Privacy Statement

WELCOME TO INNER CIRCLE

Privacy Statement in Dutch (Netherlands)

Your privacy is important to us. We comply with the General Data Protection Regulation (GDPR) and other relevant legislation on the protection of Personal Data (collectively referred to as Privacy Legislation). In this Privacy Statement you can read which Personal Data we process and how we store, protect and use your Personal Data. Furthermore, you can read for which purposes and on which legal grounds we process your Personal Data and how you can exercise your privacy rights

This Privacy Statement applies to all your use of the exclusive online dating platform, Inner Circle (available as a mobile app and also accessible via www.theinnercircle.co and m.theinnercircle.co), and all the services that we offer via this App and this Website, among which our member events. Hereinafter, altogether, our Services.

At the bottom of this statement, you can find information on the cookies we use on the Website.

Personal Data

In this Privacy Statement, your Personal Data refers to all information by which a person can be identified, directly or indirectly. This definition is in accordance with the Privacy Legislation.

Are you younger than eighteen years old?

If you are younger than eighteen years old, you cannot make use of our App and Website.

Mandatory information
When you engage our Services, it may be legally or contractually required that you provide us with certain Personal Data, as indicated with a (*) in the following clauses. For example, we need your name, username and at least one picture to provide you with an active account. Where you do not provide us with such information, this will usually imply that we will not be able to provide you with specific Services or perform part of our agreement with you

Which Personal Data do we process?

Before you can use our dating platform, we will ask you to register and create your personal Inner Circle account (Account). In this respect, you are invited to provide us:

Your first name and last name;
Your email address;
Your age/date of birth;
Your job/function;
One (or more) clear picture(s) of you.

You can create your Account through your phone number, Google, Apple or Facebook. These platforms will share with us some (personal) data you have shared with said platforms - such as your Account name, pictures, gender, wall posts and friend information. You may choose to exclude some of the personal data from being shared with us.

After creating your Account, you will be put on our waiting list for approval. Only after you are approved as a member of Inner Circle, your Account will be visible to other members. While still on our waiting list, we save the Personal Data you have provided us with. If you want to be removed from our waiting list and want us to erase your Personal Data - please send us an email via support@theinnercircle.co.

After your Account has been approved, you can complete your Account with the following information (all optional):

A description of yourself;
Geolocation and residence;
Nationality;
Education;
Job title and industry;
Height and weight;
Whether you smoke:
Whether you have children;
Date ideas, favourite spots, travel plans, hobbies and interests;
Preferences regarding matches/potential partners, such as sexual preference, age, height and weight, location, education, smoking, children, nationality and working sector.

If you make use of our paid Services, we use an external payment service provider to process certain payment details. Payment details are not stored by us.

If you download the App on an Apple device, you can only purchase a subscription through the Appstore, paid to Apple. We use an Apple token as an identifier and do not receive or process your Appstore information.

Furthermore, we will process your IP address, login information, (chat) messages, customer service history, time zone settings and browser language.

To maintain and/or improve the quality of the Website/App, we also track, record, and analyze your use of the Website/App. In this context, we process your:

likes, logins and browsed pages;
date and time of visits;
mouse movement and mouse clicks;
technical information as screen resolution, operating system, browser type and device type. (“Usage Data”)

The Usage Data are linked to your profile data.

Your Account (including picture) might be displayed on the shielded homepage of Inner Circle. Your Account may also be tagged in pictures that appear in shielded areas on the Website, App, Facebook, Instagram or any other media. Shielded means that the displayed content will only be visible for other members of Inner Circle. From time to time, we send promotional emails to members featuring selected accounts. We assess and monitor email delivery performance using third-party services. Your email address is anonymized before the email delivery performance is shared with the third-party service provider and us.

We take photographs during events which we organize which may include pictures of you and we may use these photographs for (external) promotional purposes.

How do we use your Personal Data?

PERSONAL DATA AND PURPOSE(S):	LEGAL GROUND(S):
Email address is used to:
keep you informed of your membership status; notify you of new messages and other activity regarding your Account; point out accounts of other members that might be interesting for you; keep you informed on events we organize; contact you with regard to (overdue) payments and other troubleshooting.	We may process these personal data, because this is necessary to perform our agreement with you (i.e. giving you access to the Website and App through your Account and providing our services). Next to that, we have a legitimate interest to inform you about your membership status, account activity and other service updates from Inner Circle. Every email contains a link via which you can unsubscribe from the mailing. You can also unsubscribe via the settings in your account. Next to that, you can manage your preferences for all email messages in your account settings.
Login details are used to:
verify your identity when logging in; provide your access to your account.	We may process these personal data, because this is necessary to perform our agreement with you (i.e. giving you access to the Website and App through your Account).
Personal data on your account is used to:
allow you to use your Account; show your Account to other members; allow other member to find you via targeted searches on the basis of first name, height, age and other information that members share via their accounts; show you mutual connections you and other members have on Facebook or LinkedIn (depending on whether and which profile you used to make an Account); prevent, detect and combat illegal or unauthorized activities on the Website/App. anonymise for the purpose of (statistical) analyses and scientific research with anonymized data only.	We may process these personal data, because this is necessary to perform our agreement with you. With regard to the prevention, detection and combat of illegal activities, we process personal data on the basis of our legitimate interest to ensure the users of the Website/App can engage with each other in a safe and pleasant way. This includes personal data included in/derived from notifications from other users regarding possible illegal or unauthorized activities performed with your account. With regard to the act of anonymisation, we do this on the basis of a legitimate interest to perform research and the development of our services in order to optimise the user experience, without using personal data to do so.
Pictures you upload are used to:
add to your Account and thus display to other members; include in email messages from Inner Circle to other members that might be a good match; select the best quality pictures for you via API’s (see more information below).	We may process these personal data, because this is necessary to perform our agreement with you. You may always delete or change your pictures within your Account.
Photographs taken at events are used to:
publish on our platforms for attendees and other members to see; publish for promotional purposes.	We only process the personal data for these purposes after you have given us your consent to do so, In this respect, we will of course consider your privacy. For example, we try to use such photographs for marketing purposes in other countries than where the event took place. You may withdraw your consent at any time. Once we have received your withdrawal, we will stop processing the personal data you have provided on the basis of this consent. Please be aware that this may take some time, due to the cost and effort involved in phasing out the materials containing your personal data. Of course, we will do our best to remove the personal data within due time.
Your geolocation and/or residence is used to:
share your current residence with other members nearby, based on your residence; show you which other members are nearby you at a particular moment, based on your geolocation; to show in which area you are.	We may process these personal data, because this is necessary to perform our agreement with you. You may always stop sharing your location and the location map in your profile within your Account under settings. Your geolocation will be shared with other users. Please note that we never share accurate geolocations with Inner Circle members – the accuracy is limited to 100 meters and 4 kilometers on the map in your profile.
Date of birth is used to:
calculate and verify your age; show your age on your Account; to search and match based on set preferences by you and other members; show on your Account when it is your birthday.	We may process these personal data, because we have a legitimate interest to do so (i.e. making sure you are old enough to create an Account and show your age on your Account, so other members can take this into account).
Payment Details are used to:
process your payments; include in our records for the benefit of the national tax authorities.	We may process these personal data, because this is necessary to perform our agreement with you (i.e. process your payments). We are also legally obligated to share certain payment details with the national tax authorities.
Your (chat) messages are used to:
give you access to your chat-history automatically filter messages for inappropriate content (e.g. offensive or aggressive language, or unlawful use of our platform for advertisements or link-building).	We may process these personal data, because this is necessary to perform our agreement with you (i.e. provide you the option to chat via your Account). With regard to automatically filtering messages for inappropriate content, we process personal data on the basis of our legitimate interest to ensure the users of our Services can engage with each other in a safe and pleasant way.
Your customer service history is used to:
keep a record of your correspondence with us; optimize our service level towards you based on (previous) correspondence.	We may process these personal data, because we have a legitimate interest to do so (i.e. provide you with the best service possible.)
Browser language and IP address are used to:
address you in the language you speak; determine which events we organize might be interesting to you.	We may process these personal data, because we have a legitimate interest to do so (i.e. provide you with the best service possible).
Information regarding your use of the Website/App:
We use this information to maintain and/or improve the quality of the Website/App; provide you with better matches.	We may process these personal data, because we have a legitimate interest to do so (i.e. provide you with the best service possible).
Information regarding e-mail delivery:
We use this information to: improve the quality of our mailings	We may process these personal data, because we have a legitimate interest to do so (i.e. provide you with the best service possible). Your email address is anonymized before the email delivery performance is shared with the third-party service provider and us.

Non-Personal Data

We may also process non-Personal Data whenever you interact with our Website or App. This data may include your browser type and version, the type of your computer and technical information about your means to connect to our Websites (such as your operating system and platform, and the utilized internet service providers).

We use IDFA token, a unique anonymise user ID by Apple, for payment and attribution purposes, and to deliver customized advertising. A token is a random device identifier assigned to a users device. The token is used for tracking and identifying a user (without revealing personal information), by accessing aggregated data.

Push notifications from Inner Circle

If you have given us permission via our App, we will send you push notifications via our App to inform you about your membership status and to notify you of new messages and other activity regarding Your Account. We may also send you push notifications with suggestions of people you might like and events that are organized in or nearby your place of residence. Push notifications can be controlled under settings in the app.

How to delete your account?

You can delete your account at any time under settings
Note: uninstalling the app does note delete your account

How long do we retain your Personal Data?

We retain your Personal Data no longer than strictly necessary or as long as allowed by law, whichever is shorter. Of course, you can always contact us with a request to delete you from our records.

Invite friend

If you use the ‘Invite friend'-feature to invite someone to Inner Circle, we will send an email message to the email address you submitted to us. We won't share this email address with anyone else. We will tell the recipient that you have asked us to send this message. By choosing to use the ‘Invite friend’-feature you confirm that your friend is happy to receive the email. You also hereby agree to indemnify and hold Inner Circle harmless from all claims arising out of your messages to any person through Inner Circle. You must and will not use our ‘Invite friend’-feature to send spam.

How do we protect your Personal Data?

We work hard to protect your Personal Data from unauthorized or unlawful access, alteration, disclosure, use or destruction. We take appropriate technical and organisational measures to secure the Personal Data. For example, we encrypt our services using SSL, the data are only accessible through a secret password and digital signatures, and our employees only have access to your data on a need-to-know basis. Although we will take all reasonable measures, we cannot guarantee the security of your data transmitted to our Website; any transmission is at your own risk.

Who do we share your Personal Data with?

We do not sell your Personal Data to third parties. However, we may need to share Personal Data with third-party service providers to assist us in operating the Website and App and/or to conduct some processing of your information on our behalf as described below.

For payments made via our Websites, we e.g. use third-party services such as Adyen and Paypal. These third parties are contractually obliged not to use any personal data for any other purpose than to effectuate the payment.
For the selection of your profile pictures, we use external software, specifically face API’s. In this respect the external software provider act as a Data Processor, i.e. that they are contractually obliged not to use your information for any other purposes than to help us effectuate and improve the selection of user pictures within the context of our Website and Apps.
To track, record and analyze your use of the Website/App, we use third-party analysis tools. These third-parties act as a Data Processor, i.e. that they are contractually obliged not to use your information for any other purposes than to help us analyze your use of the Website/App.
We use third-party hosting services to store and access (personal) data. These third-parties act as a Data Processor, i.e. that they are contractually obliged not to use your information for any other purposes than to help us store and access (personal) data.
We use third-party services to assess and monitor email delivery performance. These third-parties act as a Data Processor, i.e. that they are contractually obliged not to use your information for any other purposes than to help us analyse your use of the Website/App.

Your personal data outside the EU

Where personal data is transferred to a third party outside the EU, we will take reasonable measures to protect this personal data as if it was processed in the EU.

Changes to this Privacy Statement

We are constantly looking for new ways to improve our Website and App. We may update this Privacy Statement from time to time. When we change this Privacy Statement in a significant way, we will post a notification on our Website and App along with the updated Privacy Statement.

Your rights

As laid down in the Privacy Legislation, you have the right to:

Ask us to rectify or update your Personal Data;
Ask us to remove your Personal Data from our systems;
Ask us for a copy of the Personal Data we process of you. We can also transmit such copy to another controller at your request;
Withdraw your consent to process your Personal Data. This only affects the processing activities that are based on your consent and does not affect the validity of such processing activities before you have withdrawn your consent;
Object to the processing of your personal data;
File a complaint with the Dutch Data Protection Authority, if you believe that we process your personal data unlawfully.

If you have any questions, comments or concerns regarding the manner in which we handle your personal data, please contact us through the contact data below.

Please note that you can also view, edit or delete your Personal Data by logging in to your Account.

COOKIES STATEMENT

What are cookies?

Cookies are little (text) files which are stored on your device. Your web browser stores these cookies when you visit our Website: theinnercircle.co Inner Circle. These cookies will be retrieved when you visit or use our Website again. This allows us to recognise you as a previous visitor/user.

Why do we use cookies?

By using cookies, we can see how our Website is used and how we can optimize our Website and services. Cookies are also helpful to make the Website quick and safe. In addition, cookies by us or by third parties can be used to show you relevant advertisements based on your interests. See the table below for the specific purposes of each cookie we use.

Which cookies do we use?

COOKIE & PERSONAL DATA PROCESSED	FUNCTION/PURPOSE
Google Analytics:
Hashed IP addresses, user ID. Also collects and aggregates certain demographic data if available: age, gender and location. This data is retained for a period of 26 months.	We use this cookie for tracking purposes, to gain insights from visitors and their interactions in the web/ app. And for advertising purposes, so we can improve the ad serving experience to our audience.
Facebook Pixels (Facebook Connect & Facebook Custom Audience):
IP addresses, information about the web browser, page location, document, referrer and person using the website. Click data. If signing up with Facebook: email, gender, location, phone number and name. We use the data on the basis of a legitimate interest at most as long as your interest in deletion or anonymization does not prevail.	We use this cookie for tracking purposes, to gain insights from visitors and their interactions in the web/app. And for advertising purposes, so we can improve the ad serving experience to our audience.
Pinterest:
IP addresses, information about the web browser, page location, document, referrer and person using the website. And click and interaction data. We use the data on the basis of a legitimate interest at most as long as your interest in deletion or anonymization does not prevail.	We use this cookie for tracking purposes, to gain insights from visitors and their interactions in the web/app. And for advertising purposes, so we can improve the ad serving experience to our audience.
New Relic:
IP address, browser configuration, session tracking. We retain Personal Data where we have an ongoing legitimate business need to do so. When we have no ongoing legitimate business need to process such Personal Data, we will either delete or anonymise it or, if this is not possible (for example, because the Personal Data has been stored in backup archives), then we will securely store such Personal Data and isolate it from any further processing until deletion is possible.	New Relic provides technical information to help us improve and optimise our product.
Adjust:
Hashed IP address, Mobile identifiers such as the ID for Advertising for iOS (IDFA), Google Advertising ID or similar mobile identifiers, Installation and first opening of an app on Your mobile device, Your interactions within an app (e.g. in-app purchases, registration), Information regarding which advertisements you have seen or clicked on. We use the data on the basis of a legitimate interest at most as long as your interest in deletion or anonymization does not prevail.	We use this cookie to track and attribute mobile marketing engagements.

Relevant Privacy Policies

For more information, please consult the:

Can I delete the cookies?

Yes, you may delete the cookies yourself via your internet browser. If you do not want cookies to be placed on your device at all, you may change this via the cookie settings in your internet browser. Please keep in mind that some of the functions and services on the Website might not function (as good) without cookies.

Your rights

As for our use of cookies (that process personal data), you have the same rights as for all other processing of personal data. You can read about your rights in our Privacy Policy above.

Amendments to this Cookie Statement

This Cookie Statement may be amended from time to time. The most recent version of this Cookie Statement applies. We advise you to read this Cookie Statement regularly to see if there are any changes.

Contact details

Circle Imperium B.V., trading under the name Inner Circle

Prins Hendrikkade 164-C
1011 TB Amsterdam
The Netherlands
www.theinnercircle.co
Chamber of Commerce number (Kamer van Koophandel): 60993448