Smart Matrimony Ltd
Matchmaker Privacy Policy
Smart Matrimony respects
your privacy and the privacy of your Clients and has developed this Privacy Policy
to illustrate how we are committed to the protection of your privacy and your Personal
Data.
1. Definitions
“Matchmaker/Customer”
means a matchmaker that has
applied to join, and has received approval to access, the Smart Matrimony matchmaker
portal.
“Client”
means a client of the matchmaker.
"
Client
Data
" means any Client Personal Data that We process on behalf of the
Matchmaker as
a Data Processor in the course of
providing Services, as more particularly described in this Policy.
“"
Data
Controller
" means an entity/person that determines the
purposes and means of the processing of Personal Data.
"
Data
Processor
" means an entity that processes
Personal Data on behalf of a Data Controller.
“Data Protection Laws”
means the
General Data Protection Regulation (GDPR).
"
Personal
Data/Information
" means any information
relating to an identified or identifiable natural person.
“Service”
means any product or service provided by Smart
Matrimony to Customer pursuant to the
Terms and Conditions.
“We/Our”
means Smart Matrimony.
2. You and your Clients
As a Matchmaker that is part
of our Matchmaker network that uses the Smart Matrimony online portal, you will
provide Personal Data about yourself and that of your Clients to Smart
Matrimony.
3. Role of the parties
Smart Matrimony shall
process the Personal Data of a Matchmaker in its capacity as Data Controller.
You, the Matchmaker/Customer,
are the Data Controller of the Client Data and Smart Matrimony shall process
the Client Data only as a Data Processor acting on your behalf.
The Matchmaker agrees that (i) it shall
comply with its obligations as a Data Controller under Data Protection Laws in
respect of its processing of Client Data and any processing instructions it issues
to Smart Matrimony and (ii) it has provided notice and obtained (or shall
obtain) all consents and rights necessary under Data Protection Laws for Smart
Matrimony to process Client Data and provide the Services pursuant to the Terms
and Conditions and this Policy.
4. Overview
This policy describes:
- The protection of your
personal information and data security
- What data and
information we collect
- The purpose of
collecting the data and information and how we use it
- Our legal basis for processing
data
- How we store and transfer
data
- What rights you/your Clients
have under GDPR
- How you/your Clients
can exercise rights under GDPR
- Data retention and
account deletion
- How we will notify you
of changes to this policy
- How to contact us with
questions
We encourage you to read
this Privacy Policy carefully when using our website or services. By using our
website, you are accepting the practices described in this Privacy Policy.
Finding a suitable
partner for your Clients requires collecting Personal Data to process and use.
As a reputable matchmaking service we place great emphasis on the responsible
use, processing and protection of all Personal Data we collect. Therefore, we
have established a comprehensive system of technical and organisational
measures that aim to provide maximum data security:
(a) For example, all the
data that you send to us after registration or Login (e.g. contact information,
profile information etc) is SSL-encrypted (Secure Socket Layer).
(b) Firewalls protect the
information from unauthorised access.
(c) Access to your
information, and that of your Clients, is granted only to a few selected and
properly trained personnel and only with the intention and purpose of providing
you with the best service.
Our Privacy Policy has
been drafted in compliance with the relevant European Union data protection law
(GDPR).
Since contact with other Smart
Matrimony users is always made via a private messaging system, at no point will
your/your Client personal contact details, such as email address or full name,
be transmitted. Only you can decide when you provide such information to others
in the Smart Matrimony matchmaker network. For this, we advise you to heed our
guide to effectively interacting with other Matchmakers part of our network as
found in the Matchmaker Guidelines.
5. The protection of your personal
information
The website is operated
by Smart Matrimony Limited, a company registered in England and Wales with company number 1068458
It is the responsible entity and Data Controller for the purposes of the GDPR.
Smart Matrimony Ltd is a
reputable internet site that helps you to find the right partner for your Clients.
The protection of your Personal Information and that of your Clients is very
important to us. We comply with the requirements of the GDPR.
In order for Smart
Matrimony Ltd to operate effectively, Personal Data are collected, processed or
utilised ("used"). We can, for the purposes of advertising, market
research and to improve our services further analyse user profiles, but only if
you have not made use of your legal right to object to this use of your data at
any time.
In the following
sections, we explain in more detail how we ensure the protection of your Personal
Data and what data will be used in what way if you decide to join the Smart
Matrimony matchmaker network and use the Smart Matrimony service.
If you have questions or
concerns on any aspect of this Privacy Policy, our customer service is at your
disposal at any time. You can reach our customer service via the Contact Us
page on the website.
6. Data security and protection
All information you
submit at and during registration or login to us (e.g. contact information,
profile information etc) is encrypted. This encryption protects the
confidentiality of data exchanged between you and our web server, and helps to
prevent any misuse of data, e.g. by interception.
The encryption technique
we use is SSL (Secure Socket Layer). It is an accepted and widely used
technology. In view of our databases, all technical precautions have been taken
to save your data in a secure environment. Access to your/your Client
information is limited to only a few selected employees and will be granted
only for the purposes of the provision of this service, quality control, the
review of complaints and for preventing fraud.
7. Collection, processing and use of
data
Smart Matrimony is a
service on the internet that brings people together who are looking for
marriage. To provide this service, we collect, process and use a range of
personal information.
One aspect of our service is our matchmaking portal which
is akin to a CRM
(Client Relationship Management) platform. The platform:
·
Aims to help Matchmakers manage their Clients in an efficient and
effective manner
·
Provides Matchmakers with access to other Matchmakers who are part of
the Smart Matrimony network
·
Provides Matchmakers with access to Smart Matrimony’s community of
registered users.
As part of providing this
service we collect a range of information about the Matchmaker and their
respective Clients. The type of information we collect in order to provide this
service is listed below (this list is not exhaustive):
Matchmaker:
-Name
-Email address
- Phone number
-Location
-Gender
-Occupation
Client:
-Name
- Email Address
-Phone number
- Gender
- Age
-Location
-Education and occupation
-Marital status
-Ethnicity and nationality
-Your appearance
-Your religion
Your direct contact
information and that of your Clients (e.g. Name, e-mail address) are not
visible to other members.
The collection of Personal
Data at Smart Matrimony is carried out with the principal aim of giving the Matchmaker
a safe, smooth, efficient, and personal experience. The data is therefore used
to provide the services requested and desired by the Matchmaker.
The information collected
is used for three main purposes:
1. Creation of the Matchmaker’s
profile
Each Matchmaker on the Smart
Matrimony website has an individual profile page. This information is visible
to other Matchmakers and forms a key part of the interaction that our Matchmakers
have with one another
Direct contact
information of the Matchmaker is never visible to other Matchmakers.
2. Creation of the Client
profile
Each of your Clients on
the Smart Matrimony website will have an individual profile page. This page
summarises their information which is visible to other Matchmakers. This
visibility allows Matchmakers to search across the entire network of Clients
helping all Matchmakers within our network to find suitable matches for their Clients.
Direct contact
information of your Clients is never visible to other Matchmakers
3. Analytics
Smart Matrimony will use
the Matchmaker and Client information to learn more about its users to enhance
and develop its services as well as its marketing efforts.
In the following, the use
of personal data is described in more detail:
a)Other Matchmakers can see your profile
information and that of your Clients on Smart Matrimony. Direct contact
information is not visible to other Matchmakers.
d)Other Matchmakers can send you messages.
However, at no point does Smart Matrimony give out or disclose your e-mail
address. Messages are only sent through your Smart Matrimony mailbox. You have
the ability to "block" any undesirable contact if you would like to
prevent such users from contacting you.
e)Smart Matrimony sends various
notifications via e-mail to every registered user.
i.In the context of
customer relationship and customer service messages, we will inform you if, for
example, you have been sent a message. You can regulate which notifications you
receive from your Account Page.
ii.
We will also send you news, general updates, information and
special offers pertaining to Smart Matrimony. You can regulate which
notifications you receive from your Account Page. You may also unsubscribe by
following the unsubscribe link in a received email.
iii.Information messages
pertaining to the service, such as the confirmation of a paid membership,
customer service contact, and on the conclusion of a paid membership in the
form of contract documents, payment processing information, etc., are part of
our service and therefore cannot be cancelled.
iv.We hereby notify you that we
carry out statistical analysis on the opening and viewing behaviour of our
emails. This is done with the help of small graphics that are embedded in the
messages (called pixels). If you do not wish to have your viewing behaviour
analysed, you can disable graphics by default in your email client. For more
information, please see instructions offered in your email client, i.e.
Microsoft Outlook. Once images are deactivated, the messages are not displayed
in full, and message functionality may be limited.
f)Smart Matrimony sets a filter to
protect users from inappropriate keywords in received messages.
8. Use of Cookies and similar tracking
technologies
Cookies provide
information regarding the computer/device used by a visitor. We employ the use
of cookies, and may use similar tracking technologies, to gather information
about your computer/device, in connection with the performance of our services
and in order to improve our website. We may gather information about your general
internet use by using the cookie. Where used, these cookies are downloaded to
your computer and stored on the computer’s hard drive. Such information will
not identify you personally. It is statistical data. This statistical data does
not identify any personal details whatsoever. You can adjust the settings on your
computer to decline any cookies if you wish.
9. Our legal basis for processing
data
We collect and use the
data that we have in the ways described above:
i.As necessary to provide to you the Services
for which you have registered with Smart Matrimony;
ii.Consistent with your consent, which you
provide during the registration. You may revoke this consent at any time by
deleting your account.
10. Storing Your Personal Data
Smart Matrimony does not
transfer your data to locations outside of the European Union.
Smart Matrimony uses
sub-processors to process customer data. Smart Matrimony shall enter into a
written agreement with the sub-processor imposing data protection terms that
require the sub-processor to protect the customer data to the standard required
by data protection laws.
We do our upmost to
ensure that all reasonable steps are taken to make sure that your data is
treated and stored securely. Unfortunately we cannot guarantee, with complete
certainty, that the sending of information via the internet is totally secure
and on occasion such information can be intercepted. Therefore, we cannot
guarantee, with complete certainty, the security of data that you choose to send
us electronically. Sending such information is entirely at your own risk.
We have established a
comprehensive system of technical and organisational measures to help ensure
data security such as:
(a) All the data that you
send to us after registration or Login (e.g. contact information, profile
information etc) is SSL-encrypted (Secure Socket Layer).
(b) Firewalls protect the
information from unauthorised access.
11. Data Transfer to Third Parties
When we transmit data to
other members within the framework of the provision of the service, this is
only in connection with the user name you choose. Under no circumstances do we
share with other Matchmakers direct contact information (such as your name,
e-mail address). Some data that you specified when creating your Smart
Matrimony profile are always visible to other Matchmakers. The data is limited
to: User Name, Location.
Other Matchmakers can see
your Client data however this does not include any direct contact information
(such as name, email address). When we transmit data to other members within
the framework of the provision of the Service, this is only in connection with
the user name of your Clients.
Personal Data will only
be passed on to third parties if necessary to provide the service offered (e.g.
payment processing for fee-based memberships).
Smart Matrimony does not
sell its data to third parties.
We will not disclose your
Personal Information to any other party other than in accordance with this Privacy
Policy and in the circumstances detailed below:
-In the event that we sell any or all
of our business to a potential buyer.
-Where we are legally required by law
to disclose your personal information.
-To further fraud protection and
reduce the risk of fraud.
12. Your rights under GDPR
i. Right to access and
data portability
You have the right at any
time to receive information about the Personal Data and settings we store for
your account. Please note that we reserve the right to charge a fee to cover
any costs incurred by us in providing you with the information.
Most of the information
we store for your account can be viewed directly from your profile page.
ii. Right of
rectification and erasure/cancellation
You have the right at any
time to receive information about the Personal Data and settings we store for
your account, and to ask these to be corrected or deleted. Please note that we
reserve the right to charge a fee to cover any costs incurred by us in providing
you with the information.
Your right to erase data
may be limited by legal and regulatory retention requirements that we need to
consider. In addition, courts, law enforcement agencies or other authorities
can demand by law to retrieve data or request information.
For information,
correction or deletion requests please contact us via the Contact Us page on
the website.
Most of the information
that you can see on your account can be changed yourself. You can also delete
your account yourself. Therefore, please only use this service if it is for
information you cannot change on your own.
iii. Consent and right to
objection
If we use data for a
purpose which, by provisions of law, requires your consent, we will always ask
for your explicit agreement and record your consent. You can revoke your given
consent at any time by deleting your account. You can also object to future use
of your data.
To revoke consent or make
an objection, a simple message to us is sufficient. For this you can use the
Contact Us page on the website.
Please note that in case
of an objection against the use of certain data, it may be impossible to
provide some or all of the services we offer on the Smart Matrimony platform.
We are at your disposal for any questions about this.
13. Cooperation
Our Services provide the Matchmaker with a number of
controls that the Matchmaker may use to retrieve, correct, delete or restrict Client
Data, which the Matchmaker may use to assist it in connection with its
obligations under the GDPR, including its obligations relating to responding to
requests from Clients or applicable data protection authorities. To the extent
that the Matchmaker is unable to independently access the relevant Client Data
within the Services, Smart Matrimony shall (at the Matchmaker’s expense)
provide reasonable cooperation to assist the Matchmaker to respond to any requests
from Clients or applicable data protection authorities relating to the processing
of Personal Data under the Terms & Conditions. In the event that any such
request is made directly to Smart Matrimony, Smart Matrimony shall not respond
to such communication directly without the Matchmaker’s prior authorization,
unless legally compelled to do so. If Smart Matrimony is required to respond to
such a request, Smart Matrimony shall promptly notify the Matchmaker and
provide it with a copy of the request unless legally prohibited from doing so.
14. Data Retention and Account Deletion
Your data and that of
your Clients’ will continue to be processed for as long as you have an account
on Smart Matrimony.
Processing of your data and
that of your Clients’ will cease at the point you no longer have an account
with Smart Matrimony.
Your right to erase data
may be limited by legal and regulatory retention requirements that we need to
consider. In addition, courts, law enforcement agencies or other authorities can
demand by law to retrieve data or request information.
15. Third Party Links
On occasion we include
links to third parties on the website. Where we provide a link, it does not
mean that we endorse or approve that site’s Privacy Policy. You should review
their Privacy Policy before sending them any personal data.
16. Further Information
Every Internet user
should be aware that the information provided by them and published online can
be accessed and saved worldwide by other Internet users. Smart Matrimony
expressly points out to the user that the protection of data transmission in
open networks like the Internet according to current technology can never be
absolutely guaranteed. Therefore, you always need to be aware that you are
moving in a public space and please treat your private data responsibly.
17. Notification of changes to this Privacy
Policy
We'll notify you when we
make changes to this policy and give you the opportunity to review the revised
policy before you choose to continue using Smart Matrimony.
We will notify you via
email and will also post notifications on the website.
18. How to contact Smart Matrimony
with questions
The Data Controller responsible
for your information is Smart Matrimony Ltd, whose registered office address
is:
Smart Matrimony Ltd
registered in England and Wales with company number 1068458
Smart Matrimony Ltd can
be contacted online via the Contact Us form found on the website or by email
at:
admin@smartmatrimony.co.uk
You also have the right
to lodge a complaint with Smart Matrimony Ltd's lead supervisory authority, the
Information Commissioner's Office (www.ico.org.uk), or your local supervisory
authority.