Privacy Policy

Last updated: Feb 20, 2024

At Livejoy App ("Livejoy," "we," "us," or "our"), we are committed to protecting your privacy and ensuring that you have a thorough understanding of how your personal information is collected, utilized, and shared. This Privacy Policy, integral to our Terms of Use available here, governs your interaction with our products and services, collectively referred to as the "Service." By using the Service, except where explicit consent is otherwise required by law, you acknowledge and consent to the practices described in this Privacy Policy.

Table of Contents

  1. Controller
  2. What Data We Get
  3. Purposes for Processing Your Data
  4. How We Share Information
  5. Your Rights
  6. Data Retention
  7. Data Protection and Security
  8. Children’s Privacy
  9. International Transfer Policy
  10. Privacy Policy Changes
  11. Contact Us

1. Controller

  • Controller: The controller of data processing is Livejoy. You can contact us via e-mail under Contact Us.
  • Data Protection Officer: Our data protection officer (DPO) can be contacted using the email address. Should you have any questions regarding the processing of your personal data, please do not hesitate to contact our DPO.

2. What Data We Collect

We process personal data that you, as a user of Livejoy, make available to us, for example, by using our Products and that users provide to us (“Data”). We also process information through your use of Livejoy, for example, access logs, as well as information from third parties, like when you access our services through another social media account. We also collect some data automatically, like information about your device and what parts of our Services you interact with or spend time using.

Types of Data Purpose/Usage How We Collect Legal Basis Storage/Retention
Account Data Identify users and manage accounts Directly from users. Contractual necessity (GDPR 6.1.b) Until account deletion or 10 years of inactivity, then deleted or anonymized.
Profile Data User interaction and service personalization Directly from users. Contractual necessity (GDPR 6.1.b) Until account deletion or 10 years of inactivity, then deleted or anonymized.
System Data Service functionality and analytics Automatically through the app. Legitimate interests (GDPR 6.1.f) Until account deletion or 10 years of inactivity, then deleted or anonymized.
Usage Data Enhance app features and functionality Automatically through app interaction. Legitimate interests (GDPR 6.1.f) Until account deletion or 10 years of inactivity, then deleted or anonymized.
Device Information Optimize app performance and experience Automatically through device usage. Legitimate interests (GDPR 6.1.f) Until account deletion or 10 years of inactivity, then deleted or anonymized.
Geographic Data Service personalization and targeted content Automatically through device usage. Legitimate interests (GDPR 6.1.f) Until account deletion or 10 years of inactivity, then deleted or anonymized.
Other Partner Data Analyzing advertising campaign success Through partners and tools. Contractual necessity and legitimate interests (GDPR 6.1.b and 6.1.f) Until account deletion or 10 years of inactivity, then deleted or anonymized.
Advertising Data Serve personalized ads; Serve advertisements on third-party networks and measure the effectiveness of such ads Age, gender, profile info from users; location data from devices. We obtain other information from the device or browser that you use to access the service Consent obtained for personalized ads. Legitimate interests for targeting ads; Consent for personalized ads, and Consent for Cookies. Until account deletion or 10 years of inactivity, then deleted or anonymized.
Analytics and Attribution Data (via MMPs) Optimize marketing and improve experience Through MMPs for tracking user interactions, purchases, and installation sources. Legitimate interests for marketing optimization and service improvement; Consent for analytics. Until account deletion or 10 years of inactivity, then deleted or anonymized.

2.1 Data You Provide to Us

  • Account Data: Includes your name, email address, date of birth, phone number, and password, and we assign you a unique identifying number (“Account Data”). You can manage your Account Data through app settings or contact support for assistance with updates or deletion requests.
  • Profile Data: Comprises information you choose to add to your profile for a richer user experience, such as profile photos and gender. Your Profile Data will be publicly viewable by others unless you delete your account.
    • To add certain content, like pictures or videos, you may allow us to access your camera or photo album.
    • Please note that Livejoy does not process sensitive data without your explicit consent and does not ask you to disclose such data for the rendering of our services. If you choose to disclose information on your profile that is “sensitive data,” such as posting about your ethnicity, religion, sexual orientation, etc., you will be considered to have consented to the processing of that data.
    • Gender Preference: While not directly processing sexual orientation, we collect your gender preference for chats to personalize your experience. This selection is based on legitimate interests to tailor our services to your preferences.
  • Usage Data: When you use our Services and features, we collect certain data, including; messages, follow information, photos, videos, gifts, audio data, and other user data.
  • Shared Content: Livejoy lets you interact with other users or share content publicly, which we process through the gifts you receive, videos you post, and the data you provide in your profile. Such shared content may be publicly viewable by others depending on where it is posted.
  • Data About Your Accounts on Other Services: We may obtain certain information through your social media or other online accounts if they are connected to your Livejoy account. If you log in to our Services via Facebook or another third-party platform, we ask for your permission to access certain information about that other account. For example, depending on the platform or service, we may collect your name, profile picture, gender, info, and birthday. Those platforms and services make information available to us through their APIs (Application Programming Interface.) The information we receive depends on what information you (via your privacy settings) or the platform or service decide to share with us. If you access or use our Services through a third-party platform or service or click on any third-party links, the collection, use, and sharing of your data will also be subject to the privacy policies and other agreements of that third party.
  • Data About Paid Service: All our paid service is through iOS or Android platforms. We only receive a receipt of your transaction provided by these platforms. For security reasons, we do not collect or store sensitive cardholder data, such as full credit card numbers or card authentication data.
  • Communications and Support: If you contact us for support or to report a problem or concern (regardless of whether you have created an account), we collect and store your contact information, your correspondence with us, and other data about you, such as your name, email address, location, operating system, IP address, and any other data you provide or that we collect through automated means (which we cover below). We use this data to respond to you and investigate your inquiry in accordance with this Privacy Policy.
  • Sensitive Information: According to GDPR, Sensitive Data is defined as: “All personal data including racial, political, religious, trade union membership, genetic, biometric, sexual orientation, and health details.“ Please be careful when posting sensitive details about yourself on your Profile, such as your religious denomination and health details. While you may voluntarily share this information on your Profile with the world, including us, including your sexual preferences and ethnic background, there is no requirement to do so. Where you choose to publically share sensitive data about yourself at your own discretion, this will constitute an exemption to the explicit consent requirement of the law. In other words, you will be considered to have explicit consent to our processing of your information if you make certain sensitive data public to other users.

2.2. Data From Others

In addition to the information you provide us directly, we receive information about you from others or by automated means, including:

  • System Data: Technical data about your computer or device, like your IP address, device type, operating system type and version, unique device identifiers, device language, browser, browser language, and other systems data, and platform types (“System Data”).
  • Usage Data: We collect information about your activity on our Services, for instance, how you use them (e.g., the date and time you logged in, features you’ve been using, search preferences, clicks, and pages that have been shown to you, referring web page address) and how you interact with other users (e.g., users, you connect and interact with, time and date of your exchanges, number of messages you send and receive, number of content you post).
    • Device Information: We collect information from and about the device(s) you use to access our Services, including hardware and software information such as IP address, device type, device-specific and app settings and characteristics, app crashes, browser type, version, and language, operating system, time zones, identifiers associated with cookies, or other technologies that may uniquely identify your device or browser.
    • Approximate Geographic Data: An approximate geographic location, including information like country, city, and geographic coordinates, calculated based on your IP address.
  • Other Partners: We may receive information about you from our partners, for instance, where our ads are published on a partner’s website and platform (in which case they may pass along details on a campaign’s success).

3. Purposes for Processing Your Data

The main reason we use your information is to deliver and improve our Services. Additionally, we use your info to help keep you safe. Read on for a more detailed explanation of the various reasons we use your information, together with practical examples.


To administer your account and provide our Services to you

  • Create and manage your account
  • Provide you with customer support and respond to your requests
  • Complete your transactions
  • Communicate with you about our Services, including order management and billing

To help you connect with other users

  • Analyze your profile and that of other users to recommend meaningful connections
  • Show users’ profiles to one another

To improve our Services and develop new ones

  • Conduct research and analysis of users’ behavior to improve our Services and content (for instance, we may decide to change the look and feel or even substantially modify a given feature based on users’ behavior)
  • Develop new features and services (for example, we may decide to build a new interests-based feature further to requests received from users).
  • Utilize analytics tools to analyze user behavior extensively, enabling us to understand how our Services are used and to identify areas for improvement. This includes tracking how users interact with our Services, which features are most engaging, and where users may encounter difficulties.

To prevent, detect and fight fraud or other illegal or unauthorized activities

  • Address ongoing or alleged misbehavior on and off-platform
  • Perform data analysis to better understand and design countermeasures against these activities
  • Retain data related to fraudulent activities to prevent recurrences

To ensure legal compliance

  • Comply with legal requirements
  • Assist law enforcement
  • Enforce or exercise our rights, for example, our Terms

To process your information as described above, we rely on the following legal bases:


Contractual Obligation to you: Most of the time, the reason we process your information is to perform the contract that you have with us. For instance, as you go about using our service to build meaningful connections, we use your information to maintain your account and your profile, to make it viewable to other users, and to recommend other users to you.


Legitimate interests: We may use your information where we have legitimate interests to do so. For instance, we analyze users’ behavior on our Services to continuously improve our offerings, we suggest offers we think might interest you, and we process information for administrative, fraud detection, and other legal purposes.


Marketing:

  • Push Message Marketing: With your explicit consent, we will send you marketing push messages.
  • Retargeting: With your explicit consent, you might see marketing messages on the platforms listed below. In addition, other users who have similar characteristics to you on those platforms could see marketing messages on those platforms as well (i.e., Facebook Lookalike audience). You can revoke your consent at any time via our customer support. It may take a few days after the opt-out until you are removed from all audiences.

Consent: From time to time, we may ask for your consent to use your information for specific reasons. You may withdraw your consent at any time by contacting us at the address provided at the end of this Privacy Policy.

4. How We Share Information

4.1 With Other Users:

You share information with other users when you voluntarily disclose information on the service (including your public profile). Please be careful with your information and make sure that the content you share is of a nature that you’re comfortable being publically viewable since neither you nor we can control what others do with your information once you share it.

4.2 With Our Service Providers and Partners:

We use third parties to help us operate and improve our Services. These third parties assist us with various tasks, including data hosting and maintenance, analytics, customer care, marketing, and security operations. These service providers (“Data Processors”) may access your personal data and are required to use it solely as our directions to provide our requested service.

We follow a strict vetting process prior to engaging any service provider or working with any partner. All of our service providers and partners must agree to strict confidentiality obligations and data protection agreements.

4.3 Marketing Services Providers:

We collaborate with Marketing Services Providers, such as social media platforms (e.g., Facebook), to market our App and services on third-party websites and applications, as well as to gauge the effectiveness of our advertising efforts. We share select data with these providers for purposes including, but not limited to:

  • Excluding existing users from campaigns targeting new user acquisition.
  • Targeting ads to individuals who have interacted with our services but have not created an account.
  • Creating Lookalike Audiences to find new users with similar characteristics to our existing users, enhancing ad relevance.
  • Developing Custom Audiences for targeted advertising, where we believe the audience may have an interest in specific advertisements.

Data Shared Includes:

Device ID: A unique advertising identifier assigned by your device's manufacturer, used for tracking ad interactions and conversions.

Estimated Location: Derived from your IP address to tailor geographic ad targeting.

Demographic Information: Age and gender for demographic targeting.

Interaction Data: Information on your interactions with our Sites or App, such as downloads, account creation, or purchases.

Hashed Email Address: Used for creating 'custom audiences' through a process that encrypts your email into a secure code, matching it with the Marketing Service Provider's user list to serve relevant ads.

Usage of Data by Providers: While we share data for specific campaign purposes, these third parties may use the collected data for their own objectives, such as aggregating it with other information for broader advertising insights.

4.4 When Required by Law:

We may disclose your information if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government/law enforcement investigation, or other legal requirements; (ii) to assist in the prevention or detection of crime (subject in each case to applicable law); or (iii) to protect the safety of any person.

4.5 To Enforce Legal Rights:

We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and the legal rights of our users, business partners, or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.

4.6 Monitor:

We employ/ freelance Moderators to monitor activity on the site/apps and approve content. We also partner with fraud prevention and anti-spam providers to protect the service from criminal activity.

4.7 Change of Control:

In the event that our Services or any of its affiliates undergoes a business transition or change of ownership, such as a merger, acquisition by another company, reorganization, or sale of all or a portion of its assets, or in the event of insolvency or administration, we may be required to disclose your personal data.

5. Your Rights

You have certain rights around the use of your data, including the ability to (1) opt-out of cookies, and the collection of your data by certain analytics providers; (2) edit/ update your account data from the App; (3) contact us to request access to your personal data (“right to access”), and; (4) You can request your personal data to be erased (“right to be forgotten”). We want you to be in control of your information, so we have provided you with the following tools:

  • Access / Update tools in the service: Tools and account settings that help you to access, rectify or delete information that you provided to us and that’s associated with your account directly within the service.
  • Device permissions: Mobile platforms have permission systems for specific types of device data and notifications, such as phone book and location services as well as push notifications. You can change your settings on your device to either consent or oppose the collection of the corresponding information or the display of the corresponding notifications. Of course, if you do that, certain services may lose full functionality.
  • Deletion: You can delete your account by using the corresponding functionality directly on the service.

We want you to be aware of your privacy rights. Here are a few key points to remember:

  • Reviewing your information:Applicable privacy laws may give you the right to review the personal information we keep about you (depending on the jurisdiction, this may be called right of access, right of portability or variations of those terms). You can request a copy of your personal information by sending us an email at [email protected].
  • Updating your information: If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion or object to its processing, please contact us via [email protected].

Please note that for any requests sent to us via email, including but not limited to accessing your data, we require you to undergo an authentication process to confirm your identity. This measure is in place to prevent unauthorized access to your personal information. As part of this verification process, we may request additional proof of identity, such as asking that you email us from the email address you used and verified when you registered with the App or that you send us a photo ID held next to your face before we can proceed with your request.

Keep in mind that we may reject requests for certain reasons, including if the request is unlawful or if it may infringe on trade secrets, intellectual property, or the privacy of another user. If you wish to receive information relating to another user, such as a copy of any messages you received from him or her through our service, the other user will have to contact our Privacy Officer to provide their written consent before the information is released.

Also, we may not be able to accommodate certain requests to object to the processing of personal information, notably where such requests would not allow us to provide our service to you anymore. For instance, we cannot provide our service if we do not have your date of birth.

  • Uninstall: You can stop further data collection by our app by uninstalling while using the standard uninstall process for your device. If you uninstall the app from your mobile device, we will no longer be able to further process data; however, the unique identifier associated with your device will continue to be stored. If you re-install the application on the same mobile device, we will be able to re-associate this identifier to your previous transactions and activities and continue processing data.
  • Accountability: In certain countries, including in the European Union, you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how we process your personal information. The data protection authority you can lodge a complaint with notably may be that of your habitual residence, where you work, or where we are established.

If you want to exercise any of your rights listed above please visit our feedback form or email us at [email protected].

6. Data Retention

We retain your personal data only as necessary for legitimate business purposes and legal compliance. Upon deleting your account, we initiate a process to erase your personal data, completed within a 30-day Safety Retention Window. During this period, some information may be retained for administrative purposes but will not be accessible or visible on our Services.

Please keep in mind that we reserve the right to delete any of your data that we believe violates our Terms of Service or Application Store guidelines (nudity, continuous IP change, children's privacy, etc.) at our sole discretion.

E-mail correspondence regarding your personal data will be retained for a longer time to allow us to deal with any follow-up queries you may have. In any case, they will be deleted within ten years if there are no ongoing queries.

Anonymized data for statistical and product research purposes is retained indefinitely, as it cannot be linked back to you after profile deletion.

Your information will be anonymized or deleted in the following instances:

  • Immediately after the Safety Retention Window post-account deletion.
  • Following ten years of inactivity, with inactivity defined by a lack of engagement with our Services or server connection. An account is considered inactive when the Application of the Member has not established contact with Livejoy’s servers (including due to the deactivation of the geolocation process), and the User has not used the Application. (In any event, the Account of a Premium Member will never be considered to be inactive.)

Exceptions to this policy are as follows:

  • Legal obligations that necessitate longer retention periods (e.g., data retention for one year to comply with statutory requirements).
  • Need for documentation to demonstrate legal compliance (e.g., keeping consent records for five years).
  • Unresolved issues, claims, or disputes that require retaining relevant information.
  • Fraud prevention measures or to enhance user safety, such as keeping data to prevent banned users from creating new accounts.

7. Data Protection and Security

At Livejoy, safeguarding your personal information against unauthorized access, alteration, disclosure, or destruction is a priority for us. Despite the rigorous measures we implement to protect your data, it is crucial to recognize that no technology company can guarantee absolute security. As such, the security of your account also relies on the strength and confidentiality of your password. We urge you not to share your password with anyone, and in the event that you suspect your password or account has been compromised, we advise you to change your password promptly and contact us at [email protected] with any concerns.

We proactively monitor our systems for potential vulnerabilities and threats and continuously review and enhance our data collection, storage, and processing practices, along with our physical, technical, and administrative security measures.

Should we identify or suspect a security breach, we reserve the right to temporarily suspend your access to the Services, either partially or entirely, without prior notice to protect the integrity of our network. If you believe your account or personal information has been compromised, please notify us immediately at [email protected].

Please be aware that our responsibility for virus protection and securing your data extends only to our service network. Consequently, we cannot be held liable for any loss, damage, or destruction of your data caused by external factors. Rest assured, any detected unauthorized access or attack will be addressed with the utmost seriousness, pursued under civil law, and, where necessary, through criminal prosecution.

In the unfortunate event of a data breach, we are committed to notifying the relevant EU authorities, our Data Protection Officer (DPO), and any users who may be directly or indirectly impacted within 72 hours of detecting the breach. Notifications and updates regarding the situation will also be made available on our website.

Legal Notice

Data Protection Officer: Naq Cyber B.V.;

Contact: Nadia Kadhim

Address: Vlamingstraat 4, 2712BZ Zoetermeer, Netherlands

Email: [email protected]

8. Children’s Privacy

Our Services are restricted to users who are 18 years of age or older. We do not permit users under the age of 18 on our platform, and we do not knowingly collect personal information from anyone under the age of 18. If you suspect that a user is under the age of 18, please use the reporting mechanism available through the App. If we become aware that a child, minor, or anyone under the age of 18 has registered with us and provided us with personal data, we will take steps to terminate that person’s registration and delete their profile from our App. If we delete your Profile because you violated our no-children rule, we may retain basic account and profile information to ensure that you do not try to get around our rules by creating a new profile.

9. International Transfer Policy

In order to provide the Services to you, we must transfer your data to our servers and process it there. By visiting our website or using our App, you consent to the storage of your data on servers. If you are using the Services, you consent to the transfer, storage, and processing of your data. Specifically, personal data collected in Switzerland and the European Economic Area (“EEA”) is transferred and stored outside those areas.

That data is also processed outside of Switzerland and the EEA by our Fepar companies, or our service providers, including processing transactions, facilitating payments, and providing support services as described in Sections 2, 3, and 4. We have entered into data processing agreements with our service providers that restrict and regulate their processing of your data on our behalf. By submitting your data or using our App, you consent to this transfer, storage, and processing by Fepar and its processors. We operate a global network of servers including in Germany, the Netherlands, Türkiye, and Canada. We ensure that the data is adequately protected by ensuring that valid, legal mechanisms are in place. If you want more information relating to the nature of the safeguards we have in place, please email [email protected].

10. Privacy Policy Changes

We’re always looking for new and innovative ways to help you build meaningful connections; therefore, this policy may change over time. We will notify you in case of any material changes that will take effect so that you can review the changes.

11. Contact Us

If you have any questions regarding this privacy policy or our methods of processing your personal data, you can contact us directly.

E-MAIL: [email protected]
Address: YESILKÖY SB MAH. C BLOK SK. C BLOK NO: 1 IÇ KAPI NO: 13 BAKIRKÖY / ISTANBUL

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