Privacy Policy

1. Introduction

Welcome to Design Dates ("we", "us", "our", or the "Company"). We are committed to protecting your personal information and your right to privacy in accordance with the Protection of Personal Information Act 4 of 2013 (POPIA), South Africa's comprehensive data protection legislation.

We reserve the right to make changes to this Privacy Policy at any time and for any reason. We will alert you about any changes by updating the "Last Updated" date of this Privacy Policy. You are encouraged to periodically review this Privacy Policy to stay informed of updates.

2. Information We Collect

We collect personal information that you voluntarily provide to us when you register for our Services, express interest in obtaining information about us or our products and services, or otherwise contact us.

2.1 Personal Information You Provide

The personal information that we collect depends on the context of your interactions with us and the Site, the choices you make, and the products and features you use. The personal information we collect may include the following:

• Identity Data: Name, username, age, date of birth, gender, race/ethnicity, photograph.
• Contact Data: Email address, telephone number, WhatsApp number, physical address, city, province.
• Verification Data: South African ID document, passport, driver's license (for ID verification purposes).
• Preference Data: Relationship preferences, age range preferences, location preferences, interests, lifestyle information.
• Communication Data: Messages sent through our platform, WhatsApp conversations (with your consent), feedback, and correspondence.
• Payment Data: Bank account details (for EFT payments), payment transaction records (processed securely through PayFast).

2.2 Information Automatically Collected

We automatically collect certain information when you visit, use, or navigate the Site. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as:

• Device Data: IP address, browser type, operating system, device type, mobile network information.
• Usage Data: Pages visited, time spent on pages, links clicked, referral source, search queries.
• Location Data: General geographic location (city/province level) based on IP address or device settings (with your consent).
• Cookie Data: Information collected through cookies, web beacons, and similar tracking technologies (see Section 7).

3. How We Use Your Information

We use personal information collected via our Site for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations.

We use the information we collect or receive:

• To provide matchmaking services: To hand-pick compatible matches based on your preferences, personality, values, and lifestyle.
• To verify identities: To ensure the safety and authenticity of our community through ID verification.
• To facilitate introductions: To connect you with potential matches via WhatsApp or other communication channels.
• To send administrative information: To send you Service, product, and new feature information and/or information about changes to our terms, conditions, and policies.
• To fulfill and manage your orders: To process payments, deliver services, and send confirmations.
• To respond to legal requests and prevent harm: If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
• To protect our Services: We may use your information as part of our efforts to keep our Site safe and secure (for example, for fraud monitoring and prevention).
• To enforce our terms, conditions, and policies: For contract, legal, and business purposes.
• To respond to user inquiries/offer support: To respond to your questions, complaints, or requests and provide customer support.
• To send you marketing and promotional communications: With your consent, we may send you promotional materials about new features, special offers, or other information we think you may find interesting.
• To improve our Services: To analyze usage patterns, troubleshoot issues, and enhance user experience.

4. Data Sharing & Third Parties

We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations. We may process or share your data that we hold based on the following legal basis:

4.1 Service Providers

We may share your data with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf and require access to such information to do that work. These include:

• Payment processors: PayFast for secure payment processing (we do not store your full credit card details).
• Communication platforms: WhatsApp for introductions and messaging (with your explicit consent).
• Cloud hosting: Secure hosting providers for data storage and backup.
• Analytics services: Google Analytics, Facebook Pixel (with your consent via cookie banner).
• Location services: Google Maps for location-based features.

4.2 Profile Sharing with Matches

We will only share your profile information (name, age, photograph, preferences) with potential matches after you have given explicit consent. You have the right to withdraw this consent at any time by contacting us.

4.3 Legal Obligations

We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

4.4 Business Transfers

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

5. Data Security

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Site is at your own risk.

Our security measures include:

• Encryption: All sensitive data (passwords, ID documents, payment information) is encrypted using industry-standard AES-256 encryption.
• Secure transmission: All data transmitted between your browser and our servers is encrypted using HTTPS/TLS.
• Access controls: Access to personal data is restricted to authorized personnel on a need-to-know basis.
• Regular security audits: We conduct regular security assessments and penetration testing.
• Data backups: Regular encrypted backups to prevent data loss.
• Incident response: In the event of a data breach, we will notify affected users and the Information Regulator within 72 hours as required by POPIA.

6. Your Rights Under POPIA

Under the Protection of Personal Information Act (POPIA), you have the following rights regarding your personal information:

6.1 Right to Access

You have the right to request confirmation as to whether or not we hold personal information about you, and if so, to request a copy of that information.

6.2 Right to Correction

You have the right to request that we correct inaccurate, incomplete, or outdated personal information we hold about you.

6.3 Right to Deletion (Right to be Forgotten)

You have the right to request that we delete your personal information, subject to certain legal exceptions (e.g., if we are required to retain data for legal or regulatory purposes).

6.4 Right to Object to Processing

You have the right to object to the processing of your personal information in certain circumstances, such as for direct marketing purposes.

6.5 Right to Data Portability

You have the right to receive your personal information in a structured, commonly used, and machine-readable format, and to transmit that data to another controller.

6.6 Right to Withdraw Consent

Where we rely on your consent to process your personal information, you have the right to withdraw that consent at any time. Withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.

6.7 Right to Lodge a Complaint

You have the right to lodge a complaint with the Information Regulator of South Africa if you believe that your rights under POPIA have been violated. Contact details for the Information Regulator are provided in Section 13.

7. Cookies & Tracking Technologies

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Cookies are small text files that are stored on your computer or mobile device when you visit a website.

7.1 Types of Cookies We Use

• Essential Cookies: Required for the Site to function properly (e.g., session cookies, security cookies). These cannot be disabled.
• Analytics Cookies: Help us understand how visitors interact with our Site (e.g., Google Analytics). These require your consent.
• Marketing Cookies: Used to track visitors across websites to display relevant advertisements (e.g., Facebook Pixel). These require your consent.
• Preference Cookies: Remember your settings and preferences (e.g., language, region, cookie consent choice).

7.2 Managing Cookies

When you first visit our Site, you will be presented with a cookie banner allowing you to accept or decline non-essential cookies. You can also manage your cookie preferences through your browser settings. Most browsers allow you to:

• View what cookies are stored and delete them on an individual basis.
• Block third-party cookies.
• Block all cookies.
• Delete all cookies when you close your browser.

Please note that if you choose to block or delete cookies, some features of our Site may not function properly.

8. Data Retention

We will only retain your personal information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

Specific retention periods:

• Account data: Retained for the duration of your account plus 2 years after deletion (for legal and dispute resolution purposes).
• ID verification documents: Deleted within 30 days after successful verification (we do not retain copies of your ID).
• Payment records: Retained for 5 years as required by South African tax law.
• Communication records: Retained for 1 year for customer support and quality assurance.
• Analytics data: Aggregated and anonymized after 26 months.

9. Children's Privacy

If you believe that we might have any information from or about a child under 18, please contact us at dates@designdates.co.za.

10. International Data Transfers

Your information may be processed and maintained in South Africa and other countries. These countries may have data protection laws that are different from the laws of your country of residence.

We have implemented appropriate safeguards to ensure that your personal information remains protected in accordance with this Privacy Policy and POPIA when transferred internationally. These safeguards include:

• Binding contractual clauses with international service providers.
• Encryption of data during transmission and storage.
• Regular audits of international data processors.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification.

We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information. Your continued use of the Site after the effective date of any changes constitutes your acceptance of the revised Privacy Policy.

12. Contact Us

If you have questions or comments about this Privacy Policy, or if you wish to exercise any of your rights under POPIA, please contact us:

13. Complaints & Dispute Resolution

If you are unsatisfied with our response to any privacy-related concerns, you have the right to lodge a complaint with the Information Regulator of South Africa:

Before lodging a complaint with the Information Regulator, we encourage you to contact us directly to attempt to resolve your concern informally. We are committed to resolving any privacy concerns promptly and fairly.

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