Introduction

This is the Privacy Policy of MNH WEB, (“HeyU”, “us”, “we”, or “our”) which is incorporated into and is subject to our Terms of Use. Please read on to learn more about our data handling practices. By visiting our website heyu.dating (“Site”), or accessing or using our HeyU mobile application (“App”) or all of the services available or related to therein (collectively referred to in this Privacy Policy as the “Service”), you agree with the terms of this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not use the Service.

Age

The Service is not directed at children under the age of eighteen (18) and we do not knowingly collect personally identifiable information from children under the age of eighteen as part of the Service. If we become aware that we have inadvertently received or collected personally identifiable information from a user under the age of eighteen as part of the Service, we will delete such information from our records. If you are under the age of eighteen, please do not use the Service.

Information we collect

When you use the Site or App, install the App on your device, or sign up for an account with HeyU, personally identifiable information about you may be collected in order for us to be able to provide you with the Service. Please see below more details on the types of personally identifiable information that we may collect from you.

a. When you visit our Site

We may use online tracking technology such as cookies, pixel tags, web beacons and other similar technologies to automatically collect information about:

  • your visits to our Site, such as your browsing history, how long you stay on our Site, and how often you visit; and
  • your location information as provided by your mobile or other device when you interact with our Site, including your IP address and general geographic location; and the device that you use to browse our Site (e.g. your device ID, operating system, type of device, browser type and version, mobile application crashes and other system activity, and third party sites you were using before interacting with our services). You have the right to disable any of these online tracking technologies. To learn more about how we use the above data, please see the Cookie Policy section below.

b. During registration

When you install the Service on your device and/or register for an account with HeyU, personally and/or non-personally identifiable information about you may be collected.

Information you provide (mandatory) – You are required to provide your gender, name and date of birth.

Information you provide (optional) – You may also choose to provide other personally identifiable information such as your mobile phone, e-mail address, photos or videos of yourself, description of yourself and information about your interests. The provision of such information is entirely optional. If you register and log in using your Facebook, Apple or Google account, we may also collect additional information that you make available to us. For example, if you register with HeyU using your Facebook account (e.g. Facebook Connect), we may collect and store your Facebook ID and corresponding token on our servers and, if you give us your express consent, we will have access to and may collect certain information that you make available on Facebook (for example, your first and last names, email address, profile picture, friend lists and birthdays).

Your contacts – In addition, you may be asked to provide us with access to your address book on your device(s) on which the App is installed. If you consent, we will have access to the contact information stored in your address book on the device(s) that you use for accessing the App (this may include names, contact numbers, email addresses, profile pictures and Google/Apple/Facebook/Twitter IDs, but this will not include any notes or other personal information stored in your address book) and we will store it on our servers and use it to facilitate your use of the Service. For example, we will synchronize your HeyU contacts between different devices which you may use to access our Service. However, you should always seek prior consent from any person whose contact information is stored in your address book before you consent to sharing the contact information of such person with us.

c. During usage of the App

Device information – HeyU may collect and store information about the device(s) which you use to install and access the App, such as your device model, unique device identifier, IP address, device capability and statistics on page views.

Your activity – HeyU may collect and store information about your and others’ usage of and activity within the App and our Site, including matches, numbers of matches made by members, match durations, text messages, and usage by geographies. You will also have the option to allow us to take pictures and record video/audio, and gain access to your photos, media and files on your device, and your device’s location, while using the App.

Content you shared – HeyU allows you to share text messages, photos, screenshots, videos and other communications in the App with other users, and if you choose to do so, your text messages, photos, screenshots, videos and other communications will be stored on our servers. In addition, if you choose to share these items with other HeyU users, we may not be able to remove them from our servers or make them unavailable to anyone you have shared them with. By choosing to share such information, you agree that you may no longer be able to control how that information is used and that it may become publicly available (depending in part on your actions or the actions of the other users with whom you have shared the information). HeyU shall not be responsible for any use or misuse of such information that you share with other users. You may refer to Part 7 below for more information on the parties with whom you may choose to share your content.

Content you created – We may also collect and store any user content (e.g. photos, screenshots, comments, and other materials) that you create or post on the App (“User Content”).

Information about transactions made through our Service – In order to complete a transaction on the HeyU item shop, you will be requested to provide your payment information, which includes your credit card number, card expiration date, CVV code, and billing address. In that event, we will transmit your information securely directly to a third-party vendor or merchant who will collect such information in order to process and fulfil your purchase. HeyU does not process or store your payment information. However, we may store other information about your purchases made on the App, which may include the merchant’s name, the date, time and amount of the transaction and other behavioural information such as your purchase history.

Error-reporting information – We also collect error-reporting information if the App crashes or fails to operate properly so that we can investigate the error and improve the stability of the App for future releases. In general these reports do not contain personally identifiable information, or only incidentally. These error reports contain information such as the type and version of your device, the device identifier, the time the error occurred, the feature being used and the state of the App when the error occurred. We do not use this information for any purpose other than investigating and fixing the error.

Your User Profile

The information you provide for your user profile on the App (your “Profile”) may be shared with your HeyU contacts. You can access, control and modify your Profile from the App at any time. Your Profile will be made available to other users of the App who are connected to you. In addition, your Profile is discoverable by other App users, for example, through listing of contacts in the App that will include your proximity to other users. You may also choose to “block” any App user in your contact list which will prevent them from discovering your Profile at any time. In addition, HeyU may pre-populate your Profile with certain information such as your name and Facebook profile picture if you have logged into your account on the App using your Facebook account.

Purpose and use of personal information

We adopt the data minimization principle when collecting and using your data and ensure that your data will only be used in accordance with the stated purposes below. We will only process your data in connection with the Service and for other related business purposes, including:

  • To provide you with the Service, including:
    • to connect you with other users within the App;
    • to enable you to share your Profile with other users on the App;
    • to provide you with video and audio call functions of the App;
    • to allow you to send images and videos through the App;
    • to show you the names of persons you communicate with and to show your name to persons you communicate with on the App; and
    • to provide you with certain features of the App that may be offered from time to time, such as our Premium Services (please see our Terms of Use).
  • To help administer and maintain your account and User Profile on the App, including:
    • creating and updating your account;
    • verifying your identity and preventing fraud in order to ensure the safety and security of all App users;
    • and delivering to you any administrative notices, alerts and communications relevant to your use of the App.
  • To facilitate networking opportunities through the Service.
  • To handle and process any payments for transactions carried out through the Service via third party providers.
  • To provide you with location information relating to other users of the App.
  • To compile statistics about habits and preference of users to analyze site usage and help us improve the Service.
  • To respond to, handle and process correspondence, queries, applications, complaints, feedback and requests in relation to the Service that you submit to us.
  • For audit, compliance, controls and other risk management purposes.
  • For business management purposes, including data and record management.
  • For carrying out internal operations relating to the Service, including troubleshooting problems, data analysis, testing, research, improvements to the Service, detecting and protecting against error, fraud or other illegal activity in relation to our Service;
  • With your consent, to provide you with marketing and promotional materials (please see the section below on Direct Marketing for more information).
  • To establish, exercise and/or defend our legal rights.
  • To comply with our legal, regulatory and reporting requirements to regulatory bodies.
  • To ensure the safety of users through content moderation.
  • In connection with a corporate transaction involving HeyU, such as the purchase or sale of a business unit, an acquisition, merger, sale of assets, or another similar event.

There are different legal reasons for processing your data while you are using our Service. With respect to these legal reasons, we process your data for one or more of the following basis.

  • To Perform a Contract. Where the processing is necessary for the performance of the contract.
  • Legitimate Interests. Where the processing is necessary for legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal information.
  • Your Consent. Where you have given us consent to process your personal information for specified purposes, such as to provide our Service and other items requested by you.
  • Comply with the Law. Where the processing is necessary for compliance with a legal obligation.

Parties with whom we may share your information

Your User Content and your information may also be disclosed or transferred to the following parties for any of the purposes mentioned above:

  • our parent company, subsidiaries, affiliates and/or branch offices (collectively the “RC Group”);
  • any of our or any RC Group member’s agents, contractors (including, without limitation, direct marketing companies and mailing houses who help us manage our electronic and mailed communications, IT companies who support our website and other business systems, back office service providers, payment service providers, data management and analytics service providers, and data cleansing service providers);
  • any relevant third parties such as telecommunications operators, third party collection agencies, credit reference agencies, security agencies (including identification verification service providers), credit providers, banks, financial institutions (including any payment processors);
  • any professional advisors (including our legal advisors and auditors);
  • any regulatory authorities, courts and other governmental agencies;
  • and any of our actual or proposed assignees or transferees of any part of our business or operations.

Parties with whom you may choose to share your User Content

Any information or content that you voluntarily disclose or post on the App, such as your User Content, becomes available to the public. Once you have shared such User Content or made it public, that User Content may be viewed and re-shared by others.

Even if you remove any User Content (e.g. screenshots, etc.) that you created or posted on the App, copies of such User Content may remain accessible in the cached and archived pages of the App, or if other users or third parties have copied or saved such information.(e.g. using Facebook, etc.)

Any personally identifiable information that you: (i) share in text messages, photos, videos or otherwise in or through the App with other users; or (ii) submit via live messaging on the App, can be viewed and used by others. HeyU is not responsible for any use or misuse of such information that you share or submit.

Direct Marketing

If you have opted to receive direct marketing content from us, you agree that we may use your personally identifiable information to:

  • send you direct marketing communications in connection with the latest news, events, updates, offers, contests and promotions in relation to our Service; or
  • analyse your preferences, online behaviour and transactional history in order to gain insights, so that we can customise the content and types of news, events, updates, contests, promotions, offers, products and services that we present to you via our Site, our App, our direct marketing communications, social media or other communication means.

Before providing you with direct marketing communications, we will always ask for your consent. You can choose at any time to opt out from receiving such direct marketing communications from us. Please see the section on Your Data Protection Rights below.

Data Access and Removal

You can always control what information you choose to share with us on the App (except for information which we have indicated as mandatory for you to provide). To do so, you can change your settings in the App or in your mobile device. Alternatively, you can remove the App from your mobile device entirely.

You can choose to remove your data anytime you want. If you ask us to delete your account, we will use commercially reasonable efforts to remove your data from our servers, subject to any applicable legal or other requirement to maintain certain records of your personally identifiable data. Please note that the deletion of your personally identifiable data from our database may result in us not being able to provide you with the Service.

Outbound Links

If you accessed a website or application provided by a third party, including through the App or the Site, such third party may also collect information about you. We do not own or control, and are not responsible for the privacy practices of third party websites or applications. Please refer to the privacy policies of each of these third parties for more information about how they collect and use the information they collect about you. This Privacy Policy does not apply to any exchange of information between you and any such third party.

Security

Protecting your privacy and personal information is a top priority for HeyU. We make substantial efforts to ensure the privacy and security of all personally identifiable information you provide to us. Access to all personally identifiable information is strictly restricted to HeyU employees, contractors, agents and third-party service providers who need to know that information in order to provide, operate, develop, maintain, support or improve the Service or otherwise carry out any of the purposes as set out in this Privacy Policy. HeyU implements appropriate technical and physical security measures, such as using password protection, access logs, and system monitoring to maintain the confidentiality and security of all users’ information against any loss or unauthorised disclosure, use and modification.

However, due to the inherent nature of the Internet and related technology, we do not guarantee the protection of information under our control against any loss, misuse or alteration.

Data Transfer

Your information may be stored and processed in any country in which HeyU or its service providers maintain facilities. In this regard, or for purposes of sharing or disclosing data as described in this Privacy Policy, HeyU reserves the right to transfer information outside of your country. By using the Service, you consent to any such transfer of information outside of your country.

When we transfer personal information internationally, we put in place safeguards in accordance with applicable law. If you would like to know more about our personal data transfer practices, please contact us at the contact details set out under the “Contact Information” section.

Retention of Your Data

We will keep your personal data only for so long as is necessary to fulfil the purposes outlined in this Privacy Policy, unless the law requires us to keep it for a longer period. Once we no longer need your personal data, we will either irreversibly anonymise or securely delete it from our servers.

Your Data Protection Rights

HeyU would like to make sure you are fully aware of all of your data protection rights. In particular, you are entitled to the following rights:

  • Right of Access: You shall have the right to obtain from HeyU confirmation as to whether or not your personal information is being processed, and, where that is the case, you may request for a copy of your personal information
  • Right to Withdraw Consent: The provision of your consent shall give HeyU a lawful basis to process your personal information. You may also revoke your consent to the processing.
  • Right to Rectification: You shall have the right to request HeyU to correct any inaccurate personal information concerning you;
  • Right to Erasure: You shall have the right to ask for your personal information to be deleted in certain circumstances;

Please note that your right to erasure may be limited if the data are necessary for compliance with a legal obligation or for the establishment, exercise or defence of legal claims.

  • Right to Restriction on Processing: You shall have the right to object to and ask for restrictions on the processing of your personal information in certain circumstances;
  • Right to Data Portability: You shall have the right to receive the personal information you have provided to HeyU, in a structured, commonly used and machine-readable format and have the right to transmit those personal information from HeyU to another controller without hindrance from HeyU to which the personal information have been provided, where:
    • the processing is based on your consent; and
    • the processing is carried out by automated means;
  • Right to Objection: You shall have the right to object, on grounds relating to your particular situation, at any time to processing of your personal information.  HeyU shall no longer process the personal information unless HeyU demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims;
  • Right to Complaint – You shall have the right to file a complaint with our Data Protection Officer (details of which are provided below) if you think that one or more of your rights have been infringed by HeyU.

Exercising your data protection rights

If you wish to update or delete your personal information submitted, you can update it via the App. Alternatively, you can send your request to our Customer Service Manager at: heyu @ heyu.chat

In addition, you have the right to lodge complaints about how HeyU manages your personal information. You can lodge a complaint with HeyU’s Data Protection Officer whose contact details are set out under the “Contact Information” section below or with a local data protection regulator.

Cookie Policy

Cookies are small text files that are stored on your browser or device by websites, applications, online media and advertisements when you visit a website.

We use cookies and other similar identification technologies such as web beacons and pixel tags on our Site, App, emails and online advertisements for various purposes, including verifying users; remembering user preferences and settings to enhance your experience when you return to our Site or App; delivering relevant content and advertisements based on your preferences, location and usage patterns; monitoring, evaluating and optimising the operation of our Site and App; tracking and measuring the effectiveness of our advertising campaigns; and analysing traffic on our Site, our App and the websites of our partners or RC Group members.

You can exercise your right to choose whether or not to accept cookies by adjusting your browser settings to modify your cookie preferences. Most browsers are set to accept cookies by default, but you are free to remove or block all browser cookies. However, if you turn off your cookies, some of our services may not function properly and you will not be able to receive the most efficient and personalised experience.

Notification of Changes

We reserve the right at our discretion to make changes to this Privacy Policy from time to time. You may review updates to our Privacy Policy at any time via links on our Site. You agree to accept electronic communications and/or postings of a revised Privacy Policy on the Site, and you agree that such electronic communications or postings constitute notice to you of the Privacy Policy.

If we make material changes to this Privacy Policy, we will notify you by publishing a revised Privacy Policy or by means of a notice on our Site, or as required by law. You agree to review the Privacy Policy periodically so that you are aware of any modifications. You agree that your continued use of the Service after we publish a revised Privacy Policy or provide a notice on our website constitutes your acceptance of the revised Privacy Policy.

Contact information

If you have any questions about this Privacy Policy, please contact our Data Protection Officer

Date

This Privacy Policy was lastly modified in November 2020.