Privacy policy

Hunbun App Privacy Policy

Most of the dating apps currently on the market require little time and almost no emotional investment. We're here to shake things up. Hunbun aims to improve online dating by slowing down and humanizing the process. Our mission is to help people create long-lasting and meaningful connections based on emotional intimacy rather than focusing on superficial aspects. To achieve our mission we collect various pieces of personal information about you when you register with us. This policy tells you more about how we collect and use that data.

Consent to installation of the App

By signing up to the App you consent to us processing your personal data (including your name, contact details, financial and device information and Special Category Data) as described in this privacy policy.

How you can withdraw consent

Once you provide consent by signing up to the App, you may change your mind and withdraw consent at any time by contacting us at support@hunbun.co but that will not affect the lawfulness of any processing carried out before you withdraw your consent.

Our Privacy Policy

Hunbun Limited (we) are committed to protecting your personal data and respecting your privacy.

Introduction

This policy (together with our terms of use for the Services, (Terms of Use) applies to your use of:

  • The Hunbun mobile application software (App) available from the App Store and which directs you to Hunbun.co (Hunbun Site) once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device).

  • Any of the services accessible through the App (Services) that are available on the Hunbun Site (such as our support centre) or other sites of ours (Services Sites). This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. This App and the Services are not intended for children and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

This policy is provided in a layered format so you can click through to the specific areas set out below.

1.     [IMPORTANT INFORMATION AND WHO WE ARE]

2.     [THE DATA WE COLLECT ABOUT YOU]

3.     [HOW IS YOUR PERSONAL DATA COLLECTED?]

4.     [HOW WE USE YOUR PERSONAL DATA]

5.     [DISCLOSURES OF YOUR PERSONAL DATA]

6.     [INTERNATIONAL TRANSFERS]

7.     [DATA SECURITY]

8.     [DATA RETENTION]

9.     [YOUR LEGAL RIGHTS]

10.  [GLOSSARY]

11.  [DESCRIPTION OF CATEGORIES OF PERSONAL DATA]

12.  [SPECIAL CATEGORY DATA]

 

1.          IMPORTANT INFORMATION AND WHO WE ARE

Hunbun Limited is the controller and is responsible for your personal data (referred to as "we", "us" or "our" in this policy).

We have appointed a data protection officer (DPO). If you have any questions about this privacy policy, please contact them using the details set out below.

Contact details

Our full details are:

·                   Full name of legal entity: Hunbun Ltd

·                   Name or title of DPO: Abhilasha Dave

·                   Email address: support@hunbun.co

·                   Postal address: 71-75 Shelton Street, London, Greater London, United Kingdom, WC2H 9JQ

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues.

Changes to the privacy policy and our duty to inform you of any changes

We keep our privacy policy under regular review.

This version was last updated on 25.04.22. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you when you next start the App. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

Third party links

Our Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.

2.          THE DATA WE COLLECT ABOUT YOU

We may collect, use, store and transfer different kinds of personal data about you as follows:

  • Identity Data.

  • Contact Data.

  • Financial Data.

  • Transaction Data.

  • Device Data.

  • Content Data.

  • Profile Data.

  • Usage Data.

  • Marketing and Communications Data.

  • Special Category Data.

  • Location Data.

 

We explain these categories of data here [LINK TO DESCRIPTION OF CATEGORIES OF PERSONAL DATA BELOW].

We will collect Special Categories of Personal Data about you (this includes details about your religious or philosophical beliefs, sexual orientation, political opinions and information about your health including covid vaccination status). Further details about how Special Category Data is collected and used is set out at [SPECIAL CATEGORY DATA] and in the table below.

3.          HOW IS YOUR PERSONAL DATA COLLECTED?

We will collect and process the following data about you:

  • Information you give us. This is information (including Identity, Contact, Financial, Special Category Data and Marketing and Communications Data) you consent to giving us about you by filling in forms on the Hunbun Site and the Services Sites (together Our Sites), or by corresponding with us (for example, by email or chat). It includes information you provide when you access or use the Hunbun Site and sign up for news or information, download or register an App, subscribe to any of our Services, search for an App or Service, share data via an App's social media functions or log in’s and when you report a problem with an App, our Services, or any of Our Sites. If you contact us, we will keep a record of that correspondence.

  • Information we collect about you and your device. Each time you visit one of Our Sites or use one of our Apps we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies. Please see our cookie policy for further details.

  • Location Data. We also use GPS technology to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling your Location sharing with Hunbun in your settings. Please note that disabling location access prohibits the App from suggesting matches nearby, therefore the App will not be able to perform its core services.

  • Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties as set out below:

Device Data from the following parties:

  • Analytics providers such as Google based outside the UK; Segment.io based outside the UK;  

  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Apple Pay based in USA or Stripe based in Ireland;

  • Contact Data from other users of the App and the Services, for example if they contact us about you; sending authentication passwords via SMS using AWS based in the UK; using social log-ins (via Facebook, Apple and Google) which provide us with information about your name and email to create a user.

Cookies

We use cookies to distinguish you from other users of the App, the distribution platform (Appstore) or Services Sites and to remember your preferences. This helps us to provide you with a good experience when you use the App or browse any of Our Sites and also allows us to improve the App and Our Sites. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy.

4.          HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

  • Where you have consented before the processing.

  • Where we need to perform a contract we are about to enter or have entered with you.

  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

  • Where we need to comply with a legal or regulatory obligation.

 

Click here [LINK TO GLOSSARY: LAWFUL BASIS] to find out more about the types of lawful basis that we will rely on to process your personal data.

We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Purposes for which we will use your personal data

5.          DISCLOSURES OF YOUR PERSONAL DATA

When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the table [Purposes for which we will use your personal data]:

  • External Third Parties as set out in the [Glossary].

  • Other users of the App and the Site as part of the Services, for example when they view your profile. Your profile will be gradually revealed to other users when you connect with them, please see our [Terms of Use] for more information.

  • Specific third parties such as AWS for SMS services, Mailchimp for sending marketing emails and MongoDB for database services.

  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

 

6.          INTERNATIONAL TRANSFERS

Many of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data. For further details, see [INSERT LINK TO RELEVANT PART OF THIRD PARTIES SECTION]].

  • Where we use certain service providers, we may use specific contracts approved by the UK which give personal data the same protection it has in the UK. For further details, see [INSERT LINK TO RELEVANT PART OF THIRD PARTIES SECTION].]

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

7.          DATA SECURITY

All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer technology (SSL).

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way. These are the following steps we take to secure the data: (1) we use SSL to establish an encrypted link between the server and the user. (2) We are using MongoDB Atlas for production, which uses TLS and SSL to encrypt the connections to databases, it can only be accessed through IPs configured in an IP Access List (which will only contain the production server) and it allows user side filed level encryptions. (3) Lastly, the Servers can only be accessed using SSH keys.

We will collect and store personal data on your Device using application data caches and browser web storage (including HTML5).

Whilst chatting with a match ensure that you do not submit any personal or financial data that you do not want to be seen, collected or used by other users.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

8.          DATA RETENTION

We will retain your personal data for as long as you use the App or Services.

We may retain your personal data for a longer period in the event of a complaint, if we reasonably believe there is a prospect of litigation in respect to our relationship with you or if we are required to do so for legal or regulatory reasons.

In some circumstances you can ask us to delete your data: see [Your legal rights] below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

In the event that you do not use the App for a consecutive period of 24 months then we will treat the account as expired and your personal data may be deleted.

9.          YOUR LEGAL RIGHTS

Under certain circumstances you have the following rights under data protection laws in relation to your personal data.

Please click on the links below to find out more about these rights:

  • [Request access to your personal data].

  • [Request correction of your personal data].

  • [Request erasure of your personal data].

  • [Object to processing of your personal data].

  • [Request restriction of processing your personal data].

  • [Request transfer or your personal data].

  • [Right to withdraw consent].

You also have the right to ask us not to continue to process your personal data for marketing purposes.

You can exercise any of these rights at any time by contacting us at support@hunbun.co.

10.       GLOSSARY

10.1.  Lawful basis

Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

10.2.  Third parties

External third parties

Other external third parties

Professional advisers acting as processors including lawyers, bankers, auditors and insurers based in the UK, who provide consultancy, banking, legal, insurance and accounting services.

HM Revenue and Customs, regulators and other authorities based in the UK who require reporting of processing activities in certain circumstances.

10.3.  Your legal rights

You have the right to:

  • Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

    • If you want us to establish the data's accuracy;

    • Where our use of the data is unlawful but you do not want us to erase it;

    • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or

    • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

11.       DESCRIPTION OF CATEGORIES OF PERSONAL DATA

  • Identity Data: first name, last name, username or similar identifier, title, date of birth, gender, location.

  • Contact Data: billing address, email address and telephone numbers.

  • Financial Data: bank account and payment card details.

  • Transaction Data: includes details about payments to and from you and details of in-App purchases.

  • Device Data: includes the mobile phone number used by the Device

  • Content Data: includes information stored on your Device, including login information, photos, voice notes or other digital content.

  • Profile Data: includes your username and password, in-App purchase history, your interests, preferences, educational background, height, family plans, job and location.

  • Usage Data: includes details of your use of any of our Apps or your visits to any of Our Sites including, but not limited to, traffic data, website activity such as session duration, pages per session, bounce rate and other communication data,  whether this is required for our own billing purposes or otherwise.

  • Marketing and Communications Data: includes your preferences in receiving marketing from us and any third parties and your communication preferences.

  • Location Data: includes your current location disclosed by GPS technology.

  • Special Category Data: includes information about your religious beliefs, political opinions, covid vaccination preferences, relationship preferences and history.

12.       SPECIAL CATEGORY DATA

The Services by nature involve you telling us (and other users of the App and the Services when you connect with them) some intimate details about you. When you register to use the App we will ask for your Contact Data and Identity Data and also the following information which is classed as Special Category Data:

  • Gender identity;

  • Whether you want to date men, women or everyone;

  • Your political opinions;

  • Your religious or philosophical beliefs;

  • Your relationship preferences and history; and

  • Your covid vaccination status.

By sharing this information with us, you agree to allow us to create a profile for you and to suggest matches for you with other users. We will also use this information to help you to form deeper connections with the people you interact with when using the App. For example, the more your conversation flows with your match, the more of these Special Category Data will be revealed.

You can withdraw your consent to us processing this Special Category Data at any time, but you will not be able to use the App without it, as we will not be able to suggest matches.  If you want to withdraw your consent please contact us at support@hunbun.co and we will remove your profile from the App and the Services.

 

UPDATED: 01.04.23