Privacy Statement - Forces Penpals US

At Conduitor Limited (trading as Forces Penpals) we take the issue of your Privacy very seriously. You share your data with us so that we can help you support the Armed Forces and find meaningful connections, and that is a privilege which we respect.

The following Privacy Policy details what personal data we collect as a company, and how, as a company we deal with it.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purposes of data protection legislation, the data controller is Conduitor Limited, Lasyard House, Underhill Street, Bridgnorth, Shropshire, United Kingdom, WV16 4BB.

Who we are and what we do

Conduitor Limited provides you with a website and an app (‘together our site’) in order to help singles dating and social networking for the UK Armed Forces and their supporters.

We collect information about you to help us to carry out our core business and ancillary activities.

Information you give to us or we collect about you.

This is information about you that you give us by filling in forms through our Forces Penpals website: https://forcespenpals.net/ or App (together our site) or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site, to enter our database, subscribe to our services, attend an event, or complete a feedback survey, and when you report a problem with our site.

i) GPS – Your mobile device’s geographic location when you first register for Forces Penpals through our mobile app or website;

ii) Mobile Device ID. Your mobile device’s unique ID number (e.g., IMEI).

iii) Your Device Information & Specifications. Technical information about your computer or mobile device (e.g., type of device, web browser or operating system, IP address) to analyse trends, administer the site, prevent fraud, track visitor movement in the aggregate, and gather broad demographic information.

iv) Length and Extent of Usage of services and features you used.

v) Information you choose to provide: Certain information we ask you to provide to us, so that we can help you match with people. You don’t always have to give it to us, but most of the time you will get a better experience if you do. But if you have any issues with this, let us know and we can take a look at this. We don’t want to be overly intrusive – your life is just that, yours.

Any information that you provide in the non-personal identifiable section of your profile will be viewable by your match.

First Name
Name
Age
DOB
Photograph
Location
Looking for
Marital Status
Occupation
Interests, including; TV, Film, Books, Sports and Hobbies.
Data on your actions
Information on your military positions held
Categories of information you are interested in
Your match information
Answers to Conduitor
Email
IP Address

Your Search Criteria

Profile data
Free form search
Locations

Messaging

Messaging history with others;
Posts, comments and chat in our group area.
Complaints or email messages sent to us or our moderators;

What information does Conduitor collect about me if I’m under 18?

You can only become a member of Conduitor or use its features if you’re aged 18 or over or the age of majority in the country in which you reside if that happens to be greater than 18. That means Conduitor does not knowingly collect any information about children, minors or anyone under the age of majority. Nor do we knowingly market to children, minors or anyone under the age of 18. If you are less than 18 years old, we request that you do not submit information to us. If we become aware that a child, minor or anyone under the age of 18 has registered with us and provided us with personal data, we will take steps to terminate that person’s registration and delete their Profile information from Conduitor. If we do delete a Profile because you violated our no children rules, we may retain your email and IP address to ensure that you do not try to get around our rules by creating a new Profile.

Information we collect about you when you visit our website.

With regard to each of your visits to our site or portal we may collect information such as technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information if applicable, browser type and version, browser plug-in types and versions, operating system and platform.

If I put other information about me on the app, what does Conduitor do with it?

Conduitor is designed to make it easy for you to find, connect and interact with other members of Conduitor in order to help you to date and make friends. We do this by posting information about yourself and allowing your profile of information to be seen by others who are looking for the same. When using our site you should assume that anything you post or submit will be publicly viewable and accessible, both by Users of the App and non-Users of the App. For example, to make it easier to find other Conduitor members and connect with them, we will recommend your profile to other people.

You can also use our electronic messaging system, which allows you to communicate with other users. We recommend and encourage you (and all our members) to think carefully about the information they disclose about themselves.

We also do not recommend that you put email addresses, URLs, instant messaging details, phone numbers, full names or addresses, credit card details, national identity numbers, drivers’ licence details and other sensitive information in your Profile which is open to abuse and misuse.

Please be careful about posting sensitive details about yourself on your Profile such as your religious denomination and health details. While you may voluntarily provide this information to us when you create your Profile, including your sexual preferences and ethnic background, there is no requirement to do so. Please remember that photographs or any video clips that you post on Conduitor may reveal these kinds of sensitive personal data. Where you do upload and choose to tell us sensitive data about yourself, you are explicitly consenting to our processing your information and making this public to other users.

Can Conduitor collect information about me from other sites I use, such as Facebook?

If you have registered on one of our partner websites, such as Facebook, your Profile will be available to all users of the Conduitor social network whether via our site.

Remember that when you register with a Conduitor partner, you are also giving them personal data, so we recommend that you read their privacy policies as Conduitor does not control how they use their information.

If you have registered on one of our partner websites, such as Facebook, or you have verified your account via a partner website, we may connect your Conduitor profile with your profile on such partner website. We may do this by way of new products and applications which we introduce from time to time, including new products powered by our group companies.

What am I allowed to do with other user’s personal data?

Use it to meet new friends and make new contacts! Beware that you may not use other users’ personal data for commercial purposes, to spam, to harass, or to make unlawful threats. Conduitor reserves the right to terminate the accounts of those who misuse other users’ personal data or who otherwise misbehave on our site.

Purposes of the processing and the legal basis for the processing

We use information held about you in the following ways:

To carry out our obligations arising from any contracts we intend to enter into or have entered into between you and us and to provide you with a platform to meet new people.

Our Legitimate Business Interests

Our legitimate interests in collecting and retaining your personal data in order to help you meet new people and find dates/ a partner.

Fulfil a legal obligation

We rely on the fulfilment of a legal obligation if we are to disclose any data relating to fraudsters or scammers as part for a criminal or civil investigation by the relevant authorities as required by the law or to share with our partner Scamalytics Limited who assist us in fraud detection services (see further below).

Consent

We rely on your consent to retain your data and to share your profile data and other information you upload to the site to other members.

Other Uses we will make of your data:

You may appear on our app or website;
To notify you about changes to our service
To ensure that content from our site is presented in the most effective manner for you and for your computer

We will use this information:

to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
to allow you to participate in interactive features of our service, when you choose to do so;
as part of our efforts to keep our site safe and secure;
to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.

Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them see our Cookie notice.

Disclosure of your information inside and outside of the EEA

Information may be accessed by users of our site who are located outside of the EEA.

As a global service we may also transfer data outside of the EEA to service providers located in such areas, in such circumstances we will seek to ensure that appropriate safeguards are put in place, and due diligence.

Selected third parties including:

Scamalytics who are our business partner and anti-fraud solution provider. They help us to ensure we keep you safe from scammers and fraudsters, you can find out more about them here: https://scamalytics.com/privacy-policy/
Sparkpost, our email provider who we use to send out updates, recommendations and information about our services. For more see https://www.messagebird.com/en/legal/privacy
Drip.com, our marketing automation platform. We gather information on platform usage data points and send out helpful emails and marketing emails. For more info see https://www.drip.com/privacy
Zendesk, our customer support platform. We use this to reply to queries from members and solve issues. From more info see https://www.zendesk.co.uk/company/agreements-and-terms/privacy-notice/
Sentry, our error tracking and performance monitoring software. We use this to hunt down errors and track application performance issues to provide a better experience for members. See more info here https://sentry.io/privacy/
Subcontractors including email marketing specialists, event organisers, payment and other financial service providers;
Analytics and search engine providers that assist us in the improvement and optimisation of our site.

We will disclose your personal information to third parties:

In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
If Conduitor Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, and other agreements; or to protect the rights, property, or safety of Conduitor or our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection.

The lawful basis for the third party processing will include:

Their own legitimate business interests in processing your personal data, in most cases to prevent fraud;
satisfaction of their contractual obligations to us as both a data controller and data processor;
for the purpose of a contract in place or in contemplation;
to fulfil our legal obligations.

Where we store and process your personal data

The data that we collect from you will be stored in servers within the EEA however it may be transferred to, and accessed, in destination outside the European Economic Area (”EEA”).

It may be transferred to third parties outside of the EEA for the purpose of fulfilling our anti-fraud detection and prevention services. It may/will also be processed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, our anti-fraud services, development and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. Conduitor will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice.

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Retention of your data

We understand our legal duty to retain accurate data and only retain personal data for as long as we need it for our legitimate business interests and that you are happy for us to do so. Accordingly, we regularly review our use of data with the aim of removing data that we no longer have a legitimate business interest in maintaining.

In order to ensure our data is kept up to date we ask that you let us know of changes to your personal data.

We segregate our data so that we keep different types of data for different time periods. The criteria we use to determine whether we should retain your personal data includes:

the nature of the personal data;
its perceived accuracy;
our legal obligations;
whether an interview or placement has been arranged; and
our recruitment expertise and knowledge of the industry by country, sector and job role.

After you delete your profile through our application we therefore retain data for 5 years and then automatically delete it permanently. This is in order to fulfil our legal obligations to pass on data to the authorities when requested. It is also to safeguard you and our other members from fraudsters and bad actors.

Your rights

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes and we will collect express consent from you if legally required prior to using your personal data for marketing purposes.

The Data Protection Act 2018 provides both you and your end users the following rights. To:

Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing.
If you would like to have us delete your account information, we may do so by deactivating your account first and then permanently deleting your account. Feel free to contact us at [email protected] to inquire about or request data deletion.
Please note that as a company we do have an obligation to keep accurate records and also keep you safe from scammers and underage users which is why we ask you request deletion of accounts.
Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal information to another party in certain formats, if practicable.
Make a complaint to a supervisory body which in the United Kingdom is the Information Commissioner’s Office. The ICO can be contacted through this link: https://ico.org.uk/concerns/

Protecting your information

Conduitor are dedicated to keeping your data safe as such we have the following policies in place to help us do this.

We have a Data Breach Policy to help guide us in the event of a data loss or data breach, a copy of this is available on request.

To help guide us an ensure we manage safety then we also have a data security policy.

Password Restrictions

At Conduitor we require all passwords to be changed at regular intervals and to be of minimum complexities. We would ask that if you are a user of our site that you keep your password safe and report any loss/ breach of your passwords to us as soon as practically possible.

Access to information

The Data Protection Act 2018 gives you the right to access information held about you or your end user.

If you would like to exercise any of the above rights, then you should contact Conduitor and we will seek to work with you to provide any information required.

A subject access request should be submitted to Michael Blakeley, and we will seek to get you the necessary information within 72 hours.

Changes to our privacy notice

Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice.

Contact

Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to Michael Blakeley our DPO and can be contacted on [email protected].

Forces Penpals Privacy Policy