Privacy Policy

“Personal Information” is information related to a person such as a name, address, phone
number or email address or as defined by law. You are not under any legal obligation to
provide us with Personal Information; the provision of Personal Information is done with
your consent only. If you do not agree to provide Personal Information, some or all of the
Services may not be available to you.
Regarding the information collected under this policy, we act as the database
owner/controllers of the Personal Information.
Comment on the requirement for a legal basis for processing the information: Some
jurisdictions only allow the processing of personal information when there is a legal basis for
doing so. According to the EU General Data Protection Regulation (“GDPR”), the possible
legal bases include (but are not limited to) the following: your consent, the processing is
necessary to perform the agreement with you, the processing is necessary to fulfill our legal
obligations, or that the Company has a legitimate business interest in processing your
Personal Information. When we are the controller of the information, we collect and process
data only when there is a legal basis for doing so. Additional details can be found below.

1. Information we collect and legal basis. We collect information if necessary and in
accordance with your use of the Services. Therefore, the collection and processing of
Personal Information depends on the type of Services you use, as follows:

 

1.1. Inquiries and/or Contact. When you contact us with a request and/or question, we
may record our communication with you and thereby any information you provide us,
such as your name, contact details, including phone, e-mail, and the content of the
request or question.
1.1.1. We process this information to fulfill the agreement with you.
 

1.2. Sign up and Login. To access the Services, you must sign up to the Services. If
you choose direct sign up, you will be required to provide us with at least your phone
number and email address, along with some basic details necessary for our Services to
function, such as your gender, date of birth, and the types of connections you are
interested in. Alternatively, you may sign up using your account with third-party
providers (e.g., Google or Apple). By signing up through a third-party, you consent to
their terms of use. In this case, we may receive information about you from the third
party, so we recommend reviewing their policies to understand what information will
be shared with us. You can also upload information to us, including photos from your
camera.
 

1.2.1. When we process your sign-up information to provide you with our
Services, we do so to fulfill our agreement with you, specifically our Terms of
Use. When we process your sign-up information to maintain our Services –
such as preventing fraud, protecting security and addressing any issues – we
do so based on our legitimate interest in safeguarding our assets.
 

1.3. Materials Uploaded to the Services. You can also share additional information
with us, such as biography details and interests, or upload photos or videos. To add
certain content, such as photos or videos, we may get access to your camera or photo
library.
 

1.3.1. We process this information to fulfill our agreement with you,
specifically our Terms of Use.
 

1.4. The Content of Chats with Other Users. We have access to and process the
content that comes up in chats with other users.
 

1.4.1. We process this information based on our legitimate interest in
safeguarding our assets.
 

1.5. Participation in Promotions, Events or Contests. We collect the information you
used to sign up or enter.
 

1.6. Payment Services. When purchasing a subscription to a paid service or when
making a purchase directly from us (and not through a platform such as iOS or
Android), we receive details related to the purchases you made. Additionally, our
payment service provider receives details from you such as your credit or debit card
number or financial information. Information we receive may include credit card
number, validity, full name and identification number of the cardholder, and email
address for sending invoices.

 

1.6.1. We process this information to fulfill our agreement with you,
specifically our Terms of Use.
 

1.7. Information Collected Automatically. Certain information is automatically
collected about your device, browser, operating system, IP address, Device ID of the
mobile device, app settings and properties, app crashes, advertising identifiers
(randomly generated numbers that you can reset by going to your device settings, and
in some cases disable completely), and identifiers related to cookies or other
technologies that may uniquely identify a device or browser. We also collect
information about your use of the Services, for example, login times, features you
used, actions you performed, information presented to you, the addresses of the
websites that referred you to us and ads you clicked on, as well as your interactions
with other members (for example, members with whom you have a relationship, the
dates of creating a match and the dates of correspondence between you).
 

1.7.1. We process this information based on our legitimate interests to develop
and improve our products and Services, and to prevent fraud.
 

1.7.2. We process this information based on your consent.
 

1.8. Location. Subject to your consent, we will collect information about your location
(geographic coordinates) from your device. It is your responsibility to decide whether
to display the last location from which you were active, or a residential address, and
change the settings accordingly. The collection of your geographic data may occur in
the background, even when you are not using the Services, provided that the consent
you have given us expressly permits this. If we do not receive permission from you to
collect your precise geographic location, we will not collect it, and our Services that
rely on precise geographic location may not be available to you.
 

1.8.1. We process this information based on your consent. You may withdraw
your consent by changing your mobile settings.

Information we receive from other users: Other users may provide us with information about
you in connection with your use of our Services, for example if they interact with you or if
they submit a report related to you.
 

2. How We Use Information. You agree and confirm that the Company is entitled to retain
in its databases the details provided by you, along with any additional Personal Information
that may accumulate about you. The Company may use these databases in accordance with
legal provisions and the Privacy Policy, including for the purposes detailed below:
 

2.1. Services and Adaptations. We and/or our service providers may use your Personal
Information for the following purposes: (1) providing access to the Services; (2)
helping you connect with other users, including recommending you to other users and
recommending other users to you, including displaying users’ profiles to each other;
(3) providing support and assistance in solving problems that you or other users may
encounter; (4) contacting you if necessary; (5) examining questions that arise,

including through the Services, and providing a response accordingly; and (6)
preventing fraudulent or illegal activities, safeguarding the security of the Services,
and addressing any issues related to their use. If a user submits a report about another
user, we will use that information to maintain the safety of the Services and protect
the users, at our sole discretion. We may update the complaining user regarding the
status of their report, and any action taken.
 

2.2. Internal Needs. We may use your Personal Information for internal purposes,
including diagnosing operational problems, conducting reviews and evaluations for
the development of new services and/or content, improving and customizing the
Services to meet specific needs (both ours and users’), developing new products,
analysing scope of activity, performing financial assessments and forecasts,
evaluating potential customer usage, utilizing information for research, development
and testing, and adjusting server capacities to accommodate the expected workload.
 

2.3. Statistics and Analytical Tools. We and/or our service providers use analytical
tools, including “Google Analytics” to collect and analyse information about the use
of the Services, such as the frequency of visits to the Services by users, the pages
visited, and any websites or applications accessed before visiting the Services. By
analysing the data we collect, we may compile statistical information across a variety
of platforms and users, which helps us improve our Services, understand trends and
customer needs, consider new products and services, and adapt existing products and
services to customer desires. The information we collect is aggregated and not linked
to Personal Information. We may share the aggregate data with our partners, without
limitation, on commercial terms determined at our sole discretion. For more details on
how Google collects information you can control such use can be found on Googles’
policy page: https://policies.google.com/technologies/partner-sites.
 

2.4. Advertising. We may use your Personal Information to deliver targeted offers
and/or advertisements from third parties based on your personal preferences. If you do
not wish to continue receiving these offers, you can change your user settings in the
Services and thus stop the use of your Personal Information for the purpose of
receiving these offers.
 

2.5. Access to Information. Currently, Ringle employees in the positions of CEO, VP
R&D, CTO, as well as employees in support positions, have access to your
information. The types of positions may change from time to time.
 

3. Artificial intelligence. We process certain personal information using artificial intelligence
algorithms, specifically Google Vision AI. We use these algorithms to process the images that
users like you upload to our Services, to help us ensure that the images meet the Terms of
Use of our Services, and to ensure that our Services are safe for other users. For any question
or problem related to this you can contact: support@ringledating.com.
 

4. Sharing Your Personal Information. You agree that we will share your Personal
Information in accordance with the following:

 

4.1. Service Providers and Third Parties.
 

4.1.1. We may share information, including Personal Information, with service
providers of the following types: storage and server services, infrastructure,
databases and marketing service providers (“Third Party Providers”). These
providers may use the information to: (1) help us provide and/or operate the
Services; (2) assist us in understanding how the Services are used; and (3)
tailor the advertisements shown to you in the application based on your
personal preferences across our Services and other websites and/or
applications you visit.
 

4.1.2. Third Party Providers may be located in countries outside the State of
Israel. Some of these countries may have different levels of protection for
Personal Information or other information than those provided in Israel. You
consent to the transfer of your Personal Information to these countries.

 

4.2. Transfer of Ownership. We may disclose and/or transfer our databases that
contain your Personal Information as part of or during negotiations for a merger, sale
of Company assets or acquisition (including in cases of liquidation). In such instances,
your Personal Information will remain subject to the terms of this Privacy Policy, in
accordance with applicable law.
 

4.3. Complaints and Reports. If someone submits a report related to you (such as an
allegation that you violated our Terms of Use), we may forward to the reporter
information about actions taken in response to their report, if any. However, we do not
undertake to provide any information to a user who has reported another user.
 

4.4. Advertisers. When you click on an advertisement on our Services or on our
advertisement displayed on another website or application, the advertiser will know
that someone has clicked on their advertisement, and they may be able to identify you
through certain methods, such as cookies. We may share your Personal Information
with advertisers in our application: (a) with your consent, (b) when it pertains to
encrypted IP addresses and/or device identifiers, or (c) when it pertains to Personal
Information that is visible to all users of our Services, such as profile information.
 

4.5. Transfer of Information Required by Law. We will cooperate with law
enforcement authorities or any judicial order that requires or instructs us to disclose
the identity, behavior, digital content, or any other Personal Information of any user
suspected of actions deemed illegal or in violation of the law. We may also share your
Personal Information with third parties if we believe in good faith that the disclosure
of the information is appropriate and intended to protect our rights, assets or safety
(including the enforcement of the Privacy Policy) or the rights, property or safety of
third parties.
 

4.6. Sharing Additional Information. We will transfer your Personal Information to
relevant third parties in the following cases: (1) if the Company discovers that your
actions within the Services violate the Terms of Use or were intended to commit fraud

of any kind; or (2) if the Company faces legal action (criminal or civil) as a result of
actions you performed using the Services.
 

4.7. Security. We implement and maintain technical and organizational measures,
policies and procedures designed to reduce the risk of accidental destruction or loss,
or unauthorized disclosure or access to Personal Information in a manner
inappropriate to the nature of that information. The measures we take include:
 

4.7.1. Protection Measures - The physical, electronic and procedural measures
we use to protect your Personal Information include secure servers, firewalls,
antivirus, and SSL encryption of the data.
 

4.7.2. Access Control - We strive to properly manage a dedicated login system
and limit access only to authorized staff based on specific needs according to
the basic authorization rules. We periodically review permissions and revoke
access immediately upon the conclusion of each employee’s employment.
 

4.7.3. Internal Policy - We maintain and frequently review our privacy and
information security policy.
 

4.7.4. Personnel - We require each new employee to maintain confidentiality
in accordance with applicable laws and accepted industry practices.
 

4.7.5. Encryption - We encrypt data in transit using secure HTTPS protocols.
 

4.7.6. Database Backup - Our databases are backed up on a periodic basis for
certain data and verified regularly. The backups are encrypted and stored in
the production environment to maintain their confidentiality and integrity, are
regularly tested to ensure availability, and are only accessible by authorized
personnel.
 

4.7.7. However, no method of Internet transfer or electronic storage is
completely secure. Therefore, while we strive to employ commercially
acceptable measures to protect your Personal Information, we cannot
guarantee its absolute security.
 

4.7.8. Since information security partly depends on the security of the device
you use to communicate with us and the measures you take to protect your
usernames and passwords, you must take appropriate steps to safeguard this
information.
 

 

5. International Transfers.
 

5.1. We hire subcontractors and service providers located in other countries and
transfer the information we receive, including Personal Information, to them. We
carry out these international transfers to achieve the goals mentioned above. We will
ensure that these third parties are bound by written agreements that provide the same
level of privacy and data protection as outlined in this Privacy Policy, including

appropriate legal remedies in the event of a breach of your data protection rights in
the third country.
 

5.2. When we transfer the Personal Information of users located in the European
Economic Area (“EEA”) to third parties located outside the EEA and where required
by applicable law, we will ensure that the information is accorded a similar level of
protection by providing one of the following protections:
 

5.2.1. We will transfer your Personal Information only to countries recognized
as providing an appropriate level of protection for Personal Information by the
European Commission (adequacy ruling).
 

5.2.2. When we use certain service providers that are not located in countries
with a level of protection that meets the conditions of the European
Commission, we may use certain contracts approved by the European
Commission which give Personal Information the same protection as it would
receive in EEA countries.
 

5.2.3. Contact us at support@ringledating.com if you wish to receive more
information about the mechanism we use when we transfer Personal
Information outside the EEA.

 

 

6. Your Rights - How to access and limit our use of specific Personal Information. Subject to
applicable law and certain exemptions, and in some cases depending on the processing
activity we perform, you have certain rights in relation to your Personal Information that we
or other controllers hold about you, as detailed below. For any request to exercise these rights
in relation to information held by other controllers, please contact the relevant controller
directly. If you would like us to notify all other controllers, please state this request when you
contact us to exercise your rights. We will investigate and attempt to address complaints and
disputes and will make every reasonable effort to respect your desire to exercise your rights
as quickly as possible and, in any case, within the time frames provided by applicable data
protection laws. We reserve the right to request reasonable evidence to verify your identity
before we provide you with any information and/or respond to any of your requests, as
detailed below:
 

6.1. Right of Access. You have a right to know what Personal Information we collect
about you, and in some cases, even have this information provided to you. Pursuant to
Sections 13 and 14 of the Privacy Protection Law, 5571-1981, you are entitled to
review your Personal Information either personally, through an authorized
representative with written authorization, or via a legal guardian, as applicable. If you
request to review this information, we will facilitate access in accordance with the
conditions set forth by law and subject to any applicable legal requirements. In cases
where the information is held by a third party (the “Holder”), we will direct you to the
Holder and instruct the Holder to allow the review. Should you determine after
reviewing the information that it is inaccurate, incomplete, unclear, or outdated, you
have the right to contact us (or, if you are a foreign resident, the Holder) to request

correction or deletion of the information. Subject to applicable law, we may charge
you a fee. Please note that we may not be able to provide you with all the information
you request, in which case we will try to explain why.
 

6.2. Right of Data Portability. If the processing is based on performance of a contract
with you and is carried out by automated means, you may be entitled (to ask us) to
provide you or another party with a copy of the Personal Information you have
provided to us in a structured, commonly used and machine-readable format.
 

6.3. Right to Correct Personal Information. Subject to applicable law, you may request
that we update, complete, correct or delete inaccurate, incomplete or outdated
Personal Information. This right exists in accordance with Section 14 of the Privacy
Protection Law, 5571-1981.
 

6.4. Deletion of Personal Data (“Right to Be Forgotten”). If you are a resident of the
European Union, you have the right to request the deletion of your Personal
Information under the following circumstances: (i) it is no longer necessary for the
purpose for which it was collected, (ii) you have successfully exercised your right to
object (see below), (iii) the processing was unlawful, or (iv) we are required to delete
it to comply with a legal obligation. We will not be able to recover information after it
has been deleted. Please note that to ensure that we do not collect additional Personal
Information, you must clear your cookies from any device where you used our
Services. We may retain certain Personal Information (including after your request for
deletion) for auditing and record-keeping purposes or as otherwise permitted and/or
required by applicable law.
 

6.5. Right to Restrict Processing. If you are a resident of the European Union, you
may request that we restrict the processing of your Personal Information under any of
the following conditions: (i) you have contested the accuracy of the information and
requested a restriction until it has been verified; (ii) the processing is unlawful, but
you do not wish us to delete the Personal Information; (iii) it is no longer needed for
the purposes for which it was collected, but we still need it to establish, exercise or
defend a legal claim; (iv) you have exercised your right to object (below), and we are
in the process of verifying our permitted grounds for processing. We may continue to
use your Personal Information after a restriction request under certain circumstances.
 

6.6. Right to Object. If you are a resident of the European Union, you can object to
any processing of your Personal Information for which our legitimate interests are the
legal basis, if you believe that your fundamental rights and freedoms outweigh those
interests. If you raise an objection, we will have the opportunity to demonstrate that
we have compelling legitimate interests that override your rights and freedoms.
 

6.7. Right to Lodge a Complaint with Your Local Supervisory Authority. If you are a
resident of the European Union, you may have the right to lodge a complaint with the
relevant supervisory authority for the protection of Personal Information if you have

concerns about how we process your Personal Information. However, we kindly ask
that you first attempt to resolve these concerns with us directly.
 

7. Data Retention.
 

7.1. Subject to applicable law, we retain Personal Information as necessary and for the
purposes listed above. We may delete information from our systems without prior
notice when we believe that information is no longer needed for these purposes. Data
retention by each of our processors may vary based on the processor’s specific
retention policy.
 

7.2. In certain circumstances, we may retain your Personal Information extended
periods, such as when required by law, regulations, tax, audit, or accounting rules and
in order to maintain an accurate record of your transactions in the event of a
complaint or if we believe litigation regarding your Personal Information or
transactions is likely. To determine the appropriate retention period, we take into
account the amount, nature and sensitivity of the Personal Information, the potential
risk of harm from unauthorized use or disclosure of your information, the purposes for
which we process it, and whether these purposes can be achieved by other means,
alongside legal requirements.
 

7.3. Please contact us at support@ringledating.com if you would like to receive
details regarding the data retention periods for the various types of Personal
Information.