics tool, which is part of the Twitter platform fabric, in order to log crashes of the application. Crashlytics is a division of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. No personal data are transmitted. Only real-time crash reports with exact information on register codes and appliance information are transmitted that are intended to simplify maintenance and improve the resulting stability of the app. The Crashlytics privacy statement can be inspected here: http://try.crashlytics.com/terms/privacy-policy.pdf
We also use the development tool SDK provided by Facebook Inc., 1 Hacker Way, 94025 Menlo Park, CA, USA, Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland ("Facebook SDK") with regard to the app. Facebook SDK enables evaluation of user behaviour in an anonymised form and measuring of active users and their behaviour (e.g. posts, replies, votes). This does not provide us with any access at all to Facebook data or to users' Facebook accounts. For more information on Facebook SDK go to https://developers.facebook.com/docs/ios and https://developers.facebook.com/docs/android.
Cookies are text snippets that are stored either for a limited time (so-called "session cookies") in a computer's temporary memory, or on a computer's hard disk (so-called "persistent cookies"). Cookies contain, for example, information on users' previous access to the appropriate server, information on which offers were requested or which methods of payment were agreed during previous transactions. The main purposes of cookies is, by storing personal settings on websites, to prepare offers customised to customers on the one hand and, on the other, to design the use of services to be as comfortable as possible, because customers can visit these websites in this way without having to make all the settings every time. In contrast, cookies are not used to carry out programs independently or even to load viruses onto customers' computers.
Lisa18 uses sessions cookies, partner and affiliate cookies and persistent cookies.
Lisa18 uses so-called "sessions cookies". These are not stored on the computer's hard disk and are deleted when the browser is closed. Sessions cookies are used in particular for login authentication during the registration procedure.
Partner and affiliate cookies:
In addition to the above, Lisa18 uses so-called "partner cookies" or "affiliate cookies". These are understood as cookies that are set if a customer accesses the service of Lisa18 through the advertising space of a cooperation partner. These cookies are used for settlements with cooperation partners and do not contain any personal data of customers. They are deleted either when the customer registers on the Lisa18 website or automatically on expiry of the relevant cookie lifetime.
Lisa18 uses so-called "persistent cookies" in order to store the personal usage settings that a customer enters when using Lisa18 services. On the one hand, this ensures that customers find their personal settings again when they return to Lisa18 websites and, on the other, it serves the automatic differentiation of the customer's membership status, whether they have already seen specific information and advertising campaigns, or have taken part in a survey. Use of persistent cookies is intended to personalise and improve Lisa18 services.
Most Internet browsers are set to accept cookies by default. However, customers have the right and the possibility to set their computers to reject cookies, or at least for the customer to be asked to confirm beforehand. If the customer decides to reject or switch cookies off, the consequence may be a reduction in the scope of the Lisa18 service and that not all offers will function without fault.
Declaration of consent
With the conclusion of the contract I consent to the collection and processing of my personal data for the above-mentioned purposes by Interdate S.A., 13 rue du Commerce L-1351 Luxembourg Luxembourg or by third parties that work in the name of and on behalf of Interdate S.A..
I have been informed that Interdate S.A. will log my consent.
In addition, I have been informed that personal data regarding my person that are collected in the framework of the above-mentioned purposes will be processed in compliance with the General Data Protection Regulation (GDPR).
I have been informed that processing of my data takes place on a voluntary basis, and that I may refuse my consent to the processing of my data or revoke it at any time with effect for the future without any disadvantage to myself.
To revoke consent, it is sufficient to send an email stating the email address registered with Interdate S.A., the country whose Lisa18 service the customer uses, and the user name (alternatively: the assigned contact ID) to:
I have been informed that I can send my revocation by fax to: 00 1 315 87 69 121 or by post to Interdate S.A., Lisa18 Customer Service / Revocation of Consent or Data Correction, 13 rue du Commerce L-1351 Luxembourg Luxembourg.
Consent to the processing of data for advertising purposes
I consent to Interdate S.A. sending me information on new or supplementary products customised for me personally. This also includes advertising from partner companies of Interdate S.A..
I have been informed that I may revoke my consent to the storage of my data and their use for transmitting advertising with effect for the future at any time without any disadvantage to myself and at no charge. To do this, it is sufficient to send an email to firstname.lastname@example.org, stating the email address registered with Interdate S.A., the country whose Lisa18 service the customer uses, and the user name (alternatively: the assigned contact ID)