Privacy Policy

To find a suitable partner for you requires collecting personal information to process and use. As a reputable dating service we at ELITESINGLES place a great emphasis on the responsible use and protection of your personal information. Therefore, we have established a comprehensive system of technical and organisational measures that provide maximum personal information security:

· For example, all the personal information that you send to us after registration or Login (e.g. contact information, profile information, payment information when ordering a paid membership) is SSL-encrypted (Secure Socket Layer)

· Firewalls protect the information from unauthorised access

· Access to your information is granted only to a few selected and properly trained personnel and only in certain cases (see also point 2 personal information security and encryption in this document)

Since the contact with other ELITESINGLES users is always made via a private messaging system, at no point will your personal contact details such as email address or full name be transmitted. So only you can decide for yourself if and when you provide such information to your ELITESINGLES contacts. For this, we advise you to heed our guide to safe dating on the Internet

Table of Contents

1. The protection of your personal information at ELITESINGLES.

2. Personal information security and protection.

3. Collection, processing and use of personal information at ELITESINGLES.

4. Consent and right to objection.

5. Your right of access, rectification, cancellation.

6. Further information.

1. The protection of your personal information at ELITESINGLES

The website is operated by Spark Networks Services GmbH, Kohlfurter Street 41/43, 10999 Berlin, Germany.

To operate the ELITESINGLES website, personal information is collected, processed or utilised. We do not collect your personally identifying information unless you knowingly provide the information (for example, if you register as a user of the website).

We are committed to protecting your privacy and to complying with the National Privacy Principles in the New Zealand Privacy Act. For more information about the National Privacy Principles, please see the link below.

http://www.privacy.org.nz/the-privacy-act-and-codes/privacy-principles/

In the following we would like to explain in more detail how we ensure the protection of your personal information and what personal information will be used in what way if you decide to use ELITESINGLES.

If you have questions or concerns on this, our customer service is at your disposal at any time. You can reach our customer service at:

Spark Networks Services GmbH- ELITESINGLES

– Customer Care –

Kohlfurter Street 41/43

10999 Berlin, Germany

Fax: +49 (30) 868 000 311

email: [email protected]

2. Personal information security and protection

All information you submit at registration or login to us (e.g. contact information, profile information, payment information when ordering a paid membership) is encrypted. This encryption protects the confidentiality of personal information exchange between you and our web server, and helps to prevent misuse of personal information, e.g. by interception. The encryption technique we use SSL (Secure Socket Layer). It is an accepted and widely used technology. In view of our personal information bases all technical precautions have been taken to save your personal information in a secure environment. Access to your information is limited to only a few selected employees and will be granted only for purposes of quality control and review of complaints and for thwarting fraud.

3. Collection, processing and use of personal information at ELITESINGLES

ELITESINGLES is a serious matchmaking service on the internet that brings people together who are looking for a long-lasting relationship via a scientifically-based matching method. To provide this service, we collect, process and use a range of personal information. In many cases, personal information is only used in pseudonym form or anonymously. A more detailed description on this topic can be found below.

(a) WithoutRegistration

When you visit the public pages of ELITESINGLES that are accessible without registration, we need and we collect no personal information from you. When you visit our website, we store personal information by default, but without reference to:

· IP address (Internet Protocol address) of the accessing computer

· The website from which you visit us (referrer)

· The sites that you visit from our

· The date and time of your visit

· The type of browser settings

· Operating System

This personal information is used by us for statistical purposes without reference to individuals.

(b) With Registration

If you want to use the services of ELITESINGLES described in detail in the ELITESINGLES Terms and Conditions, we need some personal information from you in order to provide the desired service.

We only use the personal information that you actively provide us (e.g. contact information for the registration, profile information or photos). In many cases, you can decide what personal information you reveal about yourself in the context of profiling and / or search. Personal information that is strictly necessary for the provision of the contract is always marked separately as required (e.g. email address) so that you know what information you need to enter for the use of the service and what you can do without.

For more detailed information please see below. To learn more about the exact procedure and the method of matchmaking, please note our detailed information in the ELITESINGLES Help page.

(aa) With the free registration you will be prompted to provide the following details without which a registration cannot be completed:

· Gender

· Gender of the partner you are seeking

· E-mail address

· Password

Our scientific personality test follows after registration. First, we ask for the following information to identify suitable partners:

· Postcode

· Date of birth

· Height

· Marital Status

· Education

· Occupation

· Income

During the personality test you will be asked to answer a series of personal questions (eg. partner preferences, personal characteristics and desired traits in a partner). Information such as ethnicity or religion is called sensitive personal data, which is subject to increased legal protection and protected by us with increased technological care. Without your consent, this information may not be divulged. We collect this data and other profile information (eg. interests and preferences), because they are the basis of our matching service and the basis of your ELITESINGLES profile. Direct contact information (eg. e-mail address, postal code) does not appear on the profile and is therefore not visible to other members.

(bb) If you purchase an ELITESINGLES Paid Membership, the following personal information is collected during the payment process:

· First and Last Name

· Bank account details or credit card information

· Home address

Your payment data is processed by our payment service provider Adyen GmbH, Hackescher Markt 4, 10178 Berlin, Germany (“Adyen”). To facilitate payment processing your payment information is stored and made available when making further orders of premium memberships. The payment data is available only after the initial payment is completed, and is shown shortened for your protection. Of course you can add new payment methods for checkout. For questions or concerns, and to enforce the Clause 5 rights listed, please call the number below Clause 5. The provided EliteSingles contact information.

(cc) To log in on ELITESINGLES you use your specified e-mail address and your chosen password. During every visit to the ELITESINGLES service, utilisation personal information are forwarded by your Internet browser and stored in log files called Server Log Files. These personal information are:

· IP address (Internet Protocol address) of the accessing computer

· User ID on the ELITESINGLES platform

· Name of the page

· Date and time of access

· The referrer URL from which you came to the requested page

· Amount of personal information transferred

· Status indication whether download was successful

· Session Cookies

· Session identification number

These personal information will be evaluated anonymously by us for statistical purposes. We hereby notify you that we carry out statistical analysis on opening and viewing behaviour of our emails. This is done with the help of small graphics that are embedded in the messages (called pixels). If you do not wish to have your viewing behaviour analyzed, you can disable graphics by default in your email client. For more information, please see instructions offered in your email client, i.e. Microsoft Outlook or Mozilla Thunderbird. Once images are deactivated, the messages are not displayed in full, and message functionality may be limited.

(dd) The use of personal information for the provision of the ELITESINGLES service:

The collection of personal information at ELITESINGLES is done principally with the aim of giving the customer a safe, smooth, efficient, and personal use of the ELITESINGLES service. The personal information are therefore used to provide the services requested and desired by the customer. However, they also serve to detect and investigate potentially prohibited or illegal activities, and for the enforcement of the Terms and Conditions and the contract.

In the following, the use of personal information is described in more detail:

· Other members can see your profile information and entries on the ELITESINGLES page. Premium members can also see the photos you upload on ELITESINGLES.

· Your profile – and thus your profile information and uploaded photos – is suggested to other members as part of our matching method. The matching can be switched off in your account. When switched off, your profile will not be suggested to any other members and at the same time you do not get any partner suggestions.

· Other members can see when you visit their profile page. Conversely, you can also see which members have visited your profile. This is an essential element of the contact between members. In general it is an important part of the services of social networking sites, and thus the service of ELITESINGLES. Therefore, this cannot be turned off via the user account.

· Other members can send you messages. However, at no point does ELITESINGLES give out your e-mail address. Messages are only sent through your ELITESINGLES mailbox. You can always “block” undesirables if you want to make it so they can no longer contact you.

· Email notifications: ELITESINGLES sends various notifications on every registered user.

In the context of customer relationship and customer service messages we will inform you if, for example, other members have visited your profile, you have been sent a message, been smiled at or if there are new members that fit your search criteria. You can always disable these service messages on your user account under message options.

We also send you ELITESINGLES information and special offers, such as tips and useful information about the partner search, surveys and special offers for your ELITESINGLES membership. You can disable the ELITESINGLES info and special offers messages with your user account under message options.

Information messages pertaining to the service, such as the confirmation of customer service and information on the release of images and texts, and on the conclusion of a paid membership, in the form of contract documents, payment processing information, etc., are part of our service and therefore cannot be cancelled.

We would also like to inform you via e-mail about ELITESINGLES Partner offers and events. To protect you and ELITESINGLES from abuse, we introduce in this newsletter, the so-called “double opt-in” procedure, i.e. you only receive the newsletter, if you have ordered it by e-mail or in your user account and confirmed your email address. You can unsubscribe at any time by deactivating this either in the message options, or by following the unsubscribe process in the newsletter.

If you change your message options, it can take up to 48 hours before it is active. Nevertheless, depending on the message options, the cancellation is still successful, and after this period you will receive no additional messages from us.

· ELITESINGLES sets a filter to protect users from unsolicited mail. For example, automatic filters prevent the sending of messages with certain pay numbers or certain inappropriate keywords.

· “Like” feature: Under the photos and entries of other profiles there is a “Like” button that can be clicked. With the “Like” function, you can express that you like statements or pictures in the profile of another member with one click. As a consequence, the other member is notified. In your own profile you can see how many members like a particular text field or photo of you. You can also see which members have clicked “Like” on a certain profile element.

· “Message Read”: Premium members can use this function to detect whether their messages have been clicked on by the recipient. When a message is clicked by the recipient, the sender gets a message about the time it was accessed. You can disable this feature allows in the user account.

· Import photos from Facebook: If you have a user profile on Facebook, you can transfer photos from this profile to your ELITESINGLES profile. To do this you must click on the appropriately labeled button to connect to Facebook and log in there with your Facebook user personal information. After successful login a window will appear were all your Facebook user account pictures are stored. You can select up to 24 photos and import them into your ELITESINGLES profile.

· Personality Profile: In order to find suitable partners among other ELITESINGLES members, an individual personality profile is created for each ELITESINGLES member using the answers given in the ELITESINGLES personality test. You can find this personality profile in your profile as a separate menu item. It can be seen both by yourself, as well as by other members. It covers five major dimensions of your personality and, in addition, three related sub-dimensions (“facets”). Basic and Premium Members only see the results of the main dimensions.

For additionalinformation about the expiration of the service in general, and answers to other questions about ELITESINGLES, see our detailed descriptions on the ELITESINGLES Help page.

(c) Personal information Transfer to Third Parties

When we transmit personal information in the framework of the provision of the service to other members, this is only in connection with the user name you choose. Under no circumstances do we share with other members direct contact information (such as your name, your address, or your e-mail address). Communication at ELITESINGLES is exclusively done via your internal mailbox so that you can decide for yourself to whom you disclose your contact details. Some personal information that you specified when creating your ELITESINGLES profile are always visible to other registered users. These personal information include age, gender, height, ethnicity, religion, occupation, smoking habits and children.

You can decide on the settings on your account, whether you want to continue to have your profile suggested to other members through our matching process.

Personal information will only be passed on to third parties if necessary to provide the service offered (e.g. payment processing for fee-based memberships), and if you have given us your consent or disclosure in accordance with relevant statutory provisions that are required or permitted (e.g. if we have to comply with a request, a governmental investigative or security agency). An overview of possible third parties resulting is available in our Public Register.

In addition to internal ELITESINGLES checks, outsourced partners including Apollo Solutions Ltd., Informatics Park, La Tour Koenig, Pointe aux Sables and Mauritius (“Apollo Solutions”) also check uploaded photos of ELITESINGLES members for authenticity to ensure a high quality of service and to protect our members from scammers.

(d) Use of Cookies

ELITESINGLES uses “cookies” to make your interaction with the platform individually identifiable and optimised. A cookie is a text file that is either stored temporarily in the computer’s memory (“session cookies”) or saved on the hard drive (“permanent cookie”). Cookies contain e.g. Information about your previous requests to the appropriate server or information on what offers have been made so far. Cookies are not used to run programs or deliver viruses to your computer. The main purpose of cookies is to provide a tailor-made offer and make the use of the Service as comfortable as possible.

Most browsers are initially set to accept cookies. However, you can configure your browser so that it rejects or requests you to confirm the acceptance of cookies. If you choose to decline cookies, however, this may have the consequence that not all of our offerings are available to you.

ELITESINGLES uses session cookies, partner and affiliate cookies and permanent cookies.

· Session Cookies: ELITESINGLES mostly uses “session cookies”, which are not stored on your hard drive and are deleted when the browser is closed. Session cookies are used for login authentication and to balance the system load.

· Partner and Affiliate Cookies: ELITESINGLES use these cookies if you access our services via an external advertising space. These cookies are used to settle accounts with the cooperation partners and do not contain personal information from you.

· Permanent cookies: ELITESINGLES uses “permanent cookies” to save your personal use settings. This allows for personalisationand improves the ELITESINGLES service, because you are able to find your personal settings again on subsequent visits.

(e) Use of (Google) Universal Analytics

ELITESINGLES analyses members’ online behavior. We create anonymous user profiles in order to improve our service to you. For this we use Google Analytics, among other things (with the feature Universal Analytics), a web analytics service provided by Google Inc. 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”), but with the extension “_anonymizeIp ()”. Only the shortened IP addresses are processed, excluding direct reference to individuals.

The information generated by the cookie about your use of the website (including your IP address) will be transmitted to a Google server in the USA and stored there. Google will use this information to evaluate your use of the website, compiling reports on website activity for website operators and providing others with website and internet related services. Google may also transfer this information to third parties unless required by law or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser. We point out, however, that you may not be able to use all features of this website in this case. By using this site, you agree to the processing of data about you by Google in the manner described above and for the aforementioned purpose.

You can object to the collection and analysis of your use of the Service Google Universal Analytics. Please use the browser add-on to disable Google Universal Analytics.

For more information on Terms of Use and Privacy Policy can be found at:

www.google.com/analytics/terms/gb.html

http://www.google.com/intl/en/analytics/privacyoverview.html

(f) Use of Goodle DoubleClick

ELITESINGLES uses the remarketing technology of Google (Google DoubleClick). Through this technology users who have already visited the ELITESINGLES site and have shown interest in the service, are again targeted with advertising on the pages owned by the Google partner network. These advertisements are different to those aimed at users who have not shown interest in the ELITESINGLES services. The ad overlay is done through the use of cookies, which are small text files that are stored on the user’s computer. With the help of text files, user behavior can be analyzed when you visit the site and then used for targeted product recommendations and interest-based advertising.

If you prefer not to receive interest-based advertising, you can disable the use of cookies by Google for these purposes by configuring the deactivation settings https://www.google.com/settings/ads/onweb/ or install the plugin available there.

(g) Use of Facebook Social Plugins

ELITESINGLES uses social plugins (“plugins”) provided by the social network facebook.com, operated by facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (“facebook”). These plugins are identified by a facebook logo. If you use a social plugin on an ELITESINGLES site, your browser establishes a direct connection with the Facebook servers. Facebook then transmits the plugin content to your browser, and then integrates it into the website.

Thereby facebook obtains the information that you have accessed on the corresponding ELITESINGLES page. If you are logged in to facebook, facebook can assign the ELITESINGLES visit to your Facebook account. If you interact with the facebook plugins (e.g. press the “Like” button), the corresponding information is transmitted from your browser to Facebook and stored there. For the purpose and scope of personal information collection and the further processing and use of personal information by facebook, and your rights in this respect and settings options for protecting your privacy, please refer to the privacy policies of facebook.

If you do not want facebook to collect personal information of this kind, we recommend that you log out before your visit ELITESINGLES on facebook.

(h) Use of Google+ Social Plugins

ELITESINGLES uses the “+1” the social network Google Plus, which is operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA button (“Google+”).

When you visit a page of our website that contains a social plugin, your browser establishes a direct connection to the servers of Google. The contents of the “+1” button is transmitted from Google directly to your browser which embeds the latter into the website.

We therefore have no impact on the amount of data collected with the Google+ button.

According to Google, no personal information is collected without clicking on the button. The IP address is only collected from members who are logged in.

Information on the purpose and scope of data collection, further processing and use of data by Google as well as your rights in this respect as well as settings options for protecting your privacy, can be accessed using the Google privacy policies. Click on the “+1” button and the corresponding FAQ (eg https: // support. google.com/plus/answer/1319578 refer).

If you do not want Google+ to collect data about you, we advise you to log out of Google+ before your ELITESINGLES visit.

(i) Use of twitter Social Plugins

ELITESINGLES continues to use social plugins (“plugins”) from the social network twitter.com, operated by Twitter Inc., 795 Folsom St., Suite 600, San Francisco, CA 94107, USA. The plugins are marked with a Twitter logo. When you select an ELITESINGLES website that contains a social plugin, your browser establishes a direct connection with the Twitter servers. Twitter transmits the contents of the plugin directly to your browser, which integrates it into the website. This gives Twitter the information that you have accessed on the corresponding page ELITESINGLES. If you are currently logged into Twitter, Twitter can assign your visit to your Twitter account. If you are using the Twitter plugins to interact (eg. a tweet to an article post), the corresponding information is transmitted from your browser directly to Twitter and stored there. Purpose and scope of data collection and the further processing and use of data by Twitter as well as your rights in this respect and settings options for Protecting your privacy can be found in the Twitter Privacy Policy under https://twitter.com/privacy.

If you do not want Twitter to collect data about you, we advise you to log out of Twitter before your ELITESINGLES visit.

(j) Checking and verification of personal information

In order to protect our customers from people who abuse the ELITESINGLES service, we analyse the platform and consider customer input for plausibility using various automated monitoring tools in addition to the internal monitoring done by our customer care agents. However, ELITESINGLES does not assume responsibility or a legal obligation in doing this. Also, certain character string or logins of different members, for example, those which originate from the same computer, can result in the blocking of suspicious activity.

ELITESINGLES reserves the right to enforce an automated filtering of messages. Here certain word lists and personally written texts are checked for their compliance with our terms and conditions. For example pornographic or offensive words and texts are automatically matched with customers and blocked. We also try to protect our members from scammers by undertaking anti-scamming checks.

Should a suspicion of abuse of the ELITESINGLES service arise from these checks, the legal consequences for members are listed in the general Terms and Conditions. ELITESINGLES can also prevent the acceptance and delivery of incoming and outgoing messages, if there is high probability that it is a message containing any illegal and / or content in defiance to the terms and conditions. A notice of rejected or non-delivered messages is not carried out

4. Consent and right to objection

If we use personal information for a purpose, which by provisions of law requires your consent, we will always ask for your explicit agreement and record your consent.

You can revoke your given consent at any time and/or object to future use of your personal information.

To revoke consent or make an objection a simple message to us is sufficient. For this you can use the following contact information:

Spark Networks Services GmbH

Kohlfurter Street 41/43

10999 Berlin

E-Mail: [email protected]

Fax: +49 (30) 868 000 311

Please note that in case of an objection against the use of certain personal information, it may be impossible to provide some or all of the services we offer on the ELITESINGLES platform. We are at your disposal for any questions about this.

5. Your right of access, rectification, cancellation

You have the right at any time to receive information about the personal information and settings we store for your account, and to ask these to be corrected or deleted.

Your right to erase personal information may be limited by legal retention requirements that we need to consider. In addition, courts, law enforcement agencies or other authorities can demand by law to retrieve personal information or request information.

For information, correction or deletion requests please contact us with your name, your e-mail address and your user name at the following:

Spark Networks Services GmbH

Kohlfurter Street 41/43

10999 Berlin

email: [email protected]

Fax: +49 (30) 868 000 311

Much of the information you can also see yourself directly and conveniently in your account and those that you see you can also change or delete yourself.

6. Further information

Any Internet user should be aware that the information provided by them and published online can be accessed and saved worldwide by other Internet users. ELITESINGLES expressly points out to the user that the protection of personal information transmission in open networks like the Internet according to current technology can never be absolutely guaranteed. Therefore you always need to be aware that you are moving in a public space and please treat your private space responsibly.