SoulConnect App Privacy Policy

Introduction
1. The online dating and matchmaking mobile application (the SoulConnect App), our website (https://www.soulconnectapp.com) (Website) and the products and services made available through the SoulConnect App are created and controlled by JD AI Technology Pty Ltd trading as Soulconnect App (ABN 54 684 964 850) (SoulConnect, we, us or our).
2. We are committed to ensuring your Personal Information is protected. We manage your Personal Information in accordance with the Australian Privacy Principles set out in the Privacy Act 1988 (Cth) (Privacy Act).
3. By accessing and using and continuing to access and use the SoulConnect App, the Website and the products and services you agree to this Privacy Policy.
4. This Privacy Policy outlines how we collect, store, share, use and disclose your Personal Information, and how you may access your Personal Information kept by us or how you may make a privacy complaint.
The information we collect about you
1. Personal information has the same meaning that it has under Privacy Act, namely, information means information or an opinion about an identified individual or an individual who is reasonably identifiable, whether the information or opinion is true or not and recorded in a material form or not.
2. We collect and use Personal Information and Non-Personal Information from members who access and use the SoulConnect App, our products and services and any other individual who interacts with us or who visit our Website.
3. We will only collect and hold Personal Information and Non-Personal Information about you that is reasonably necessary to undertake our business activities and functions, make the SoulConnect App, our Website and our products and services available to you, or as otherwise permitted by law.
4. We collect and hold Personal Information about members as well as information or data that does not contain Personal Information. For example, the type of Personal Information and Non-Personal Information that we collect includes:
  1. registration details and profile information (for example, full name, date of birth, mobile number and profile picture);
  2. account credentials (including your username and password created by you as a member of the SoulConnect App);
  3. information contained in your member profile (such as your location, profile picture or image, information relating your interests, hobbies, lifestyle choices and other personal preferences);
  4. information about a member you have connected with or communicated with, and how you interact with other members;
  5. information about the products or services that members are interested in purchasing or have purchased;
  6. any other content, information and other data that you post or submit on, or via the SoulConnect App;
  7. information relating to your dealings, or enquiries you have made, with us, including information about the SoulConnect App, our Website, products and services or complaints you have raised with us about other members or any other ancillary products or services made available to you on, or via, the SoulConnect App; and
  8. other information that you provide to us or that we may collect in the course of our relationship with you.
5. We may also collect some information that is not Personal Information because it does not identify you or anyone else. For example, we may collect:
  1. anonymous answers to surveys or aggregated information about how members interact and use the SoulConnect App; and
  2. information regarding your access and use of the SoulConnect App and our Website, including location information, your computer’s internet protocol (IP) address, unique device identifier, browser characteristics, device characteristics, operating system, language preferences, referring URLs, information on actions taken on the SoulConnect App and our Website, dates and times of visits to the SoulConnect App and our Website and other usage statistics.
6. If you are a candidate seeking employment with us, we will use your Personal Information to process your application and assess your suitability for any role. We may retain your information for future reference.
Sensitive Information
1. We do not collect your Sensitive Information (as defined by the Privacy Act). However, some of our services are automated and we may not recognise that you have accidentally provided us with Sensitive Information.
2. If you have accidentally sent us Sensitive Information, please contact us using the contact details set out in section 13 below.
How we collect Personal Information
1. We will collect Personal Information about you in a number of different ways. We may collect Personal Information directly from you or in the course of our dealings with you. For example, when you:
  1. access and use the SoulConnect App (including when you open an account or create or update your account on, or, via, the SoulConnect App);
  2. create your member profile (including when you upload, publish, edit or delete information from your member profile);
  3. contact, connect or communicate with other members on, or, via, the SoulConnect App;
  4. when you visit the SoulConnect App and/or our Website or submit information or a query through the SoulConnect App and/or Website (including on, or via, our related social media accounts), contact us, or complete any online forms or documents or when you enter or participate in competitions, promotions, events, sweepstakes, surveys and questionnaires; and
  5. when you otherwise contact, interact or communicate with us (such as by telephone, email or in person) with a query or request or make a comment on our social media sites or lodge a complaint about another members, member profiles any other ancillary products or services made available through the SoulConnect App.
2. We may also collect Personal Information and Non-Personal Information about you from publicly available sources and third parties, including:
  1. when you provide your Personal Information to our Authorised Affiliates or other third parties;
  2. when you provide your Personal Information to other members;
  3. if you use our social media sites or applications, pages or plugins or third party products or services that interact with the SoulConnect App, our products, services or third party payment processors.
3. When we collect your Personal Information from third parties, we shall take reasonable steps to make sure you are aware of the collection.
4. If you provide us with Personal Information about another individual (as their authorised representative), we rely on you to:
  1. inform them that you are providing their Personal Information to us; and
  2. advise them that they can contact us for further information.
5. You must take reasonable steps to ensure the individual is aware of, and consents to, the matters outlined in this Privacy Policy, including that their Personal Information is being collected, the purposes for which that information is being collected, the intended recipients of that information, the individual's right to access that information, and who we are and how to contact us.
6. Upon our request, you must also assist us with any requests by the individual to access or update the Personal Information you have collected from them and provided to us.
How we use your Personal Information
1. We only use, process and disclose your Personal Information for the purposes for which it is collected.
2. In particular, we use, process and disclose your Personal Information and Non-Personal Information to:
  1. provide or deliver the SoulConnect App, our Website and our products and services to you, including, without limitation, to provide the means through which members can be matched and connected with compatible members or for the purpose of purchasing or acquiring products or services made available to you through the SoulConnect App;
  2. provide or deliver our Website to visitors;
  3. informing you about the SoulConnect App, our Website, products or services or about offers, competitions, promotions, events, sweepstakes, surveys, questionnaires about us, the SoulConnect App or other matters which we believe are of interest to you (such as recruitment or job opportunities);
  4. manage, administer, improve, test, develop and upgrade the SoulConnect App, Website and our products and services, informing you about scheduled maintenance or outages and managing our relationship with you or to otherwise investigate complaints about the SoulConnect App and other members;
  5. share with our Authorised Affiliates;
  6. charge and bill members to access and use the SoulConnect App;
  7. verifying your identity;
  8. for internal record keeping;
  9. for direct marketing purposes (see below);
  10. complying with our legal and regulatory obligations;
  11. for any purpose to which you have consented; and
  12. for any other purpose notified to you at the time of collection.
3. In the event of a merger, acquisition or sale of the whole or part of our business or assets, we reserve the right to transfer your Personal Information as part of the transaction, without your consent or notice to you.
Disclosure to Authorised Affiliates
1. In order to provide or deliver the SoulConnect App, our Website and our products and services to you and to connect members, we may disclose your Personal Information and Non-Personal Information to:
  1. our related body corporates, business partners, service providers, third party contractors, agents or suppliers;
  2. authorised external service providers who perform functions on our behalf, such as internet and technology services providers, app and website software developers (e.g Appetiser), hosting and data storage companies, accounting and bookkeeping service providers, marketing, advertising and security service providers, third party payment processors, fulfilment companies, credit reporting agents, debt collection agents, market research and recruitment service providers; and
  3. external business advisors, such as accountants, auditors, lawyers, insurers and financiers,
    (collectively, Authorised Affiliates).
2. We may share your Personal Information with other members for the purposes of providing you with dating and matchmaking services. Wherever reasonably possible, the Personal Information shared with other members will be limited to your first name and location (suburb only) and other information published by you on your member profile (such as your profile picture or image, information relating your interests, hobbies, lifestyle choices and other personal preferences).
3. We may also disclose your Personal Information and Non-Personal Information:
  1. to any other party with your consent and direction;
  2. to law enforcement bodies or regulatory authorities to assist with their functions, or as otherwise required or authorised by law; or
  3. where we consider it necessary to comply with any applicable law, regulation, legal process, governmental request or industry code or standard.
4. When we disclose your Personal Information or Non-Personal Information to any of our Authorised Affiliates, we will ensure that they undertake to protect your privacy. These Authorised Affiliates are not permitted to use the information for any purpose other than the purpose for which they have been given access.
5. Our Authorised Affiliates may also provide us with Personal Information and Non-Personal Information collected from you. If you disclose Personal Information to Authorised Affiliates, we rely on you to provide the Authorised Affiliates with consent for us to collect, storage, use, process, alter and disclose your Personal Information.
Overseas disclosures of Personal Information
1. In the course of providing you with access to, and use of, SoulConnect App, our Website and products or services and to connect members, it may become necessary or desirable to disclose Personal Information to Authorised Affiliates located overseas. The countries in which these overseas recipients may be located will depend upon the individual circumstances. However, in the course of our ordinary business operations we commonly disclose Personal Information to Authorised Affiliates located in [insert].
2. The laws where these overseas recipients may be located provide various levels of protection for Personal Information which are not always equivalent to the level of protection that may be provided for in Australia. Where we transfer your Personal Information overseas, we will take reasonable steps to ensure that your Personal Information is treated securely, and the means of transfer provides adequate safeguards.
3. If you have any questions in relation to the transfer of your Personal Information please contact us using the contact details set out in section 13 below.
Notifiable Data Breaches Scheme
In the event of any loss, or unauthorised access or disclosure of your Personal Information that is likely to result in serious harm to you, we will investigate and notify you and the Australian Information Commissioner as soon as practicable, in accordance with notifiable data breach scheme contained in Part IIIC of the Privacy Act.
Marketing communications
1. We may use and disclose your Personal Information to send you information about the SoulConnect App, our Website and the products or services we offer as well as other information that may be of interest to you.
2. These communications may continue, even after you stop using the SoulConnect App or visit the Website.
3. We may send this information to you via the communication channels specified at the time you provide your consent.
4. These communication channels may include mail, email, SMS telephone, social media or by customising online content and displaying notices on the SoulConnect App.
5. You can opt out of receiving these communications by:
  1. contacting us using the details below; or
  2. using the unsubscribe function in the email or SMS.
Security of your Personal Information
1. We will take steps that are reasonable in the circumstances to ensure that the Personal Information that we hold are protected from misuse, interference and loss and from unauthorised access, modification or disclosure. We hold Personal Information in both hard copy and electronic forms in secure databases on secure premises, accessible only by authorised staff.
2. We protect your information using physical, technological and administrative security measures to minimise and manage the risks of unauthorised access, disclosure, use and alteration of your Personal Information.
3. The transmission of information via the Internet is not completely secure. We cannot guarantee the security of your data transmitted to our online services and any transmission is at your own risk.
4. We will destroy or de-identify Personal Information within a reasonable period of time after you have terminated your account on the SoulConnect App or where your Personal Information is no longer required, unless we are required or authorised by law to retain the information. However, we may retain Personal Information (including basic registration information) in accordance with documentation retention and destruction laws.
Accessing and correcting your Personal Information
1. We take reasonable steps in the circumstances to ensure the Personal Information we hold about you is accurate, up-to-date, complete, relevant and not misleading. Under the Privacy Act, you have the right to access and seek correction of your Personal Information that is collected and held by us.
2. If at any time you would like to access or correct the Personal Information we hold about you, or you would like more information about our approach to privacy, please contact us. We will grant you access to your Personal Information the extent necessary or authorised by the Privacy Act or other law and we take reasonable steps in the circumstances to correct Personal Information where necessary and appropriate.
3. To obtain access to your Personal Information:
  1. you will have to provide proof of identity to ensure that Personal Information is provided only to the correct individuals and that the privacy of others is protected; and
  2. we may charge you a reasonable administration fee, which reflects our costs in providing you with access to your Personal Information in accordance with your request.
4. If we refuse your request to access or correct your Personal Information, we will provide you with written reasons for the refusal and details of complaint mechanisms.
Cookies policy and analytics
1. We may collect information when you access and use the SoulConnect App and our Website by utilising features and technologies of your internet browser, including cookies, and similar technologies. A cookie is a piece of data that enables us to track and target your preferences. We use cookies or similar technologies to collect standard log and visitor behaviour information in an anonymous form. We use this information to analyse how visitors and members use the SoulConnect App and our Website and to compile statistical reports on website activity. You can set your computer to reject cookies or similar technologies, but this may affect your ability to use certain parts of the SoulConnect App and Website.
2. We may also log your IP address. Your IP address is your computer’s electronic Internet address. We may collect your IP address to see trends, run the website, track user movements, and gather broad demographic information.
3. Services that our website may use from time to time include Apple Analytics, which transmits website traffic data to Apple servers. Apple Analytics does not identify individual users or associate your IP address with any other data held by Apple. We use reports provided by Apple Analytics to help us understand traffic and usage on the SoulConnect App.
4. By using the SoulConnect App, you consent to Apple processing your data in the manner described in Apple’s Privacy Policy (https://www.apple.com/legal/privacy/) and for the purposes set out in this Privacy Policy.
5. Services that the SoulConnect App and our Website may use from time to time include Google Analytics, which transmits website traffic data to Google servers. Google Analytics does not identify individual users or associate your IP address with any other data held by Google. We use reports provided by Google Analytics to help us understand traffic and usage on our website. By using our website, you consent to Google processing your data in the manner described in Google’s Privacy Policy (www.policies.google.com/privacy) and for the purposes set out in this Privacy Policy.
6. Google may pass on cookies to its partners and other third parties to achieve its purposes. For more information on how Google uses the information collected from cookies, and how you can opt out of this feature please see Google’s Privacy Policy. You can also view Google Analytics’ currently available opt-out (see https://chrome.google.com/webstore/detail/google-analytics-opt-out/fllaojicojecljbmefodhfapmkghcbnh/related?hl=en-GB).
Privacy complaints
1. If you have any complaints or issues you wish to raise with us regarding the way we have handled your Personal Information, or would like to discuss any issues about our Privacy Policy, please contact us directly by email to hello@soulconnectapp.com. Please provide us with full details of your complaint and any supporting documentation.
2. We will respond to you within a reasonable period of time to acknowledge your complaint and inform you of the next steps we will take in resolving your complaint. At all times, we will treat your privacy complaint seriously and in a confidential manner.
3. If you are unhappy with a response that you have received from us, you may direct your complaint to the Office of the Australian Information Commissioner.
Changes to this Privacy Policy
From time to time it may be necessary for us to review and revise our Privacy Policy. We may notify you about changes to this Privacy Policy by posting an updated version on our Website and/or the SoulConnect App. We encourage you to check our Website and/or the SoulConnect App from time to time to ensure you are familiar with our latest Privacy Policy.