Privacy Policy

Last updated: 28-March-2024

1. Application of this Privacy Policy

CouldSee ("we" and "us") respects the privacy of its users and has developed this Privacy Policy to demonstrate its commitment to protecting your privacy. This Privacy Policy governs your use of https://couldsee.app/partnerships ("Service") and describes the data we collect, how it is stored, how that data may be used, with whom it may be shared, and your choices about such uses and disclosures. Please be sure to carefully read the entirety of this Privacy Policy when using our Service.

By accessing the Service you accept this Privacy Policy and agree to the terms, and notices contained or referenced herein. If you do not agree to the terms of this Privacy Policy, please do not use our Service.

2. What kinds of data we collect about you

We collect data you make available to us voluntarily while using the Service. We also collect some type of data automatically (e.g. your IP address).

2.1. Data you give us

You may provide us data in different ways. For example, we collect and store data that you give us when you register user profile ("Profile") or respond to CouldSee's emails or report a problem with the Service.

Account and Profile data. To register your account, you will need to provide us with your name, country of residence, and email address. We will also automatically assign a User ID to your account.

Verified users may be required (where applicable and requested by CouldSee) to record a video as confirmation of their consent to register on the CouldSee website. In the video, the verified users must say: their name, the date of the video recording, their passport number (holding the passport so that the details are visible), that they confirms their registration on the CouldSee website, that they acknowledge to have read and understood the CouldSee website Privacy Policy and confirm that they are using their own Profile.

You may optionally provide additional data on your Profile (complete Profile helps you get the most from our Service). This includes your short biography, profile photo, state and city of residence, phone number, interests and activities, “questions and answers” section information, date of birth, your gender and age, religion, zodiac sign, occupation, photographs, other personal characteristics and demographic data such as your height, weight, body type, marital status, habits, educational background, and hometown. Because you control your Profile, these details are available to you at any time by accessing your "Profile" page, which gives you the chance to correct or update (other than name, date of birth and email address) your data at any time by logging in to CouldSee.

Please do not post or add personal data to your Profile that you would not want to be publicly available. We also do not recommend that you put email addresses, instant messaging details, phone numbers, credit card details, national identity numbers, drivers' license details in your Profile which may make them open to abuse and misuse. Please be careful about posting sensitive details about yourself on your Profile such as religion, health details, sexual preferences or ethnic background. Where you choose to provide us sensitive data about yourself, you are manifestly making this public to other users.

Identity document data ("ID"). You may voluntarily provide us with your ID for Profile verification or we may ask you to provide your ID for security reasons or when we are required to do so by law.

Payment details. To allow you to make payments easier next time, you may save your payment details after making the purchase of credits on our Service. In this case, we will save your zip code, card holder's name, card's expiration date, and the last 4 digits of the card. As a result, next time you would like to make a purchase, you will not have to provide this information manually. If you tick checkbox “Don’t save my card”, we will only save the last 4 digits of your card and the name of the payment system (Visa/Mastercard/American Express)

Requests for technical support. There is a feature on our Service for you to leave your inquiries for user support. When you would like to leave your request, we will ask you to provide us with your name, emails address, phone number, subject line, type of the request (category), the content of the message, and relevant files attached, We will use this information to process your request and deliver our support to you.

2.2. Data we collect about you

We collect data through a variety of sources. One of our sources is cookies that record data about the use of our website. With regard to your use of our Services we may automatically collect the following data:

Navigation data. We collect data about how you navigate and use our Services, such as the types of content you view or engage with or the frequency and duration of your activities.

Cookies and other similar technologies. As further described in our Cookie Policy, our Service uses cookies to distinguish you from other users. You can control cookies through your browser settings.

Browser and Device data. We collect data from or about the computers, smartphones, or other devices where you install or access our Service, depending on the permissions you've granted. We may associate the data we collect from your different devices, which helps us provide consistent Services across your devices. Browser and Device data may include data about your Internet browser type, operating system, hardware version, type and model, geolocation, IP and MAC address, connection data such as ISP, language and time zone, pages visited, and actions performed.

When you visit our Service from third-party resources, we also receive the URL of both the site you came from, your device information, including its ID, your language, country and region information, your IP and MAC address, and date and time of your visit.

Search queries. When you conduct a search for other users on our Service, we automatically record your search queries and criteria you apply to search for the partner. We further use this information to personalise our Service for you and provide you with more relevant suggestions.

Interactions with other users. Whenever you use instant messaging, letter feature, order a gift for the other user, or schedule a date on our Service, we record and process your interactions with other users, including the content of messages and files exchanged, date and time of messages sent, type of the gift ordered, its cost (in credits), female's user ID, female's first name and last name, date and time of the order, its credits cost. This information is being used to provide you with interaction features and, in case of any disputes, provide you with customer support. We may also allow access of our partners to assist the other user with the use of our Service, to deliver the gift on your behalf, and to analyse the interaction statistics of certain users connected with this partner.

Transaction data. When you make payments through the Service, you need to provide financial account data, such as your credit card number, to our third-party service providers. We do not collect or store full credit card number data, though we may receive credit card-related data, data about the transaction, including: date, time, and amount of the transaction, the type of payment method used. Please note: payment information goes to our payment processors and is not collected, processed, or stored by Service.

Advertising. We cooperate with a third-party ad network to manage our advertising on other sites. Our ad network partner uses cookies to collect non-personal data about your activities on this and other web sites to provide you targeted advertising based upon your interests. For more information about advertising and tracking online, visit the Network Advertising Initiative or Digital Advertising Alliance. This website allows consumers to "opt out" of the behavioral advertising delivered by member companies. To learn more about the cookies that may be served through our Service, and how you can control our use of cookies, please see our Cookie Policy.

2.3. Data about Children

We do not collect any data about children, minors or anyone under the age of 18. Nor do we knowingly direct our marketing communication 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 data 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 data, we will take steps to terminate that Profile and delete their personal data.

3. How we use the data we collect

We and our service providers use personal data to: (i) provide the Service; (ii) detect and prevent fraud; (iii) promote, analyse and improve our Service.

In particular, we use your personal data in order:

to provide you with the Services you use or request, for example, we use your data to authenticate you and authorise access to our Services, to suggest your Profile to the users who conduct extensive search by comparing those search parameters to data provided in your Profile.

to improve our Service by using data about your usage and interaction with our Service (traffic analysis). We conduct surveys and research, test features in development. We analyse the data we have to evaluate our Service, and conduct audits and troubleshooting activities to improve our Service content and layouts.

to personalise the Service for you, such as to select the payment processor available to you, we also may use your data to determine your eligibility for promotions, sweepstakes and contests and show you personalised advertisements, if you provided consent on it.

to verify your identity, including during account verification, background checks on users.

to prevent, detect, investigate, resolve disputes and/or remediate malicious activities, fraud, other cybercrimes, take legally-required actions or make sure you are a real person and want to avoid fake accounts being created.

to contact you about our Service matters by email and other ways through our Services, including push notifications. We will send you messages about the availability of our Service, security, payment transactions, status of your orders, legal notices or other service-related information ("Service messages"). We also send messages about your statistics, such as who visit your Profile, add you to favorites list, like you or send you a message ("Statistic messages"), you can unsubscribe from Statistic messages at any time. Please be aware that you cannot opt out of receiving Service messages from us.

to show you advertisements on our Service and/or send you commercial emails about our Service, features, offers, promotions, contests, and events or provide other news or information about third-party services that may be of interest to you. We offer you the choice to opt-out from advertisement and/or commercial emails.

to provide you customer service and support. We will also notify you if we want to use your personal data for a new or different purpose. We will use your personal data for such other purposes only if and to the extent necessary or permitted by applicable law or with your consent.

to share data about usage and interactions with our partners that are connected to our Service and assist female users. They use this information to analyse their performance in connection to the use of our Service.

If you are an individual from the European Economic Area (EEA), our legal basis for collecting and using the personal data will depend on the personal data concerned and the specific context in which we collect it. However, we will normally collect personal data from you only where:

  • (a) we have your consent to do so - to process your special categories of data (explicit consent), to send our marketing emails and collect non-necessary cookies on our website, and to remember your payment details;
  • (b) where we need the personal data to perform a contract with you (e.g. to deliver the CouldSee Service you have requested) - for account and public profile creation and maintenance, to enable interactions with other users, and provide you with technical support
  • (c) where the processing is in our or a third party's legitimate interests (and not overridden by your data protection interests or fundamental rights and freedoms) - to analyse the usage and interaction traffic data for our improvement and marketing purposes, to comply with the requirements of applicable law requirements (where the laws of non-EU countries apply), and to ensure security and fraud prevention on our Service;
  • (d) where we are subject to law requirements of the European Union or those of one of the EU countries.

5. Advertising

5.1. Advertising of other services on CouldSee

We display advertising of third-party services using data you make available to us when you interact with our Service. Our custom system enables us to learn about when and what ads you see, what ads you click. This allows us to provide you with more useful and relevant ads. For example, if we know what ads you are shown we can be careful not to show you the same ones repeatedly.

5.2. Advertising of our Service on other websites

We serve you tailored advertising outside of our Service based on data relating to your access to and use of our Service, as well as data received from third parties. In order to understand and improve the effectiveness of our advertising, we may use cookies and other technologies to identify the fact that you have visited our Service or one of our advertisements on other websites, and we may provide that data to one or more third-party advertising networks. We may choose to work with Google AdWords, DoubleClick, Google Analytics or other advertising networks. Each of these companies has its own privacy policy. The data we provide may include the time and date of your visit to our website, pages viewed, links clicked and other data that does not disclose your identity. We may target advertising to you through a variety of ad networks and exchanges, using data from advertising technologies on and off of our Services like, unique cookie, or similar tracking technology, pixel, device identifiers, geolocation, operation system information, email. The advertising you receive on other websites is customised based on predictions about your interests generated from your use of our Service, visits of different websites.

6. Advertising Choices

You have choices regarding our use and disclosure of your personal data. We offer you choices about receiving advertising.

- Advertising from third parties on CouldSee is tailored to you based on your previous use of Service. You can choose not to receive advertising from third parties by contacting our Customer Service.

- If you no longer want to receive marketing-related emails from us about our Service, you can opt-out of receiving such electronic communications. Please note that if you opt-out of receiving marketing-related emails, we may still send you important administrative messages that are required to provide you with our Service.

7. Retention Period

We will retain personal data for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. We will store your account-related data for two years from your last usage of our Service. Regarding the verification information (Identity document data), we will delete it within 30 days after we conduct the verification of your identity. Payment verification data will be deleted 180 days after your last transaction. Your IP-logs and traffic data will be stored for a term of one year from your last visit on the website.

Please note that we have a variety of obligations to retain the data that you provide to us, including to ensure that transactions can be appropriately processed, settled, refunded or charged-back, to help identify fraud and to comply with anti-money laundering and other laws and rules that apply to us and to our financial service providers. Accordingly, even if you close Profile, we will retain certain data to meet our obligations.

8. How we share personal data

The protection of your personal data is important for us. Your personal data will be shared with third parties only (i) if we have a legal obligation to do so (ii) if the data transfer is necessary for the performance of the contract with you, (iii) if you have consented to the transfer of your data, (iv) if we have joint processing activities with our partners.

Third-party service providers and partner companies will receive your data only if and to the extent necessary for the performance of our contract with you or with your consent. In such cases, the extent to which data is shared will however be kept to the absolute minimum. To the extent that our service providers come into contact with your personal data, we will make sure that they too will comply with all applicable data protection laws.

We do not share personal data with other companies, organisations and individuals unless one of the following circumstances applies:

With your consent. We will share personal data with other companies, organisations or individuals when we have your consent to do so.

Other users. Any data you include on your Profile and any action you take on our Service may be seen by other users.

  • - When you update or add photo (which you can change) is to share it publicly.
  • - When you like, add to favorite or visit another user Profile, that person will see it.
  • - We let senders know when you act on their letters or chat message.

Service providers. We may share your personal data with third parties that perform certain services on our behalf. We use this service to provide hosting for and maintenance of our website, applications development, backup, storage, email marketing assistance, sending you push notifications, performing business and sales analysis, supporting our Service functionality, and supporting contests, sweepstakes, surveys and other features offered through our Service. These Services process your personal data based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures.

Joint controllership. We have third-party partner agencies that are connected to the Service and assist female users with the use of the Service. Jointly with these agencies, we enable the search of your profile for other female users and help them interact with you through the chat, letter, date scheduling, and gift ordering features. We also perform and provide the analysis of interactions with female users to such agencies.

For the purposes mentioned above, we are considered joint data controllers with such third-party agencies. We are ultimately responsible for managing and administering the database with your account data. We ensure the technical and organisational measures for protecting the data, conclude agreements and manage relationships with service and software providers to maintain the database, and provide technical support to the users. You can exercise your rights regarding your data by contacting us directly.

Other Situations. We also may disclose your personal data:

  • - In response to a subpoena or similar investigative demand, a court order, or a request for cooperation from law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us in our sole and exclusive discretion.
  • - When we believe disclosure is appropriate in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of our company, our users, our employees, or others; to comply with applicable law or cooperate with law enforcement; or to enforce our Term and Condition or other agreements or policies.
  • - In connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

9. International data transfers

CouldSee is a global business. We may transfer personal data to countries other than the one in which you live. This country may not have the same data protection law as the country in which you initially provided the data. We deploy safeguards if we transfer Personal Data originating from the European Union (EU) and European Economic Area (EEA) to other countries not deemed adequate under applicable data protection law.

We process data outside of the EU and EEA

In particular, to offer our Service, we need to transfer your personal data to the United States, Ukraine. The United States and Ukraine are not considered to provide an adequate level of protection under EIJ data protection law. It means that these countries do not have the same data protection laws as the country in which you initially provided the data. In all cases, we use European Commission-approved Standard Contractual Clauses as a legal mechanism for data transfers from the EIJ. Learn more about the Standard Contractual Clauses adopted by the EIJ Commission. These clauses are contractual commitments between companies transferring personal data, binding them to protect the privacy and security of the data. CouldSee accordingly adopted Standard Contractual Clauses so that the data flows necessary to provide, maintain, and develop our Service take place legally.

10. Third-party websites

There are a number of places on our Service where you may click on a link to access other websites that do not operate under this Privacy Policy. For example, if you click on an advertisement on our Service, you may be taken to a website that we do not control. These third-party websites may independently solicit and collect data, including personal data, from you and, in some instances, provide us with data about your activities on those websites. We recommend that you consult the privacy statements of all third-party websites you visit by clicking on the "privacy" link typically located at the bottom of the webpage you are visiting.

11. How we protect your personal data

We use a variety of security technologies and procedures to help protect your personal data from unauthorised access, use or disclosure. When personal data is collected on our Service and/or transmitted to other websites, it is protected through the use of encryption, such as the Secure Socket Layer (SSL) protocol. However, data transfers are generally subject to security gaps, please make sure not to provide your login data to any third parties.

12. Changes to this Privacy Policy

We may modify this Privacy Policy at any time. If we decide to make material changes to this Privacy Policy, we will provide notice through our Service, or by other means, to provide you an opportunity to revise changes before they become effective. We recommend that you add CouldSee to your approved sender list, within your email reader.

If you disagree with the changes to this Privacy Policy, you should close your Profile. Your continued use of our Service after we send a notice about our changes to this Privacy Policy means that you are consenting to the updated Privacy Policy.

13. Privacy Rights

  • Opt-out (object against the processing).
    You can to opt-out of:
    • (i) direct marketing communications;
    • (ii) any new processing of your personal data that we may carry out beyond the original purpose;
    • (iii) our marketing analysis of your data;
    • (iv) the transfer of your personal data.
  • The right to be informed;
  • The right to lodge a complaint with a supervisory authority:
    you have the right to raise a complaint with the supervisory authority in the Member State where you live, where you work, or where the infringement took place. You can find the full list of Data Protection Authorities here: https://edpb.europa.eu/about-edpb/board/members_en
  • The right to request access to your personal data;
  • The right to request rectification of your personal data;
  • The right to object to processing of your personal data;
  • The right to request restriction of processing your personal data;
  • The right to data portability:
    If you request the transfer of your personal data to you or to a third party, we will provide your personal data in a structured, commonly used, in machine-readable format;
  • The right to withdraw consent, including the explicit consent to process your special categories of data;
  • Right to erasure (right to be forgotten).

If you wish to exercise any of the rights set out above, please contact us by email: legal@couldsee.app . If emailing us your request, please make clear in the email what personal data you would like to have changed. For your protection, we may only implement requests with respect to the personal data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.

14. Contact Us

If you have any questions or concerns about this Privacy Policy or our collection, use, or storage or your data, please do not hesitate to contact us by e-mail: privacy@couldsee.app