This Privacy Policy applies to all personal data that (Company) processes on its website
www.erosdates.com (‘Website’) and in the context of the services offered there.
We believe it is important to handle the personal data that is entrusted to us in a transparent and responsible manner. In this Privacy Policy we explain, among other things, why we collect and use personal data, which data that is and what rights you have. We process your personal data in a careful manner and in accordance with the General Data Protection Regulation (‘GDPR’) and the associated implementing law. We advise you to read the Privacy Policy carefully and to keep a copy of it for your own administration.
1. Data Controller
The data controller for the processing of the personal data is:
- Business Investment Group
- Oude Boteringestraat 60
- 9712GM Groningen
- Registered in the Chamber of Commerce under number: 81376375
If you have any questions about the processing of your personal data, you can contact our privacy officer via: privacy@erosdates.com
2. Which data do we process?
We process various types of personal data via the Website and our services. For example, when you visit our Website, create an account, publish an advertisement or review or use the message function. If we process personal data, this is usually because you use our services and you provide the personal data to us yourself. It is also possible that we process personal data in response to complaints, reports, fraud investigations, police claims or to comply with other mandatory regulations.
Examples of types of personal data that we process are: e-mail address, IP address, company name or work name, address details, telephone number, date of birth, nationality, gender, physical characteristics.
Special personal data: explicit consent
Via the Website and the services, we also process data relating to your sexual behavior or sexual orientation with your explicit consent. This is special personal data. This special personal data is processed, for example, if you place this data and/or information in an advertisement, review or in other content on the Website and/or within the service provision.
You can always withdraw your consent for the use of this special personal data via your own account and delete your data and information. In some cases, it may be necessary to terminate your account for this. For more information about withdrawing your consent and deleting your data, you can also contact our privacy officer via: privacy@erosdates.com
3. Purpose and basis of processing personal data
Below you will find an overview of the purposes for which we process personal data. Each time, the legitimate basis for processing this data is indicated. The most important bases for which we process personal data are:
- Processing that is necessary for the performance of the agreement to which you are a party;
- Processing that is necessary for the protection of our legitimate interests;
- Processing that is necessary to comply with a legal obligation that rests on us.
- Use of the account: access to the services
For access to and use of your account, we process, among other things, your e-mail address and user name (nickname). In addition, we link an IP address to the account so that you do not have to enter your data again each time.
Please note: Your user name is published with the messages, reviews and/or advertisements you have posted. This name is therefore visible to other users, visitors to the Website and search engines. To protect your privacy, we advise you not to use your own name, or a name that can be traced back to you, as a username (nickname).
The Account is required to give you access to certain parts of the Website and to allow you to use certain services, including exchanging messages and placing advertisements or reviews. The processing of personal data is necessary for the execution of our agreement.
2. Placing advertisements, reviews and responses to reviews
We offer you the opportunity to publish advertisements, reviews and responses to reviews via the Website. For the publication of a paid advertisement, we process payment details, including bank details. The advertisements, reviews and responses to reviews may contain personal data, including special personal data relating to your sexual behavior or sexual orientation and image and film material. The Advertisement, reviews and responses to reviews (including the (special) personal data) are visible to other Users of the Website and the search engines.
We are allowed to process your special personal data because you have given explicit permission for this (article 9 paragraph 2 sub a GDPR). The processing of personal data is necessary for the execution of our agreement.
3. Messages
If you use the option to contact another user via the message function on the Website, the content of the message is visible to the user with whom you are communicating. This processing is necessary for the execution of our agreement.
4. General contact
We can use your e-mail address to contact you, for example in connection with (problems with) the use of the Website or the services, to provide the information you requested or to handle your question and/or complaint. This processing is necessary for the execution of our agreement or for the promotion of our legitimate interest in being able to maintain contact with our relations.
5. Research into use of Website
Your IP address and information from cookies can be used to compile online usage statistics (at an aggregated and anonymous level), to analyze search and surfing behavior and thus to gain a better picture of the use of the Website. It is not possible to identify visitors or users based on this information, all data is immediately anonymized.
This processing of personal data is necessary for the protection of our legitimate interest to analyze and optimize the reach and effectiveness of our Website.
6. (Access) control and combating fraud, abuse and minimum age
Your email address and password are used as access control to your account and to prevent crime, fraud and corruption. The IP address is also used to prevent fraud or abuse of the Website. For example, the IP address is used to check whether there are duplicate accounts or whether fraud is being committed with advertisements.
We can use your proof of identity to check whether you meet the minimum age limit. For this purpose, we request temporary access to an official proof of identity using an application produced by the government, the ‘KopieID app’. We request that you make non-essential personal data (such as the Citizen Service Number, nationality, height) invisible. After this (temporary) inspection, we will only store your date of birth, so that we can demonstrate that you are of legal age.
The legal basis for this processing of personal data is the necessity for the protection of our legitimate interest in the field of combating fraud, abuse of our services and unlawful acts
7. Sending our e-mail newsletter
Only if you have given permission for this, we will use your e-mail address to send you our e-mail newsletter. This contains interesting information for you about our Website and services. The legal basis for this processing of personal data is the necessity for the protection of our legitimate interest in the field of direct marketing.
You can always withdraw your permission and unsubscribe from the e-mail newsletter by clicking on the unsubscribe link (‘unsubscribe me’) at the bottom of the newsletter.
4. Retention periods
We do not process your personal data for longer than necessary for the purpose for which this data is processed.
- Account data
The personal data is stored in your account for as long as you have an account/agreement with us. You always have the right to delete your account. You can do this by logging in and deleting it or by sending an email to privacy@erosdates.com. We will delete your account, including your personal data, if we block your access to the service and Website or if our agreement ends otherwise.
After deleting your account/terminating the agreement, we may retain some account data for a period of four weeks. For example, to combat fraud, abuse of our services and other unlawful acts or to comply with a legal obligation.
2. Advertisements, reviews and responses to reviews
The advertisements you have published on the Website, including your (special) personal data, will remain published until you delete the advertisement and/or the agreement ends. If a visitor ends the agreement, their reviews will also be automatically deleted. If an advertiser ends the agreement, the reviews relating to their advertisements and their responses to the reviews will be automatically deleted.
If an advertiser removes an advertisement or withdraws their permission to allow reviews for the advertisement, but maintains the account, the reviews relating to the advertisement and the responses to that review will no longer be shown on the Website. However, this review and responses to that review will be stored within the (Company) platform, so that they can be shown again as soon as the advertiser publishes the advertisement again or chooses to allow reviews again.
3. Messages
The messages that you have sent and received via the Website will remain visible to you in your own account. You can always delete these messages yourself. If you terminate your account, the messages will be deleted automatically.
4. Paid advertisements and other services and invoices
The information about the advertisements or other services that you have purchased and paid for are automatically stored in your account. The invoices can also be found there. We store the data if and for as long as necessary to comply with our legal obligation under, for example, tax legislation (7 years).
5. E-mail newsletters
If you have given permission to receive our e-mail newsletter, we will process the associated personal data until you withdraw your permission. You always have the right to withdraw this permission.
6. IP address, search behavior and usage data
The information about the use of the Website, time of visit, device and browser information and location information is immediately and automatically anonymized. Your IP address is stored by us for as long as you have an Account. This is automatically deleted after termination of your Account.
7. General
Finally, if we no longer need to process the personal data for the reason stated above, we will destroy and/or anonymize the personal data, unless we are forced to retain certain personal data for a longer period on the basis of a legal obligation or on the basis of a burden of proof. In that case, only the personal data that are specifically necessary for that purpose will be retained for the applicable retention period.
5. Provision of personal data to third parties
We do not provide personal data to third parties, unless we are required to do so on the basis of a legal obligation. This may be the case, for example, if the police or another competent authority requests personal data on the basis of a legal provision.
Processors
For the management of the advertisements placed on the Website, for the settlement of the payment or for other services related to our Website or services, we may use other service providers. For example, the administrators or software developers or payment service providers engaged by us. These suppliers (so-called ‘processors’) process the personal data exclusively on our behalf. We have concluded a processing agreement with the processors in which the processor is obliged to comply with all obligations under the GDPR and this Privacy Policy. For questions about these processors, you can contact our privacy officer via privacy@erosdates.com.
Processors outside the EEA
A few of our suppliers are located outside the European Union. If these suppliers process your personal data on our behalf, we ensure that there are appropriate safeguards in place, which, in accordance with the GDPR, provide an equivalent and sufficient level of protection for your rights and freedoms. We do this, for example, by ensuring that the supplier is bound by the model contracts approved by the European Commission for the transfer of personal data to countries outside the EU (“Standard Contractual Clauses”). For more information about the safeguards regarding transfers outside the EU, you can contact our privacy officer via privacy@erosdates.com
6. Security measures
We have taken appropriate technical and organizational measures to protect your personal data. These protect your personal data against loss or any form of unlawful or unauthorized processing and against accidental loss, destruction or damage.
The technical security measures include the use of secure socket layer (SSL)/ Transport layer security (TLS) encryption or other forms of encryption, Encrypted passwords – servers protected by advanced firewall. The organizational measures include, for example, that only authorized (Company) employees may view your data. These employees only have access to your personal data to the extent necessary to perform their tasks.
7. Your rights
You can submit a request to view, obtain, correct, limit or delete your personal data at any time via our email address privacy@erosdates.com. We will always process your request without delay and inform you, in any case within one month of receipt of the request, of the action taken on the request. If we cannot grant your request, we will always explain this in more detail. If we grant your request to obtain your personal data, we will make the personal data available to you or to a third party designated by you in a standard format to be determined by us.
You can always withdraw your consent and/or object to the (further) processing of your personal data. You can do this via your account, but also by contacting our privacy officer via privacy@erosdates.nl. We will process your request without delay, in any case within one month, and delete the personal data in question, unless we are required to retain the personal data in question for a longer period on the basis of compelling legitimate grounds or a legal obligation. In that case, we will inform you of this and motivate our decision.
If you have complaints about the way in which we process your personal data or handle your requests, you can contact our privacy officer via privacy@erosdates.com. If this does not lead to a solution, you can of course always use your right to file a complaint with the Dutch Data Protection Authority (www.autoriteitpersoonsgegevens.nl) or to appeal to the competent court.
Any other questions or comments about this Privacy Policy can be directed to our customer service (privacy@erosdates.com).
8. Changes
This Privacy Policy may be changed. If we make changes, we will announce the changed version on the Website or by e-mail at least one month before it comes into effect. We advise you to regularly review the Privacy Policy. If you do not agree with the changes, you can always delete your account and thus terminate the agreement.
BUSINESS INVESTMENT GROUP, Groningen, Juni 2024