Privacy Notice

Effective Date: 26 February 2019

1. ABOUT US

Pernimus Limited, a company located in Cyprus, is firmly committed to your privacy. This notice sets out our practices related to the collection, use and sharing of personal data when you visit topdiscreetdatingsites.com (the "Platform") and make use of the services available on the Platform (the "Services"). To help us meet our commitment to you, we have appointed a Data Protection Officer to oversee our privacy practices and our compliance with this notice. If you have any questions or concerns regarding our policies and practices related to your information, you can contact our Data Protection Officer at [email protected]or by writing to Pernimus Limited, 9 Karpenesiou Street, 2021 Nicosia, Cyprus.

For the purposes of this Privacy Notice, personal data means personal information, personal data or personally identifiable information as defined by the privacy or data protection laws in your jurisdiction.

The following is a high-level summary of this notice. Please read this notice carefully in its entirety before accessing the Platform or using the Services.

• Controller: Pernimus Limited is the "controller" of your data. Information processed: We process different types of information from you in connection with your access to the Platform and use of the Services. In particular, we collect information when you contact us (for example, your email or mailing address). We also collect information automatically from your use of the Platform for example cookies and your IP addresses. For more information about the types of personal data we process please click here.
• Usage: We use the information we collect from you for a number of different purposes which are described here. The main purpose is to respond to your inquiries and facilitate your use of the Services.
• Security: We take the protection of your personal data seriously. For more information about how we protect your information please click here.
• Your Rights: depending on where you are located, you will have various rights in relation to your data. For more information about your rights, please click here.

2. WHAT TYPES OF INFORMATION DO WE PROCESS?

We collect and receive the following types of information directly from you and automatically through your use of our Services.

A. Information you provide. When you contact our Platform via email or mail. Without this information, we will not be able to respond to you.

B. Information that will be collected automatically from your device. We also collect personal data through use of cookies and other tracking devices - for further details see Annex A.

3. PURPOSES FOR USING YOUR PERSONAL DATA AND LEGAL JUSTIFICATION

We collect your information as a Data Controller when we have a legal basis to do so. The following legal bases pertain to our collection of data:

• Our use of your personal data is necessary to perform a contract or take steps to enter into a contract with you. This applies to our processing activities described in Section 2A and 2B.
• Our use of your personal data is in our legitimate interest as a commercial organization to respond to your inquiries.
• Our use of your personal data is necessary to comply with a relevant legal or regulatory obligation that we have in particular, where we are required to disclose personal data to a court, tax authority or regulatory body in the event of an investigation. Our use of your personal data is in accordance with your consent.

4. HOW WILL WE SHARE YOUR INFORMATION

We share personal data with the following categories of recipients for the purposes described in Section 3 of this privacy notice above:

• Legal Request. We will share your information to respond to law enforcement requests; or where required by applicable laws, court orders, or government regulations; or to protect against misuse or unauthorized use of our Platform; or to protect the personal safety or property of our users or the public (among other things, this means that if you provide false information or attempt to pose as someone else, information about you may be shared as part of any investigation into your actions).
• Our Service Providers. We share your information with our service providers to perform certain functions on our behalf in connection with the provision of the Platform. This specifically includes providers of cloud hosting services and data analytics. These parties will only process your personal data under our instructions.
• Sale or Merger. We will share your information in connection with the sale, assignment, bankruptcy proceeding or other transfer of our business or a portion of our business, including a corporate merger, consolidation, restructuring, sale of assets or other corporate change of our direct or indirect parent companies that affects us. In connection with a due diligence review involving such a potential transaction, we may also share information with potential acquirers, merger partners or investors, and their agents (including professionals) where such individuals agree to use personal data under the same conditions as identified in this notice.

5. DATA TRANSFERS

If you are a resident of the European Union, whenever we transfer your data outside of Europe we will either: (a) ensure that the recipient is certified with the Privacy Shield Framework or that the country is deemed adequate by the European Commission; (b) put in place Standard Contractual Clauses or (c) implement appropriate safeguards approved by the European Commission to ensure an adequate level of protection in compliance with applicable data protection laws. You have a right to request details about the appropriate safeguard where this is documented (but it may be redacted to ensure confidentiality).

6. SECURITY

We take the protection of your personal data seriously. We protect personal data against loss and theft as well as unauthorized access, disclosure, copying, use, and modification using security safeguards, including physical, organizational and technological measures, commensurate with the sensitivity of your personal data. Employees who have access to your personal data are made aware of the importance of keeping it confidential. Where we use service providers who might have access to your personal data, we require them to have privacy and security standards that are comparable to ours. We use contracts and other measures with our service providers to maintain the confidentiality and security of your personal data and to prevent it from being used for any other purpose. Please be aware that no data security measures can guarantee complete security. You should also take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, relying on two-factor authentication and keeping your log-in and password private.

7. HOW LONG DO WE KEEP THE PERSONAL DATA WE COLLECT?

We apply a general rule of keeping personal data only for as long as required to fulfil the purposes for which it was collected as set out in section 3 above.

8. CHILDREN

The website is not for use by children under the age of 18 years. Accordingly, we do not knowingly collect, store, share or use the personal data of children under 18 years. If you are under the age of 18 years, please do not use this Service or provide any personal data, even if prompted by the website to do so.

9. YOUR RIGHTS

• Right to withdraw consent - where applicable, you have the right to withdraw your consent at any time.
• Right of access, rectification and erasure - you have the right to request access to and obtain a copy of any of your personal data that we may hold, to request correction of any inaccurate data relating to you and to request the deletion of your personal data under certain circumstances.
• Data portability - where we are relying (as the justification for processing) upon your consent, or the fact that the processing is necessary to perform a contract to which you are party or to take steps at your request prior to entering a contract, and the personal data is processed by automatic means, you have the right to receive all such personal data which you have provided us in a structured, commonly used and machine-readable format, and also to require us to transmit it to another controller where this is technically feasible.
• Right to restriction of processing - you have the right to restrict our processing of your personal data (meaning we could only store it, unless we have your consent or are required to process the restricted data for the establishment, exercise or defense of legal claims) where:
• you contest the accuracy of the personal data, until we have taken sufficient steps to correct or verify its accuracy;
• where the processing is unlawful but you do not want us to erase the personal data; where we no longer need your personal data for the purposes of the processing, but you require such personal data for the establishment, exercise or defense of legal claims; or
• where you have objected to processing justified on legitimate interest grounds (see below), pending verification as to whether we have compelling legitimate grounds to continue processing.
• Right to object to processing (including profiling) based on legitimate interest grounds - where we are relying upon legitimate interests to process personal data, you have the right to object to that processing. If you object, we must stop that processing unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or we need to process the personal data for the establishment, exercise or defense of legal claims. Where we rely upon legitimate interest as a basis for processing we believe that we can demonstrate such compelling legitimate grounds, but we will consider this on a case-by-case basis.

In the event that you exercise this right in relation to any information noted as mandatory in section 2 and we have been unable to demonstrate that we have a compelling legitimate ground for processing that outweighs your interests, rights and freedoms or that we require the information in connection with a legal claim, we shall comply with your data subject request by deleting your personal information.

• Right to object to direct marketing (including profiling) - you have the right to object to our use of your personal data (including profiling) for direct marketing purposes, such as when we use your personal data to inform you of our promotions.
• You also have the right to lodge a complaint with the supervisory authority of your residence or the place of alleged infringement if you consider that the processing of your personal data infringes applicable law (although we ask you to try resolve any complaints with us first by any of the methods listed at the top of this notice). Where you are a European Union resident, a list of all of the data protection supervisory authorities is available here local supervisory authority. For our processing in Cyprus, the Cypriot data protection regulator's details can be found here.

10. CONTACT US / COMPLAINTS

In addition to any rights applicable to you pursuant to Section 9 above, you have the right to access the personal data we hold about you and to have any concerns you may have over our policies and practices addressed. In addition, you have the right to obtain information regarding our policies and practices as they relate to the collection, use and disclosure of personal data, including those with respect to the transfer and storage of your information outside of your jurisdiction of residence, and update your personal data. Please contact us as indicated at the top of this notice if you wish to exercise any of your rights, or if you have any enquiries regarding the processing of your personal data.

11. CHANGES TO THIS NOTICE

This notice is current as of the Effective Date set forth above. We may update this notice from time to time, so please be sure to check back periodically.

ANNEX A - COOKIE POLICY

We use cookies, clear GIFs, third-party analytics and other tracking mechanisms to track your use of our Platform and the Services. Such tracking mechanisms may automatically collect information such as: your IP address, domain name, browser type and operating system; web pages you view; links you click; how you move through the Platform and the length of time you visit our Platform and use the Services; and the referring URL, or the webpage that led you to our Platform.

Cookies. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. We might use cookies to uniquely identify you, in order to track aggregate and statistical information about user activity, and to display advertising both on our Platform and on third-party sites. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. If you disable cookies some features of our Platform may not function. Further information may be found at www.allaboutcookies.org.

Clear GIFs.  Clear GIFs (a.k.a. web beacons, web bugs or pixel tags) are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, though, clear GIFs are embedded invisibly on web pages, not stored on your hard drive. We might use clear GIFs to track the activities of our visitors, help us manage content, and compile statistics about usage. These can be blocked either by using a third-party application such as Ghostery, or, in the case of emails, by changing your settings to prevent images from being downloaded (where your email client supports this functionality).

Do-Not-Track. Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies or opting out of ad networks).