Privacy Policy
Hey there! Welcome to Penguin’s Privacy Policy.
We understand that reading a privacy policy isn’t exactly exciting, but we’ve made an effort to keep this one clear and straightforward because we genuinely want you to read it! Think of us as your digital guide, here to walk you through what data we collect, why we collect it, and how we use it. So, grab your favorite drink, get comfortable, and let’s explore the world of personal data together.
1. Who We Are
If you live in Canada or the U.S.A:
Slide Group Inc
770 Brookfield Road
Suite A206
Ottawa, Ontario
Canada
2. Where This Privacy Policy Applies
This Privacy Policy applies to all websites, apps, events, and services we provide under the Penguin brand. Whether you’re looking for your soulmate, attending one of our events, or using any of our other services, this Policy covers it all. For ease, we’ll refer to them collectively as our “service” throughout this Privacy Policy.
If any of our services require a separate privacy policy, it will be provided to you, and that specific policy will apply instead of this one.
3. Data We Collect
To help you build meaningful connections, we need some information from you, such as basic profile details and your preferences for potential matches. Additionally, using our service generates data, like your login times and usage patterns. We may also collect information from third parties, such as when you access our service through platforms like Facebook, Google, or Apple, or when you upload data from another account to complete your profile. For more details, please refer to the table below.
A. Data you give us
Account Data
When you create an account, you provide us with essential information like your phone number, email address, and date of birth to set up your profile.
Profile Data
When you complete your profile, you provide additional information such as your gender, interests, preferences, and approximate location. In some countries, certain details, like sexual orientation, lifestyle, health, or political beliefs, may be classified as sensitive data. By choosing to share this information, you consent to its use in accordance with this Privacy Policy.
Content
When you use our service, you may post photos, videos, audio, text and other types of content, such as your chats with other members.
Purchase Data
When you make a purchase, we keep the details of the transaction (e.g., what you purchased, the date of the transaction, and the price). The exact data depends on the payment method you choose. When you pay directly with us (rather than through a platform such as iOS or Android), you provide your debit or credit card number or other financial info.
Marketing, Survey and Research Data
At times, we conduct (i) surveys, focus groups, or market research for research purposes, and (ii) promotions, events, or contests for marketing purposes. By participating, you provide us with information necessary to process your entry and participation, along with your responses and feedback.
B. Data Generated or Automatically Collected
Usage Data
Using the service generates data about your activity, such as your login times, the features you use, actions taken, content shown to you, referring webpages, and ads you engage with. It also tracks how you interact with others, including searching, matching, and communicating. Additionally, we may collect data about your interactions with our ads on third-party websites or apps.
Technical Data
When you use the service, we collect data from and about the device(s) you use to access it. This includes hardware and software details like your IP address, device ID and type, app settings and characteristics, app crashes, advertising IDs, and identifiers linked to cookies or other technologies that may uniquely identify your device or browser. For more details on cookies, refer to our Cookie Policy.
C. Other data we collect with your permission/consent
Geolocation Data
With your permission, we can collect your device’s geolocation (latitude and longitude). If you choose not to grant permission, certain features that require precise location data may not be accessible to you.
Face Geometry Data
You may opt to use certain features, such as Photo Verification or Photo and ID Verification, which involve collecting facial geometry data. In some jurisdictions, this may be classified as biometric data. To learn more about these features and how we handle your facial geometry data, please refer to our verification guidelines.
ID Data
You may provide us with a copy of your government-issued ID to help us check that you’re who you say you are.
4. Why and How We Use Your Data
The primary reason we process your data is to deliver and continually enhance our service. This includes connecting you with potential matches, personalizing your experience, and helping you get the most out of our platform. We also process your data to ensure the safety and security of all our members, a responsibility we take very seriously. We’re always working to improve our systems to protect you. Additionally, we process your data to show relevant ads, which you can manage through your settings. For more details, continue reading.
Please see our FAQ for information on how we process personal data through “profiling” and “automated decision-making.”
| Purposes for processing your data | Grounds for processing your data | Categories of data processed (Those are described in Secion 3 of this Policy) |
|---|---|---|
| To facilitate your use of our service, including: -Creating and managing your account and profile -Operating and supporting various service features -Recommending members to you and vice versa -Organizing sweepstakes and contests -Responding to your inquiries and requests -Monitoring service performance and addressing any issues -Processing applications for our premium/VIP services |
Performance of our contract with you Your consent (where sensitive data or other type of data that requires consent is processed) |
Account Data, Profile Data, Content, Purchase Data, Marketing, Survey, and Research Data, Third-Party Data, Customer Support Data, Social Media Data, Usage Data, Technical Data, Geolocation Data, Face Geometry Data |
| To support your purchases on our service, including: -Processing payments -Providing discounts, promotions, and personalized pricing options |
Performance of our contract with you |
Account Data, Profile Data, Technical Data, Purchase Data, Usage Data |
|
To manage advertising and marketing efforts, including: -Running and evaluating the effectiveness of advertising campaigns on our platform -Executing and assessing the impact of marketing campaigns promoting our service on third-party platforms -Informing you about products and services that may be of interest to you |
Consent (where required by applicable law) or, alternatively, our legitimate interest. Our legitimate interest lies in promoting our service and displaying ads tailored to members' interests, enhancing their experience while helping to support the free aspects of our service. |
Account Data, Profile Data, Usage Data, Marketing, Survey and Research Data, Technical Data |
| To enhance our service and develop new features, including: -Conducting focus groups, market research, and surveys -Analyzing usage patterns of our service -Reviewing interactions with customer support to improve quality -Developing and refining new features and services, utilizing machine learning and other technologies, and testing them -Carrying out research and publishing findings |
Fulfillment of our contract with you Our legitimate interest: We have a legitimate interest in continuously improving our service Consent where required by applicable law (e.g., processing sensitive or unique data in certain countries to ensure fair and equitable treatment of all communities and to maintain diversity and inclusivity in our service) |
Account Data, Profile Data, Content, Purchase Data, Marketing/Survey/Research Data, Third-Party Data, Customer Support Data, Social Media Data, Usage Data, Technical Data |
| To ensure the safety of you and other members of our service and across Slide Group, including: -Preventing, detecting, and combating violations of our Terms, fraud, and other illegal or unauthorized activities -Developing and enhancing tools to prevent and address violations, fraud, and unauthorized activities -Preventing repeat offenses by blocking individuals who breach our Terms from creating new accounts -Informing individuals who report issues about the actions we’ve taken -Verifying user identities -Securing payments and preventing financial fraud |
Fulfillment of our contract with you Our legitimate interest: Ensuring the safety of our members is in both our interest and theirs Protection of your vital interests and those of other members Compliance with legal obligations, such as removing illegal content Your consent (when processing sensitive data or other information requiring consent) |
Account Data, Profile Data, Content, Purchase Data, Third-Party Data, Customer Support Data, Usage Data, Technical Data, Face Geometry Data, ID Data |
|
To comply with applicable laws and to establish, exercise, and defend legal claims and rights, including: -Retaining data to comply with legal requirements and demonstrate compliance -Assisting with investigations and defending against potential or ongoing litigation, regulatory actions, or disputes -Responding to lawful requests from law enforcement, courts, regulators, or other authorities -Reporting illegal or infringing content to relevant authorities -Establishing, exercising, or defending against ongoing or potential claims -Sharing data with law enforcement or partners to combat abusive or illegal activities |
Our legitimate interest: We have a legitimate interest in complying with applicable laws and protecting ourselves, our members, and others, particularly in the context of investigations, legal proceedings, and disputes Protection of your vital interests and those of other members Compliance with legal obligations, such as responding to information requests from law enforcement agencies |
The categories of data shared will vary based on the specific circumstances surrounding each obligation, compelling interest or dispute |
5. How We Share Data
Since our goal is to help you make meaningful connections, some of your information is of course visible to other members on the service. We also share data with service providers and partners who assist us in operating the service, with other Match Group companies for the reasons laid out below and, in some cases, for legal and related reasons. Read on for more details.
| Recipients | Reasons for sharing | Categories of Personal Data |
|---|---|---|
| Other members | You share data with other members when you voluntarily disclose information on the service for others to see (e.g., your public profile). If someone submits a report involving you (such as a claim you violated our Terms of Use), we may let the reporter know what actions we took, if any, as a result of their report. The same applies if you submit a report involving another member. |
Profile Data, Content, Social Media Data, Third Party Data, Customer Support Data |
| Service providers/partners | We share data with vendors and partners who help us operate, promote and improve our service. They provide us services such as data hosting and maintenance, analytics, customer care, marketing, advertising, payment processing, legal support, and security operations. |
Depending on the service provided by the vendor or partner, it may include: Account Data, Profile Data, Content, Purchase Data, Marketing, Survey and Research Data, Third Party Data, Customer Support Data, Social Media Data, Usage Data, Technical Data, Geolocation Data, Face Geometry Data, ID Data |
| Advertising Partners | We may publish ads about third-party advertisers’ products and services on our service, and publish ads promoting our own service on third-party sites and apps. To help improve the relevance of these ads, we provide certain info about you to third parties, including advertising partners, or allow them to collect such data from our services (such as via cookies, SDKs, or similar technologies). Some of our advertising partners enable us to transform your email address, advertising identifiers or phone number into an identifier that can’t be used to identify you personally and then use that unique identifier to either exclude you from our marketing campaigns, or to target our ads at an audience that is similar to you in terms of background, interests or app usage. |
Account Data, Profile Data, Usage Data, Technical Data |
| Affiliates | We may share data with affiliates or receive data from them for the purposes laid out in Section 6 of this policy. |
The categories of data will vary based on the reason for sharing, but it may include: Account Data, Profile Data, Content, Purchase Data, Marketing, Survey and Research Data, Third Party Data, Customer Support Data, Social Media Data, Usage Data, Technical Data, Geolocation Data, Face Geometry Data, ID Data |
| Law enforcement authorities |
We may disclose your data to: (i) comply with a legal process, such as a court order, subpoena or search warrant, government/law enforcement investigation, or other legal requirements; (ii) assist in the prevention or detection of crime; (iii) protect the safety of any person; and (iv) establish, exercise or defend legal claims. |
The categories of data shared will vary depending on the specific circumstances surrounding the request, but it often can include: Account data, Profile Data, Content, Purchase Data, Customer Support Data, Third Party Data, Social Media Data, Usage Data, Technical Data, Geolocation Data, ID Data |
| In the context of merger and acquisition, with our Affiliates or new owner(s) | We may transfer your data if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control. | The categories of data shared will vary based on the type of corporate transaction. It may include the entire organization data or only a specific subset such as Purchase Data. |
| When the profile sharing functionality is used | You may choose to share other members’ profiles and they may share yours with people outside of our service, using the sharing functionality. | Profile Data Content |
6. How Match Group Companies Work Together
Penguin is part of the Slide Group Business.
We may share data about you with our Affiliates and they may share data about you with us, for the reasons laid out below:
- To make all Slide Group platforms safer, for instance by making sure that when a bad actor is found on one Slide Group platform (for instance ours), they can be banned from all.
- To assist each other in data processing operations, as service providers. This assistance may include processing operations, such as data hosting and maintenance, customer care, marketing and targeted advertising, analytics, finance and accounting, legal support, payment processing, service improvement, data security and fighting against spam, abuse, fraud and other wrongdoings.
- To improve your chances at building significant connections with others, we may make you visible on other Slide Group services or allow you to benefit from cross-platform functionalities. We will of course comply with applicable law and, where relevant, notify you of any such opportunity and allow you to agree or to refuse.
- Where and as allowed under applicable law, to better understand how people use Slide Group services overall, to personalize your experience across Slide Group services and to enhance marketing and advertising campaigns.
- For other legitimate business purposes including corporate / consolidated audit, analysis and reporting.
7. Cross-Border Data Transfers
Because we operate a global service, the sharing of your data laid out in Section 5 involves cross-border data transfers to the United States of America and other countries that may have different laws about data processing. When we transfer personal data outside of the EEA, the United Kingdom, Switzerland or other countries whose data protection laws have been deemed adequate by the European Commission or other competent governmental bodies, we typically rely on what are called standard contract clauses. These standard contractual clauses are commitments between companies transferring personal data, binding them to protect the privacy and security of your data. Contact us for a copy.
8. Your Rights
We want you to be in control of your data, so we want to remind you of the following rights, options and tools available to you. Depending on where you live, you may not have the same rights or they may be named differently. If you have any questions on your rights and how to exercise them, please contact us here.
1- Right to be informed of the personal data we process about you and/or ask for a copy of it
You can access and review some data directly by logging into your account. You can also retrieve a copy of your data by emailing info@thepenguinapp.com.
2- Right to amend or update your personal data where it’s inaccurate or incomplete
You can update your data directly within the service by simply updating your profile. If you wish to rectify other data, please contact us at info@thepenguinapp.com.
3- Right to delete personal data
You can delete some of the data you provided us directly within the service. You can also close your account as explained here, and we’ll delete your data as it is laid out in this Privacy Policy. You can always contact us at info@thepenguinapp.com.
4- Right to object to us processing personal data or to request that we temporarily or permanently stop processing personal data
You can directly opt out from certain of your personal data processing in your account settings. Otherwise, you can contact us at info@thepenguinapp.com should you wish to object to or restrict a data processing we’ve listed throughout this Privacy Policy.
5- Right to withdraw consent you’ve given us to process your personal data for a specific purpose
You can directly withdraw consent you’ve given us either by updating your account settings or removing Device Permissions you’ve agreed to in your device settings (e.g., access to specific types of device data such as phone contacts, pictures, advertising identifiers, and location services or consent to receive push notifications). When you withdraw consent, certain services may lose functionality. You can always contact us here for more information.
6- Protection
For your protection and the protection of all of our members, we may ask you for information to verify your identity or authority to act on behalf of a member before we can answer the above requests. We wouldn’t want someone else to get in control of your data!
Keep in mind, we may reject requests, including if we are unable to authenticate you, if the request is unlawful or invalid, or if it may infringe on trade secrets or intellectual property or the privacy or other rights of someone else. If you wish to receive information relating to another member, such as a copy of any messages you received from them, the other member will have to make a request themselves.
If you are a resident of Texas, Oregon, Montana, Virginia, Colorado, or Connecticut, USA, if we deny your privacy request, you may be able to appeal by contacting us, and explicitly referencing “Privacy Request Appeal.” If you have concerns about the result of your appeal, you may contact the attorney general for your state.
In certain countries, including in the European Economic Area and the United Kingdom, you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how we process your personal data. You can find information about your data protection regulator in the European Economic Area here, and in the United Kingdom here. The data protection authority you can lodge a complaint with may be that of your habitual residence, where you work or where an alleged infringement took place.
9. How Long We Retain Your Data
We want the connections you make through our service to last forever, but we keep your personal data only as long as necessary for legitimate business reasons (as laid out in Section 4) and as permitted by applicable law.
If you decide to stop using our service, you can close your account and your profile will no longer be visible to other members. Note that we will close your account automatically if you are inactive for two years.
Following account closure, we delete your data as laid out below:
- To protect the safety and security of our members, we implement a safety retention window of three months following account closure or one year following an account ban. During this period, we keep your data to investigate unlawful or harmful conducts. The retention of data during this safety retention window is based on our legitimate interest as well as that of potential third-party victims.
- We maintain limited data to comply with legal data retention obligations: in particular, we keep transaction data for 10 years to comply with tax and accounting legal requirements, credit card information for the duration the user may challenge the transaction, and “traffic data” / logs for one year to comply with legal data retention obligations. We also keep records of consents members give us for five years to comply and evidence our compliance with applicable law.
- We maintain limited data on the basis of our legitimate interest: we keep customer care exchanges with you for 6 years from the date of the communication, customer care records and supporting data, as well as imprecise location of download/purchase, for five years in support of our safety efforts, to support our customer care decisions, enforce our rights and enable us to defend ourselves in the event of a claim, information on the existence of past accounts and subscriptions, which we delete three years after the closure of your last account to ensure proper and accurate financial forecasting and reporting, profile data for one year in anticipation of potential litigation, for the establishment, exercise or defense of legal claims, and data necessary to prevent members who were banned from opening a new account for as long as necessary to ensure the safety and vital interests of our members.
- Finally, we maintain data on the basis of our legitimate interest where there is an outstanding or potential issue, claim or dispute requiring us to keep data in particular if we receive a valid legal subpoena or request asking us to preserve data (in which case we would need to keep the data to comply with our legal obligations) or if data would otherwise be necessary as part of legal proceedings.
Where and as legally permitted, we may maintain and use data that, by itself, cannot identify or be attributed specifically to you for the purposes described in this Privacy Policy, including to improve our service and create new features, technologies and services and keep Slide Group services safe.
10. Children's Privacy
Our service is restricted to individuals who are 18 years of age or older. We do not permit individuals under the age of 18 on our platform. If you suspect that a member is under the age of 18, please use the reporting mechanism available on the service. You can learn more about Penguin’s age verification practices here.
11. Privacy Policy Changes
This policy may change over time. We’re always looking for new and innovative ways to help you build meaningful connections and strive to make sure explanations of our data practices remain up-to-date. We will notify you before material changes take effect so that you have time to review the changes.