GoSayHELLO
Privacy Policy
Welcome to the GoSayHELLO Privacy Policy (“Policy”)! This explains how we collect, store, protect, and share your information, and with whom we share it. We suggest you read this in conjunction with our Terms and Conditions of Use.
Whilst you’re enjoying the GoSayHELLO mobile application (including the desktop version) (“App”), our websites and microsites (such as GoSayHELLO.com) or using our digital products and services (such as our competitions or surveys) (together, referred to in this Privacy Policy as our “Sites”), we collect some information about you. In addition, you may choose to use the App or Sites to share information with other users, including your friends and contacts (“Users”). We may also need to share your information sometimes.
The App and Sites are global, and your information will be sent to and used in the United States and the UK regardless of the country you reside in. This Policy explains how we protect your personal data when we transfer it overseas, so please read very carefully!
Who we are
The App and Sites are operated by the “GoSayHELLO Group” (also referred to in this policy as “we” or “us”) which includes GoSayHELLO Holding Limited, Badoo Trading Limited and GoSayHELLO Trading LLC, all of which are controllers of personal information collected and processed through the GoSayHELLO App and Sites.
The GoSayHELLO Group has designated a Data Protection Officer and they can be reached by emailing info@GoSayHELLOapp.com or by post at the following address: 651 N. Broad St, Suite 205 #5453 Middletown, Delaware 19709
1. COLLECTION OF INFORMATION.
Registration Information
When you download the App and create an account (“Account”), we may collect certain information (“Registration Information”) about you, such as:
- Name;
- Username;
- Email address;
- Mobile number;
- Gender identity;
- Date of birth;
- Photographs;
- Location; and
- Login information for social media accounts that you connect to your GoSayHELLO Account (this could include, for example, your Facebook and Instagram accounts). For more information about this, see “Linking other Accounts to GoSayHELLO” in section 7 below.
Once you register, you will be able to review and change this information at any time just by logging in to GoSayHELLO (other than your date of birth and location (which, if you have given GoSayHELLO access to your location in your device settings, is automatically updated based on the location of your device)). It is your responsibility to ensure that your account details are kept up to date. If your phone number changes, please ensure that you update this in your account.
The information we collect helps to enhance the App and verify our Users (robots are not welcome!). Registration Information such as your sexual preference, name and username may be visible to other Users who view your profile page.
For Users who are California residents, the data we may collect falls within the following categories of “personal information”, as defined by the California Consumer Privacy Act (CCPA):
- Identifiers, such as name and location;
- Personal information, as defined in the California customer records law, such as contact (including email and telephone number) and financial information;
- Characteristics of protected classifications under California or federal law (if you choose to provide them), such as age, gender identity, marital status, sexual orientation, race, ancestry, national origin, religion, and medical conditions;
- Commercial information, such as transaction information and purchase history;
- Biometric information (not relevant here);
- Internet or network activity information, such as browsing history and interactions with our Sites and App;
- Geolocation data, such as mobile device location;
- Audio, electronic, visual and similar information, such as photos and videos;
- Professional or employment-related information, such as work history and prior employer;
- Non-public education information; and
- Inferences drawn from any of the personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.
Profile Information
We recommend and encourage you (and all our members) to think carefully about the information you disclose about yourself. We also do not recommend that you put email addresses, URLs, instant messaging details, phone numbers, full names or addresses, credit card details, national identity numbers, drivers’ licence details and other sensitive information which is open to abuse and misuse on your profile.
When you post information about yourself or use the messaging function to communicate with other Users, the amount of personal information you share is at your own risk. Please see Section 4 below for more information on who can access what you post on GoSayHELLO.
Purchases Information
If you decide to purchase any of our premium services, we will process your payment information and retain this securely for the prevention of fraud and for audit/tax purposes.
GoSayHELLO uses automated decisions to prevent fraudulent payment transactions being processed as part of its anti-fraud procedures. In order to do this, our systems check payment transactions for behaviour that indicates breaches of our Terms and Conditions of Use. If a transaction meets certain criteria that demonstrate that the Terms and Conditions of Use are likely to have been breached and the transaction is likely to be fraudulent, the relevant transaction may automatically be blocked. Where a transaction is blocked, the user will be notified that their transaction cannot be processed and affected Users can contact GoSayHELLO to contest the decision.
Please note that if your account is blocked for any reason, any account(s) that you have on other GoSayHELLO Group platforms/applications, such as Badoo, may also be blocked as part of our anti-spam and anti-fraud procedures.
Geolocation Information
If you have given GoSayHELLO access to your location in your device settings, when you use your mobile, we will collect information about WiFi access points as well as other location information about your longitude and latitude and may save your device’s coordinates to offer certain features to you. This information helps us identify your physical location and we use it to personalize the App and make it easier for you to interact with other Users, by enabling the general locality information to be displayed to Users seeing your profile and showing you the profiles of other Users who are near you.
If you have given GoSayHELLO access to your location, but wish to turn this off, you can do so by the following methods:
- iPhone app — settings, privacy, location services, GoSayHELLO
- Android — settings, location, GoSayHELLO, permissions, location
Device Information
We may collect information about your device when you use the App including the unique device identifier, device model, operating system, and MAC address, for a number of purposes, as set out in this policy. In addition, if you permit us to do so, the App may access your device’s address book solely in order to add someone to your contacts.
Links
We may keep track of how you interact with links available on GoSayHELLO including third party services by redirecting clicks or through other means. We may share aggregate click statistics such as how many times a particular link was clicked on.
GoSayHELLO Success Stories, Surveys and other Contributions
From time to time, we run surveys for research purposes, and we may contact you to find out if you would like to take part. We may also contact you to find out if you would like to provide feedback, a testimonial or take part in marketing campaigns (for example, if you let us know that you have found a match on the App, we may contact you to ask if you would be happy to feature in advertising for GoSayHELLO). Such surveys and marketing campaigns are optional, and more information will be provided at the point of contact. If you do not wish to be contacted to take part in a survey or marketing campaign, please contact our Customer Support Team via our info@GoSayHELLOapp.com.
When you Contact Customer Support
If you contact our Customer Support team via info@GoSayHELLOapp.com, we will receive your email address, and may track your IP address, as well as the information you send to us to help resolve your query. We will keep records of our communications with you, including any complaints that we receive from you about other Users (and from other Users about you) for 6 years after deletion of your account.
2. USE OF YOUR INFORMATION.
- offer you our services and features
- contact you with information about the App (e.g., updates and new features);
- personalize the App/Sites and the content we deliver to you;
- conduct research and analytics about how you use and interact with the App/Sites;
- resolve disputes, troubleshoot problems and to enforce our Terms & Conditions;
- investigate fraud, protect our legal rights, and to enforce our Terms & Conditions.
- send you information about the promotions and offers we have available – if you’ve signed up for our newsletters or otherwise told us it’s OK (you can withdraw this consent at any time via Settings in the App or by using the opt-out mechanisms and links provided in each message); and
- protect our Users and third parties from harm.
Lawful Basis
Under EU and UK data protection laws, we are required to tell you our lawful basis for using your data and we have set this out in the table below. Where the legal basis is consent, you can withdraw consent at any time. Where the legal basis is legitimate interests, you have a right to object to our use of your data. We explain in the relevant sections in this Policy how you can withdraw consent or opt-out of certain data uses (where applicable).
Purpose for which data is used
To provide you with the GoSayHELLO social networking service
Data
Name, email address, date of birth, location (CCPA Categories A and B)
Source
You provide your name, email address and date of birth to us. We obtain location data from the device that you use to access the service
Legal basis
Contractual necessity
To facilitate networking opportunities on the GoSayHELLO App
Optional information that you choose to provide in your profile, including through profile verification, or adding GoSayHELLO badges, which may include information your sexual preferences, interests, nonbinary gender, religion, ethnic background, photos etc. (CCPA Categories C, H, I, J)
You provide this information to us
Consent
To verify your identity and prevent fraud and to ensure the safety and security of Users
Phone number and if requested, photo provided as part of profile verification and for users based in countries where age verification is required by law: photo of Government ID + geolocation and device information (CCPA Categories A, B, C, F, G and H)
You provide this information to us, except for the geolocation and device information, which we obtain from the device that you use to access the service
Legitimate interests – it is in our legitimate interests to ensure that accounts are not set up fraudulently and to safeguard Users of the site
3. DISCLOSURE OF INFORMATION.
Our policy is to not disclose your Registration Information or personal data, except in the limited circumstances described here:
Circumstances where data may be disclosed
Service Providers – We engage certain trusted third parties to perform functions and provide services to us. We may share your Registration Information or personal data with these third parties, but only for the purposes of performing these functions and providing such services. More information about this is available directly below.
Disclosed data
This could include all data, including all CCPA Categories listed above
Moderators – To monitor activity on the App and approve content.
Payment Processing and Telecommunications Companies – To facilitate payments for our premium services.
Name and user registration details, profile information, content of messages and photographs (CCPA Categories A, B, C, E, and H)
Cardholder name, cardholder address, card number, payment amount, transaction date/time (CCPA Categories A, B, and D)
MORE INFORMATION ABOUT DISCLOSURES
Sharing your personal data with Service Providers
We engage certain trusted third parties to perform functions and provide services to us (“Service Providers”). The suppliers with which GoSayHELLO shares User personal data vary depending on a variety of factors, such as which of our App, Sites and services a User engages with. For example, to provide our services to Users, we typically use the following suppliers:
- Billing services – to allow customers to purchase paid features of our App (for example, Google Play)
- Authentication services – to allow customers to authenticate their account (for example, Twilio)
- Social media providers – to allow customers to create/connect their GoSayHELLO account with their account(s) on such platforms (for example Facebook, Instagram or Spotify)
- Product improvement and market research – we use third party platforms (such as Typeform) and agencies (such as Kantar) to carry out customer surveys and market research to improve our products and services
- IT services – some of the third-party software providers used in the operation of our business may process Users’ personal data (for example, if a User contacts us via social media with a support inquiry, their inquiry is processed by our community management software provider Khoros)
We carry out due diligence on all Service Providers we engage to ensure they have adequate data protection and information security measures in place and only provide them with the personal data necessary to the service they are providing. Measures are taken to ensure that the data shared is non-attributable to the greatest extent possible and our suppliers are also subject to extensive obligations under our contractual arrangements, including strict data retention limits.
Sharing your personal data with Marketing Services Providers
We partner with providers of marketing services (such as Facebook for example) (‘Marketing Services Providers’) to help us market and advertise our App and services on third party websites and applications and measure the effectiveness of our advertising campaigns. For example:
- to exclude you from advertising campaigns aimed at finding new users, if you already have a GoSayHELLO account;
- to show GoSayHELLO adverts to users who have visited the GoSayHELLO App/Sites but haven’t yet created a GoSayHELLO account;
- to show GoSayHELLO adverts to existing Users to encourage them to use the service (for example, when we release new features for the App, we may advertise these features to existing users);
- to create an audience for our advertisements of other potential users who have similar characteristics to you based on the information the Marketing Service Providers holds about you (also known as a Lookalike Audience); or
- to include you in a ‘custom audience’ that will receive GoSayHELLO advertising content (a custom audience is essentially a list of people who we think are most likely to be interested in a particular advertisement)
We share a limited amount of your personal data with these Marketing Services Providers, namely:
-
- the advertising identifier associated with your device (this is a random number assigned by your mobile device manufacturer (for example Apple or Google) to your device to help advertisers (including the manufacturer) know when an ad has been viewed or clicked in an app, and when an ad causes a ‘conversion’(for example, downloading the app advertised to you))
- your estimated location (based on your IP address)
- age and gender
- data about your visit to our Sites or App and action taken on those (for example if you downloaded our App or created an account with our App)
For more information about how we use cookies and other tracking technologies, including how you can set and manage your preferences with regards to such technologies, please see our Cookie Policy.
Some platforms require user consent before GoSayHELLO is permitted to use data gained through the platform for advertising purposes and where this is the case, GoSayHELLO will only use this data where the necessary consent has been obtained. Through your device’s privacy settings, you also have the option to prevent or limit device identifiers being shared with third party advertisers and what use is made of the device identifiers.
In some cases, these third parties will also use the data that they collect for their own purposes, for example they may aggregate your data with other data they hold and use this to inform advertising related services provided to other clients.
4. WHAT OTHERS MAY SEE ABOUT YOU.
We think our Users are awesome, and we want you to share how awesome you are with the world, so we have built certain features to enable this. Our App is designed to make it easier for you to connect with other Users and to interact with them. When using the GoSayHELLO App, you should assume that anything you post or submit on the App may be publicly-viewable and accessible, both by Users and nonusers of the App. We want our Users to be careful about posting information that may eventually be made public.
Please be careful about posting sensitive details about yourself on your profile such as your religious denomination and health details. You may also choose to add sensitive information about yourself when you add certain GoSayHELLO badges to your profile, such as your religion and political leanings. While you may voluntarily provide this information to us when you create your profile, including your sexual preferences, there is no requirement to do so. Please remember that photographs that you post on GoSayHELLO may reveal information about yourself as well.
Where you do upload and choose to tell us sensitive information about yourself, including through the addition of badges to your profile, you are explicitly consenting to our processing of this information and making it public to other Users.
Your GoSayHELLO profile and other information you make available via the App, including certain information added to your profile.
Please also note that in certain countries (currently, South Korea only), Users are provided with functionality enabling them to download a copy of their conversation history (as this is required by local laws) and that GoSayHELLO has no control over how users may then publish or use that information.
If you log in to or access the App through your Facebook account or another third party account on a device which you share with others, remember to log out of the App and the relevant third-party account when you leave the device in order to prevent other users from accessing your GoSayHELLO account.
5. OUR POLICY TOWARDS AGE.
Although we want as many people as possible to enjoy our creation, you have to be at least 18 years old to use the App – sorry kids, we know GoSayHELLO is cool, but you’ll have to come back when you’re old enough! GoSayHELLO does not knowingly collect any information about or market to children, minors or anyone under the age of 18. If you are less than 18 years old, we request that you do not submit information to us. If we become aware that a child, minor or anyone under the age of 18 has registered with us and provided us with personal information, we will take steps to terminate that person’s registration.
6. SECURITY.
Here at GoSayHELLO, we pride ourselves on taking all appropriate security measures to help protect your information against loss, misuse and unauthorized access, or disclosure. We use reasonable security measures to safeguard the confidentiality of your personal information such as secured servers using firewalls.
Unfortunately, no website or Internet transmission is ever completely 100% secure and even we cannot guarantee that unauthorized access, hacking, data loss or other breaches will never occur, but here are some handy tips to help keep your data secure
- Please make sure you log out of your Account after use as you never know who may stumble onto your Account!
- Please don’t share the password you use to access your GoSayHELLO Account with anyone else!
- Change your password periodically
We cannot guarantee the security of your personal data while it is being transmitted to our site and any transmission is at your own risk. If you ever think someone has had access to your password or Account, please follow the steps below.
If you believe that someone else has signed into your GoSayHELLO account there are a few security precautions that we recommend. If you sign in to GoSayHELLO with your Facebook profile we recommend that you update your Facebook password immediately.
Additionally, you can log out of any active sessions involving your Facebook profile by following these steps via Facebook.com
- Go to your Security and Login Settings on Facebook
- Select “Where You’re Logged in”
- Select the session you want to edit and click “End Activity.”
Once you’ve finished linking that secondary login method, you’ll be able to remove your registered phone number. If you sign in to GoSayHELLO with your Apple ID we recommend that you update your Apple ID password immediately.
7. LINKING OTHER ACCOUNTS TO GOSAYHELLO.
Using your social media details to sign in to GoSayHELLO
When you sign into our App using your Facebook account, you give permission to Facebook to share with us your name and profile picture. Unless you opt-out, you also give permission to Facebook to share with us your email address (if there is one associated with your Facebook account), date of birth, profile photos, gender, Page likes and current town/city. If you register or sign in with your Apple ID, you give Apple permission to share your Apple login, a name (that can be edited by you) and an email (you can choose to hide your email and Apple will create a random email address so your personal email can stay private). This email address will be linked to your GoSayHELLO account and will be used to retrieve your GoSayHELLO account. We will then use this personal data to form your GoSayHELLO account. If you remove the GoSayHELLO app from your Facebook settings, or from your Apple ID, we will no longer have access to this data. However, we will still have the personal data that we received when you first set up your GoSayHELLO account using your Facebook or Apple ID (you must delete your GoSayHELLO account entirely for us to no longer have access to this data).
Linking social media accounts to your GoSayHELLO account
You may link your GoSayHELLO account with your Instagram, Facebook or Spotify accounts. This allows you to share some information from those accounts directly to your GoSayHELLO account (for example, Instagram photos, or your top Spotify artists).
We only receive the limited information that Instagram or Spotify permits to be transferred (as detailed by Instagram/Facebook/Spotify and agreed by you when you first connect your account from such platforms with your GoSayHELLO account). If you no longer want to link your GoSayHELLO account to your Instagram, Facebook or Spotify account, please visit the settings in your Instagram, Facebook or Spotify account and follow the instructions to remove the GoSayHELLO app access permissions. Please note that any information already added to your GoSayHELLO account from those platforms will not be deleted unless you delete it within your GoSayHELLO account as well.
8. YOUR CALIFORNIA PRIVACY RIGHTS.
Using your social media details to sign in to GoSayHELLO
For Users who are California residents, you have the following rights (in addition to those listed at section 9 below) under the California Consumer Privacy Act, and you have the right to be free from unlawful discrimination for exercising your rights under the Act:
- You have the right to request that we disclose certain information to you and explain how we have collected, used and shared your personal information over the past 12 months.
- You have the right to request that we delete your personal information that we collected from you, subject to certain exceptions.
California’s “Shine the Light” law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the businesses’ practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes. If you wish to find out about any rights you may have under California Civil Code section 1798.83, you can write to us at info@GoSayHELLOapp.com.
From time to time, as part of a joint promotion with a third party, we may, if you participate in such promotion, disclose your contact information to the third party to allow them to market their products or services to you. Where this is a condition for participation in a promotion, we will always let you know before when you enter the promotion. Please follow the instructions provided to you by third parties to unsubscribe from their messages.
In addition, under California law, operators of online services are required to disclose how they respond to “do not track” signals or other similar mechanisms that provide consumers the ability to exercise choice regarding the collection of personal information of a consumer over time and across third party online services, to the extent the operator engages in that collection. At this time, we do not track our Users’ personal information over time and across third-party online services. This law also requires operators of online services to disclose whether third parties may collect personal information about their users’ online activities over time and across different online services when the users use the operator’s service. We do not knowingly permit third parties to collect personal information about an individual User’s online activities over time and across different online services when using the App.
