PRIVACY POLICY
We care deeply about protecting your privacy and are committed to making PURE a product that people love and trust. This document outlines how we use and the circumstances in which we may disclose the personally identifiable information (which we call “Personal Data”) and other information that we collect.
PURE is the Data Controller and is committed to protecting the rights of its users in line with the Data Protection Law, including the European General Data Protection Regulation 2016/679 (“GDPR”) and any other data protection and/or privacy legislation, regulation or guidance applicable to the Service.
In this Privacy Policy, we use the terms “PURE”, “we”, “us” and “our” to refer Online Classifieds AG, 74 Steinhauserstrasse Str., Zug, Switzerland (the company that makes PURE). “Service” includes any websites or applications we operate, including this website and the PURE mobile app. “You” or “your” refers to users (data subject) of our Service.
WHAT INFORMATION DO WE COLLECT?
When you use our Service we may collect Personal Information and other information from you, as described below:
PERSONAL DATA. We collect Personal Data from you when you voluntarily provide such information, such as when you create an account, add information to you user profile, or contact us with inquiries.
We normally collect and process the following categories of information:
- Identity date, such as Gender identity;
- Contact details: Email address;
- Sexual preferences;
- Photographs;
- Location;
Please note that with regard to the processing of sensitive information about you, such as your sexual orientation/preference (special categories of data), you are voluntarily providing such information and are explicitly consenting to the processing of this information by PURE. You may withdraw your explicit consent at any given time.
By voluntarily providing us with Personal Data, you are consenting to our use of it in accordance with this Privacy Policy and agreeing that it may be transferred to the offices and servers of PURE and the authorized third parties referred to herein, located in the United States.
NON-IDENTIFIABLE OR AGGREGATED INFORMATION (analysis and statistic purposes). When you use our Service, we also receive and store certain non-identifiable personal information. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. PURE may store such information itself or such information may be included in databases owned and maintained by PURE affiliates, agents or service providers. We may use such information and pool it with other information to track, for example, the total number of visitors to our Service, the number of visitors to each page of our Site, the domain names of our visitors' Internet service providers, and how our users use and interact with the Service. At times, PURE also conducts research on its customer demographics, interests and behavior based on the Personal Information and other information provided to us. This research will be compiled and analyzed on an aggregate basis. PURE may share this non-identifiable and aggregate data with its affiliates, agents and business partners, but this type of non-identifiable and aggregate information does not identify you personally. PURE may also disclose aggregated user statistics in order to describe our Services to current and prospective business partners, and to other third parties for other lawful purposes.
In order to that, we may use a technology called “cookies” to help provide additional functionality and analyse Site usage more accurately. You will always be provided with the option to choose (consent) which categories of cookies we should use on your device You can disable and change your cookie settings via your web browser.
A NOTE ABOUT LOCATION: Our Service is designed to help you learn more about other people nearby, and we use your location information (e.g., by using the GPS on your mobile device) to provide the functionality of our Service. This will be enabled only if you agree to give permission to PURE to access your location. You can disable this at any given time by changing your location permissions on your phone. Please keep in mind that when you use the service other users can see this information about you, and they may use it or disclose it to other individuals or entities outside of our control and without your knowledge. Your information may be subject to abuse, misuse, and monitoring by others, and you share this information at your own risk.
HOW AND WHY USE YOUR INFORMATION?
We use the Personal Data you provide in a manner that is consistent with this Privacy Policy. For example, we may use it:
— to provide the core functionality of the Service (e.g., displaying your request to people nearby);
— to monitor your use of the Service and improve the user experience;
— to respond to your comments and inquiries;
— to communicate with you regarding the Service;
— and for any other purpose for which the information was provided.
Your Personal Data are processed by PURE only if at least one of the following legal bases apply:
a) It is necessary for us to process your Personal Data in order to provide the Service and thus carry out our obligations under the terms and conditions of the Service (e.g. create user profile, receive payment, provide the Service in accordance with the description under the terms and conditions)
b) You have provided your consent (e.g. direct marketing, data transfers to the USA or other countries outside the EEA, explicit consent for processing special categories of data (see above).
c) It is necessary to process your Personal Data in order to pursue our legitimate business interests provided that your rights and freedoms do not override those interests (e.g. protecting our Service, enhancing our Service functionality and efficiency)
d) It is necessary to process your Personal Data in order to comply with our legal obligations (e.g. tax law and/or other regulatory requirements)
WHAT INFORMATION DO WE SHARE WITH THIRD PARTIES?
The following are certain circumstances in which we may share your Personal Information with certain third parties without further notice to you:
- in the event of a corporate sale, merger, reorganization, dissolution or similar event;
- with service providers we work with in connection with the operation of the Service, such as email or database providers;
- with our corporate affiliates or subsidiaries for the purpose of providing the Service;
- with consultant/platform providers for anti-spam and anti-fraud purposes;
- and if required to do so by law or in the good faith belief that such action is necessary to comply with a legal obligation, protect and defend the rights or property of PURE, protect the users’ data and safety of the site, or protect against legal liability.
We may engage and contract with third party companies (e.g., service providers) to provide services that help us with our business activities such as cloud hosting services. These third-party service providers are limited to only using information as instructed to provide contracted services to us.
We may generally engage and contract with such third-party companies (e.g., service providers) to provide services that help us with our business activities such as cloud hosting services or user verification services. These third-party service providers are limited to only using information as instructed to provide contracted services to us and are under contractual obligation to protect your Personal Data in accordance with Data Protection Law.
YOUR CONTROL
You can use the Site without providing any Personal Data. If you choose not to provide any Personal Data, you may not be able to use certain parts of the Service.
SECURITY
We are committed to ensuring that your information is secure. In order to prevent unauthorized access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.
YOUR RIGHTS
PURE will respect your legal rights to your data. We shall, to the extent legally permitted, promptly notify You if We receive any requests from You to exercise the following your rights:
THE RIGHT TO BE INFORMED
— We are publishing this Privacy Policy to keep you informed as to what we do with your Personal Data. We strive to be transparent about how we use your data
THE RIGHT TO ACCESS
— You have the right to access your information. Please contact us if you wish to access the Personal Data we hold about you
THE RIGHT TO RECTIFICATION
— If the information PURE holds about you is inaccurate or not complete, you have the right to ask us to rectify it. If that data has been passed to a third party with your consent or for legal reasons, then we must also ask them to rectify the data. Please contact us if you need us to rectify your information.
THE RIGHT TO ERASURE
— This is sometimes called ‘the right to be forgotten’. If you want Us to erase all your personal data and we do not have a legal reason to continue to process and hold it, please contact us
THE RIGHT TO RESTRICT PROCESSING
— You have the right to ask Us to restrict how we process your data. This means We are permitted to store the data but not further process it. We keep just enough data to make sure we respect your request in the future. If you want Us to restrict processing of your data, please contact us
THE RIGHT TO DATA PORTABILITY
— PURE must allow you to obtain and reuse your personal data for your own purposes across services in a safe and secure way without this effecting the usability of your data. Please contact us if you want information how to port your data elsewhere/ This right only applies to personal data that you have provided to Us as the Data Controller
THE RIGHT TO OBJECT
— You have the right to object to PURE processing your data even if it is based on Our legitimate interests, the exercise of official authority, direct marketing (including data aggregation), and processing for the purposeless of statistics. If you wish to object please contact us
THE RIGHT TO WITHDRAW CONSENT
— If you have given Us your consent to process your data but change your mind later, you have the right to withdraw your consent at any time, and we will stop processing your data. If you want to withdraw your consent, please contact us
Please note that the above-mentioned rights are not absolute. These rights are subject to exceptions and their applicability will largely depend on the legal basis we are relying in each case and the various circumstances of the request.
CHILDREN’S INFORMATION
PURE does not knowingly collect Personal Data from children under the age of 14. If you are under the age of 14, please do not submit any Personal Data through the Service. We encourage parents and legal guardians to monitor their children's Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data on this Service. If you have reason to believe that a child under the age of 14 has provided Personal Data to PURE through this Service, please contact us immediately and we will endeavor to delete that information from our databases.
LINKS TO OTHER WEBSITES
This Service may contain links to other websites not operated or controlled by PURE. The policies and procedures we describe here do not apply to these third-party sites, nor do the links from this Service imply that PURE endorses or has reviewed these third-party sites. We suggest contacting those sites directly for information on their privacy policies.
STEPS WE TAKE TO PROTECT YOUR PRIVACY
PURE takes reasonable steps to protect the Personal Data provided via the Service from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet, email or other electronic transmission is ever fully secure or error free, so you should take special care in deciding what information you send to us in this way.
DATA TRANSFERS
As part of the services offered to you through this website, the information which you provide to us may be transferred to countries outside the European Economic Area (“EEA”). By way of example, this may happen if any of our servers are from time to time located in a country outside of the EEA. These countries may not have similar data protection laws.
If we transfer your information outside of the EEA in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this Policy.
If you use our services while you are outside the EU, your information may be transferred outside the EU in order to provide you with those services.
NEWSLETTER AND MARKETING COMMUNICATIONS
On PURE, users can opt to receive newsletters and commercial communications.
PURE always collects the explicit, free and unambiguous consent of users prior to submitting newsletters and marketing communications to these users or, more in general, before undertaking electronic marketing initiatives dedicated to them.
In such cases, users may be invited to submit personal information in addition to their e-mail address (e.g., gender, country of residence, etc.) for the purpose of having newsletter and marketing communications tailored to the user profile.
Users can always easily withdraw their consent from receiving newsletters and commercial communications in the following ways:
- By clicking on the ‘unsubscribe’ link in any of such email;
- By contacting our Customer service.
With respect to personal information of non-registered users who have opted to receive newsletters and marketing communications, PURE acts as the sole Controller.
CHANGES TO PRIVACY POLICY
We may occasionally modify this Privacy Policy. When we do, we will let you know by changing the “last updated” date within this Privacy Policy, and your continued use of the Service shall indicate your agreement with the terms of the revised Privacy Policy.
COOKIES POLICY
In this Cookies Policy we explain the cookies which Pure uses, the purposes for which cookies are used and how you can manage your preferences in relation to cookies.
WHAT ARE COOKIES
We collect information by placing cookies on your computer or mobile phone. A cookie is a piece of text stored on your computer or mobile phone by your web browser. They are basically a tool that stores information about website visits, recognises you and your preferences each time you visit Pure, and ensures site functionality enabling us to provide the services our members request.
When you visit the publicly available sections of Pure, cookies which are necessary to make our application/site work (referred to as "strictly necessary" cookies) are placed on your device or mobile phone. We may use persistent tracking cookies (also known as local storage devices), mainly for security protection purposes, such as to prevent fishers, scammers and unauthorised login attempts.
You may set your browser and your mobile phone settings to block cookies and local storage devices, but if you do so, you may not be able to access the features that Pure offers.
WHY DO WE USE COOKIES?
We use of cookies and local storage devices falls into the following categories:
- those that are strictly necessary to deliver the services and products you have requested. It is not possible to turn these cookies off because they are essential to enable us to provide the service that you have requested;
- cookies related to the performance of Pure, such as analytics that help us determine how our site is performing and ensure a smooth and trouble-free experience for our members and visitors.
Below is a list to explain Pure's cookie functions and why they're used.
- Analytics and research: Pure uses Google Analytics and Yandex Metrica to collect information about how visitors use the our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. For more information about Google's privacy policy, please visit http://www.google.com/intl/en/policies/ and https://yandex.com/legal/confidential/?lang=en
- Security and site integrity: We use cookies and other devices, such as CAPTCHAs, to help keep Pure and our members safe and secure.We may use persistent cookies, which will help us to ensure we have identified the same device is logging in to the correct account. These types of cookies also help with our anti-spam measures and may help us to prevent phishers, scammers, unauthorised login attempts to your account and accessing any hacked accounts.
- Performance: We need to use certain cookies and local storage devices to ensure our members have the best possible experience, such as assisting with your navigation of our site, ensuring pages load up quickly and respond faster to your requests for Pure services.
Our use of cookies and local storage devices, including the specific cookie names, may change over time, but will generally fall into the above categories. We will notify you of any important changes to our use of cookies and local storage devices. If you would like to know more about cookies, the following websites provide useful information:
QUESTIONS
Again, if you have feedback, comments, or questions about this Privacy Policy you can contact us anytime at [email protected].
The data protection officer for PURE services can be contacted at [email protected] .
Updated on 24.10.2022