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 Ltd, First Floor, 85 Great Portland Street, London, W1W 7LT. 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

First Floor, 85 Great Portland Street

London,

W1W 7LT

 

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.