OUR COMMITMENT TO YOU

Protecting your privacy is a top priority for Aura. Ensuring your privacy is fundamental in the design and implementation of our products and services that you know and love, so that you can have complete confidence in them and can focus on finding serious dating opportunities.

We appreciate that you trust us when you give us your information, and we take it very seriously.

We make no concessions when it comes to privacy. We design our products and services with user privacy in mind. We bring experts from various fields, including legal, security, engineering, product development and more, to make sure that all decisions are made with privacy in mind.

We strive to be transparent about how we handle your data. Because we use many of the same online services that you do, we know that insufficient information and overly complex language are the most common problems with privacy policies. We take the exact opposite approach: the text of our Privacy Policy and related documents is written in simple language. In fact, we want you to read our policies and understand how we apply them.

We work hard to protect your information. We have specialized departments dedicated to protecting your data. We are constantly updating our data protection practices and working hard to improve information security.

Privacy Policy

Welcome to Aura's privacy policy. Thank you for taking the time to read it.

We appreciate that you trust us with your information and we intend to always live up to your trust. First, you need to understand what information we collect, what we collect it for, how we use it, and what choices you have about using your information. This policy describes our privacy practices in plain language and keeps legal and technical language to a minimum.

This privacy policy is available beginning August 1, 2020.

1. Who we are

The company that is responsible for your information according to this privacy policy (data controller):

AURA PAY, LLC

Antonovicha 48, Suite 3

Kiev, 03150

Ukraine

2. Where our Privacy Policy applies

This privacy policy applies to websites, applications, events, and other services provided by Aura. For simplicity, in this privacy policy, they are all collectively referred to as "services." To make this clearer to you, we have added links to this privacy policy on all relevant services.

Some services may have their own privacy policies. If a particular service has its own privacy policy, then it will be the service's policy and not this privacy policy.

3. The information we collect.

It goes without saying that we cannot help you search for dating if we do not have some information about you, such as basic profile information and characteristics of the people you want to meet. We also collect information that is generated when you use our services, such as access logs, as well as information from third parties, such as when you log in to our services through a social media account. If you would like more information, we will explain it in more detail below.

The information you give us

When you use our services, you give us certain information. That includes:

When you create an account, you at a minimum provide us with your username and password, and some basic information necessary for the service to work, such as your gender and date of birth.
By creating an account you agree to the addition of a biometric template of your face (photo) taken with the camera of the device on which the application is installed. At the same time you give your consent to other users of the Aura network to recognize your face through their device on which the application is installed.
While Aura makes every effort to protect you from unauthorized access or modification, disclosure or destruction of your personal information, we do not guarantee, and you should not expect, that your personal information will always remain secure.
Considering that we have no control over what others will do with your information after you post it, including adding a biometric template of your face (photo) and allowing other Aura users to recognize your face, you agree that Aura is not responsible for the use, preservation, alteration, disclosure or destruction of this information by other Aura users or third parties.
When you complete your profile, you can provide us with additional information, such as your personality, lifestyle, interests and other information, as well as photos and videos. For certain content, such as pictures or videos, you can give us access to your camera or photo album. Some of the information you may share with us is considered sensitive or confidential in some countries, such as your racial or ethnic origin, sexual orientation and religious beliefs. By providing us with this information, you consent to us processing it.
When you sign up for a paid service or make a purchase directly on our site (rather than through platforms such as iOS or Android), you provide us or the payment processor with information such as your debit or credit card number and other financial information.
When you participate in focus group surveys, you share with us what you think about our products and services, your answers to our questions, and your feedback.
When you participate in our promotions, events or contests, we collect the information that you provide when you register or log in.
When you contact our customer support center, we collect information that you provide to us during the call. Sometimes we monitor or record conversations for training purposes and to ensure the quality of our service.
If you ask us to contact someone or otherwise process information about other people (for example, if you ask us to send an email on your behalf to one of your friends), we collect the information that you give us about other people in order to fulfill your request.
Of course, we also process your chat conversations with other users and the content you post to make the services work.

Information we get from others

In addition to the information that you provide directly to us, we also receive information about you from others, including:

Other Users. Other users may provide information about you when you use our services. For example, we may collect information about you from other users if they contact us to provide it.
Other Partners. We may receive information about you from our partners, such as when we publish Aura ads on partner sites and platforms (in this case, they may pass along information about the success of the advertising campaign).

Information that is collected when you use our services

When you use our services, we collect information about what features you used, how you used them, and what devices you used to access our services. See below for more information.

Usage Information. We collect information about how you use our services: how you use them (date and time you log in, features you use, searches, clicks and pages displayed for you, addresses of pages you were redirected from, ads you click on) and how you communicate with other users (e.g., users you contact and interact with, time and date of contact, number of messages you receive and send).
Device Information. We collect information from the devices on which you use our services, including:
hardware and software information, such as your IP address, device ID and type, specific device and app settings and features, app crashes, advertising identifiers (such as AAID for Google and IDFA for Apple, both of which are randomly generated numbers that you can reset in your device settings), browser type, version and language, operating system, time zones, cookie-related identifiers or other technologies that may identify your personal device or browser (for example, IMEI/UDID and MAC address);
information about your wireless or mobile Internet connection, such as your ISP and signal strength;
Information about your device's sensors, such as accelerometers, gyroscopes, and compasses.
Other information provided with your consent. With your permission, we may determine your exact location (latitude and longitude) by various means, depending on the services and devices you use (GPS, Bluetooth connections, or Wi-Fi). Location data may be collected in the background, even when you are not using our services, if you give us permission to collect this information. If you do not give us permission to collect your location information, we will not collect that information. Similarly, with your consent, we may collect your photos and videos (for example, after you post photos, videos or live broadcasts on one of our services).

4. Cookies and similar data collection technologies

We use and may allow others to use cookies and similar technologies (e.g., web beacons, pixels) to recognize you and your devices. You can read our Cookie Policy for more information about why we use them (e.g., to identify you, remember your preferences and preferences, analyze site traffic and trends, implement and evaluate the effectiveness of advertising campaigns so you can use social media features) and how you can control their use through your browser settings and other tools.

Some web browsers (including Safari, Internet Explorer, Firefox, and Chrome) have a "Do Not Track" ("DNT") feature that tells a web site that the user does not want their online activity to be tracked. If a website that responds to the DNT signal receives a DNT signal, the browser can block that website from collecting certain information about the browser user. Not all browsers offer the DNT option, and DNT signals have not yet been unified. For this reason, many businesses, including Aura, do not currently respond to DNT signals.

5. How we use information

The main reason why we use your information is to provide and improve our services. In addition, we use your information for your security purposes and to provide advertising that may be interesting for you. Learn more about why we use your information and read our case examples.

To manage your account and provide you our services

Create and manage your account.
Provide you with customer support and respond to your requests.
To conduct your transactions.
Discuss our services with you, including order management and billing.

Help you communicate with other users

Analyze your profile, activity on the service, and your preferences to recommend you for serious dating and display your profile to appropriate users.
Show members' profiles to each other.

Ensure a seamless experience on your devices

Link the different devices you use to ensure that our services run smoothly on all those devices. We do this by linking devices and browser data, such as logging into your account on different devices or using partial or full IP address, browser version and similar data about your devices to help identify and link them.

To provide new Aura services to you

Register and display your profile in the new Aura features and applications.
To administer your account in these new features and applications.

Provide you with relevant offers and advertisements

Organize giveaways, contests, discounts, or other offers.
Develop, display and track content and ads tailored to your interests on our services and other sites.
Communicate with you via email, phone, social media or mobile device about products or services that we think you may be interested in.

Improve our services and develop new ones

Manage focus groups and surveys.
Conduct research and analysis of user behavior to improve our services and content (for example, we may change the look and feel or even significantly modify a particular feature based on user behavior).
Develop new features and services (for example, we may create a new feature based on interests as a result of requests received from users).

Prevent, detect and combat fraud or other illegal or unauthorized activities

Address current or suspected violations on and off the platform.
Perform data analysis to better understand and develop responses to those actions.
Retain data related to fraudulent actions to prevent their recurrence.

Ensure legal compliance

Comply with legal requirements
Assist law enforcement agencies.
Respect or enforce our rights, such as our Terms and Conditions.

In order to process your information as described above, we rely on the following legal bases:

Providing you with our service: In most cases, the reason we process your information is to fulfill the terms of the agreement we have with you. For example, as you use our Serious Dating Service, we use your information to maintain your account and your profile to make it available for others to view and recommend others to you.
Legitimate interests: We may use your information if we have a legitimate interest. For example, we analyze user behavior on our services for continuous improvement and make suggestions that we think may be of interest to you, and we also process information for administrative, fraud detection and other legal purposes.
Consent: Sometimes we may, for certain reasons, request your consent to use your information. You may withdraw your consent at any time by contacting us at the address listed at the end of this privacy policy.

6. How we share information

As our goal is to help you make connections, most information is exchanged with other users. We also share some information about our users with service providers and partners who help us with our services and, in some cases, with the courts. Read on to learn more about sharing your information with other users.

Sharing your information with other users

You share information with other users when you voluntarily disclose information on the service (including a public profile). Be careful about sharing your information and make sure that the content you share is something you are comfortable posting, as neither you nor we can control what others will do with your information after you post it.

If you choose to limit the audience for all or part of your profile, for certain content or information about you, then it will be displayed according to your settings.

Providing your information to our service providers and partners

We use third parties to support our operations and improve our services. These third parties help us with a variety of tasks, including hosting and maintaining data, analytics, customer service, marketing, advertising, payment processing and security operations.

We may also provide information to partners who distribute and help us promote our services. For example, we may provide limited information about you to advertising partners in a hashed, unreadable format.

We conduct a strict background check before engaging a service provider or working with an affiliate. All of our service providers and partners must agree to strict confidentiality obligations.

With other Aura Pay group companies

Aura is part of the Aura Pay family of companies, which as of the effective date of this Privacy Policy.

We share your information with other Aura Pay group companies to provide assistance on their part in processing your information as service providers, according to our instructions and on our behalf. Assistance provided by other Aura Pay Group companies may include technical data processing operations such as hosting and data maintenance, customer service, marketing and targeted advertising, financial and accounting support, better understanding our service usage and user behavior to improve our service, ensuring the security of our data and systems, combating spam, abuse, fraud and other wrongdoing.

We may also share information with other Aura Pay Group companies for legitimate business purposes, such as corporate auditing, analytics and summary reporting, and to comply with applicable laws. We may also share user information with other Aura Pay group companies to remove users who violate our terms of service or who have been found to be engaged in criminal activity and/or misconduct. In some cases, we may remove such users from all platforms.

For corporate transactions.

We may transfer your information if we are involved, in whole or in part, in a merger, sale, acquisition, split, restructuring, reorganization, dissolution, bankruptcy or other ownership or management change.

When it is required by law

We may disclose your information when necessary to: a) comply with court orders, such as a court order, subpoena or search warrant, government/law enforcement investigation, or other legal requirements; b) assist in preventing or detecting crime (in each case according to applicable law); or c) to protect the safety of the user.

Enforcement of legal rights

We may also release information: a) if disclosure would reduce our liability in an actual or perceived lawsuit; b) as necessary to protect our legal rights and the legal rights of our users, business partners or other stakeholders; c) to enforce our agreements with you; and d) to investigate, prevent or take other action regarding illegal activities, suspected fraud or other violations.

With your consent or at your request

We may ask for your consent to share your information with third parties. If so, we will explain why we want to share the information.

We may use and share non-personal information (i.e., information that does not itself identify who you are, such as device information, general demographics, general behavioral data, geolocation in impersonal form), and personal information in hashed, unreadable form, under any of the above circumstances. We may also share it with other Aura Pay Group companies and third parties (in particular advertisers) in order to develop and place targeted ads on our services, third party websites or applications, and to analyze and report on the ads you see. We may combine this information with additional non-personal information or personal information in hashed, unreadable form collected from other sources. For more information about our use of cookies and similar technologies, check out our cookie policy.

7. Cross-Border Data Transfers

The provision of the information set forth in Section 6 sometimes involves cross-border data transfers, such as to the United States and other jurisdictions. As an example, when a service allows users to be in the European Economic Area (EEA), their personal information is transferred to countries outside of the EEA. We use standard contractual provisions approved by the European Commission or other appropriate safeguards to transfer data from the EEA to other countries. Standard contractual clauses are obligations between companies transferring personal data to ensure that your privacy and security is protected.

8. Your rights

We want you to have control over your information, so we have provided you with the following tools:

Service access/update tools. Account tools and settings through which you can access, correct or delete information provided to us and associated with your account. If you have any questions about these tools and settings, please contact our customer support center
Device permissions. Mobile platforms have permission systems for certain types of device data and notifications (permissions for phonebook services, location information, and pop-up notifications). You can change the settings on your device to allow or disallow the collection of relevant information or the display of relevant notifications. Prohibiting may restrict the functionality of some services.
Deletion. You can delete your account using the appropriate service feature.

We want you to be aware of your privacy rights. Here are some key points you should keep in mind:

Information verification. Laws governing the processing of personal information may give you the right to request information we keep about you (depending on the jurisdiction, this may be called the right to access and verify the completeness and accuracy of the information).
Updating Information. If you believe that the information we hold about you is inaccurate or that we are no longer permitted to use it, and if you would like to request that it be corrected, deleted or restricted, please contact us.

For the protection and security of all our users, we may ask you to provide proof of identity before we can respond to the above requests.

Keep in mind that we may decline requests for certain reasons, including if the request is illegal or may violate another user's trade secrets, intellectual property, or privacy. If you wish to receive information concerning another user, such as copies of communications received from or through our service, the other user must contact our Privacy Officer to provide written consent before the information is released.

In addition, we may not be able to accommodate certain requests that carry objections to the processing of personal information, especially when such requests would prevent us from providing our services to you. For example, we cannot provide you our service if we do not have your date of birth.

Uninstalling an app. You can stop an app from collecting information by uninstalling it in the standard way for your device. If you uninstall the app from your mobile device, the unique identifier associated with your device will be saved. Once the app is installed on the same device, we will be able to re-associate that identifier with your previous transactions and activities.
Liability. In some countries, including the European Union, you have the right to file a complaint with the relevant data protection authority if you have concerns about how we process your personal information. The authority supervising the processing of personal data is located at your place of residence, work or our place of registration.

9. California Residents

If you are a California resident, you may request a disclosure notice about the types of personally identifiable information about you that we have provided to third parties for their direct marketing purposes during the previous calendar year. The deadline to respond to your request is 60 days. For your protection and the protection of all of our users, we have the right to ask you to provide proof of identity before we can respond to such a request.

10. How we protect your information

We work hard to protect you from unauthorized access or the modification, disclosure or destruction of your personal information. Like all technology companies, while we take steps to keep your information secure, we do not promise, and you should not expect, that your personal information will always remain secure.

We regularly review our systems for potential vulnerabilities and attacks, and we regularly review our information collection, storage and processing practices to update our physical, technical and organizational security measures.

We may suspend your use of all or part of our services without notice if we suspect or detect any security breach.

To protect our systems and data from unauthorized access, theft and loss, we have implemented a bug bounty program.

11. How long we keep your data

We keep your data for as long as we need it for legitimate business purposes (as described in Section 5) and in compliance with applicable legal requirements. To ensure the protection and security of our users inside and outside our service, we implement a data retention "security window" of three months after an account is deleted. During this period, the account information will be retained, although the account will, of course, not be visible on the services.

In practice, we delete or anonymize your information when your account is deleted (after the security window) or after two years of continuous inactivity, unless:

we must keep it as required by applicable law (for example, some "traffic data" is retained for one year to comply with our data retention obligations under the law);
we must retain it as evidence of our compliance with applicable law (e.g., records of consent to our terms, privacy policy and other similar agreements are retained for five years)
there is an unresolved issue, claim or dispute that requires us to retain the information until it is resolved; or
the information must be kept for our legitimate business interests, such as fraud prevention and increased user protection and safety. For example, we may need the information to prevent a user who has been disenrolled from opening a new account because of unsafe behavior or security incidents.

Keep in mind that although our systems are designed to perform data deletion processes according to the above recommendations, we cannot promise that all data will be deleted within a certain period of time due to technical limitations.

12. Child privacy protection

Our services are only provided to users 18 years old or older. We do not allow anyone under the age of 18 to use 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, use the reporting mechanism available on the service.

13. Changes to our privacy policy

As we are always looking for new and innovative ways to support serious dating, this policy may change over time. We will notify you before any significant changes take effect so that you have time to review the changes.