Update Bumble Privacy Policy

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Bumble/Privacy Policy.md

@@ -109,7 +109,7 @@ Our main goal is to ensure your experience on Bumble is an enjoyable one and you
 *   conduct research and analytics about how you use and interact with the App/Sites;
 *   resolve disputes, troubleshoot problems and to enforce our Terms & Conditions;
 *   investigate fraud, protect our legal rights, and to enforce our Terms & Conditions.
-*   to send you information about the promotions and offers we have available - if you’ve signed up for our newsletters or otherwise told us it’s OK (you can withdraw this consent at any time via Settings in the App or by using the opt-out mechanisms and links provided in each message); and
+*   to send you information about the promotions and offers we have available - if you’ve signed up for our communications or otherwise told us it’s OK (you can withdraw from marketing at any time via Settings in the App or by using the opt-out mechanisms and links provided in each message); and
 *   protect our Users and third parties from harm.
 
 ### Moderation Practices
@@ -128,12 +128,11 @@ Under EU and UK data protection laws, we are required to tell you our lawful bas
 | To facilitate networking opportunities on the Bumble App | Optional information that you choose to provide in your profile, including through profile verification, or adding Bumble badges, which may include information about your sexual preferences, non-binary gender, religion, ethnic background, photos etc. (CCPA Categories C, H, I, J) | You provide this information to us | Consent |
 | To verify your identity and prevent fraud and to ensure the safety and security of Users | Phone number and if requested, photo provided as part of profile verification and for users based in countries where age verification is required by law: photo of Government ID + geolocation and device information (CCPA Categories A, B, C, F, G and H) | You provide this information to us, except for the geolocation and device information, which we obtain from the device that you use to access the service | Legitimate interests – it is in our legitimate interests to ensure that accounts are not set up fraudulently and to safeguard Users of the site |
 | To take payment for premium services (not applicable for Users making payments via the Apple App Store) | Payment card details (CCPA Categories B and D) | You provide this information to us | Contractual necessity |
-| To send you marketing information about our offers and services | Email address and mobile phone number (CCPA Category B) | You provide this information to us | Consent |
+| To send you marketing information about our events, offers and services | Email address and mobile phone number (CCPA Categories A and B) | You provide this information to us | Consent or legitimate interests and in accordance with the laws applying to our marketing activities. We have a legitimate interest in promoting our business and products |
 | To show you other Users near you | WiFi access points and location data when you use the App (if you give us permission) (CCPA Category G) | We obtain this information from the device that you use to access the service (if you give us permission) | Legitimate interests – it is in our legitimate interests to provide this functionality as part of the services |
 | To carry out research and analysis to help us improve the App | Log and usage data, including IP address, browser type, referring domain, pages accessed, mobile carrier and search terms, images and video (CCPA Categories F and H) | You provide photos and videos to us. We obtain the log and usage information from the device that you use to access the service | Legitimate interests – it is in our interests to analyse the way in which Users are accessing and using our services so that we can further develop the App, implement security measures and improve the service |
 | To respond to correspondence and queries that you submit to us, including social media queries | Email address and IP address, social media name, phone number (CCPA Categories B and F) | You provide your email address, social media name and phone number to us when you contact us and we obtain your IP address from the device that you use to contact us | Legitimate interests – it is in our legitimate interests to respond to your queries to ensure that we provide a good service to Users and troubleshoot problems |
-| To block accounts as part of our anti-spam procedures | Email address, phone number, IP address and IP session information, social network ID, username, user agent string (CCPA Categories B and F) | You provide your email address, phone number and username to us. We obtain the other information from the device that you use to access the service | Legitimate interests – it is in our legitimate interests to prevent unauthorised behaviour and to maintain the safety and security of our services |
-| To investigate and block Users for reported infringements of our Terms and Conditions of Use | Name and user registration details, profile information, content of messages and photographs (CCPA Categories A, B, C, E, and H) | You provide your name, profile content and activities on the App to us | Legitimate interests - it is in our legitimate interests to prevent unauthorised behaviour and to maintain the safety and integrity of our services |
+| To investigate and block Users for reported infringements of our Terms and Conditions of Use | Name and user registration details, profile information, content of messages and photographs + usage and device data such as IP address and IP session information (CCPA Categories A, B, C, F, and H) | You provide your registration details, profile information, messages content and photographs to us. We obtain the other information from the device that you use to access the service. | Legitimate interests - it is in our legitimate interests to prevent unauthorised behaviour and to maintain the safety and integrity of our services |
 | To enable Users to create and enhance their Bumble profile and log into the App via third party accounts | Data from Facebook and other third-party accounts (see section 7 of this Privacy Policy for more details) (CCPA Categories A, B, C, and H) | We obtain this information from Facebook, or the providers of any other accounts you use to log in or connect with your Bumble account | Legitimate interests – it is in our legitimate interests to facilitate access to our services |
 | To block payment transactions as part of our anti-fraud procedures | Name, IP address, email address, mobile number, cardholder name, payments received, type of payment, user ID, country (CCPA Categories, A, B, and D) | You provide your name, email address, mobile number and card details to us. We obtain your IP address from the device that you use to contact us. We obtain your payment information from your interactions with our service | Legitimate interests – it is in our legitimate interests to prevent fraudulent transactions and to maintain the security of our services |
 | To serve promo cards and advertisements on the App | Location, gender, age, and information that you have optionally provided us with via your profile (CCPA Categories A, C and G) | We obtain age, gender and profile information from you, and location data from the device that you use to access the service | Legitimate interests – it is in our legitimate interests to target advertisements so that Users see relevant advertisements and to allow us to generate income from advertising revenue |
@@ -150,11 +149,11 @@ Our policy is to not disclose your Registration Information or personal data, ex
 | Circumstances where data may be disclosed | Disclosed data |
 | --- | --- |
 | **Service Providers** – We engage certain trusted third parties to perform functions and provide services to us. We may share your Registration Information or personal data with these third parties, but only for the purposes of performing these functions and providing such services. More information about this is available directly below. | This could include all data, including all CCPA Categories listed above |
-| **Moderators** – To monitor activity on the App and approve content. | Name and user registration details, profile information, content of messages and photographs (CCPA Categories A, B, C, E, and H) |
+| **Moderators** – To monitor activity on the App and approve content. | Name and user registration details, profile information, content of messages and photographs (CCPA Categories A, B, C, and H) |
 | **Payment Processing and Telecommunications Companies** – To facilitate payments for our premium services. | Cardholder name, cardholder address, card number, payment amount, transaction date/time (CCPA Categories A, B, and D) |
 | **Law and Harm** – As we mentioned in the [Terms & Conditions](https://bumble.com/en/terms), we think it is very important that all Users behave whilst using the App. We will cooperate with all third parties to enforce their intellectual property or other rights. We will also cooperate with law enforcement enquiries from within or outside your country of residence where we are required to by law, where there is an investigation into alleged criminal behaviour or to protect the vital interests of a person. This may include preserving or disclosing any of your information, including your Registration Information, if we believe in good faith that it is necessary to comply with a law or regulation, or when we believe that disclosure is necessary to comply with a judicial proceeding, court order, or legal request; to protect the safety of any person; to address fraud, security or technical issues e.g. through anti-spam providers to protect the service from criminal activity or to protect our rights or property or those of third parties. In such cases we may raise or waive any legal objection or right available to us. | This could include any personal data that Bumble holds about you, depending on the nature of the request or the issue that we are dealing with, including all CCPA Categories listed above |
 | **Business Transfers** – In the event that a Bumble Group entity or any of its affiliates undergoes a business transition or change of ownership, such as a merger, acquisition by another company, re-organisation, or sale of all or a portion of its assets, or in the event of insolvency or administration, we may be required to disclose your personal data. | This could include all personal data that Bumble holds about you, including all CCPA Categories listed above |
-| **Marketing Services Providers** – To help us serve marketing and advertising on third party websites and applications and measure the effectiveness of our advertising campaigns. More information on this is available below | Advertising identifier associated with your device (Device ID), estimated location (based on your IP address), age, gender and data about your visit to our Sites or App and action taken on those (for example if you downloaded our App or created an account with our App) (CCPA Categories B, C, G, F and K) |
+| **Marketing Services Providers** – To help us serve marketing and advertising on third party websites and applications and measure the effectiveness of our advertising campaigns. More information on this is available below | Advertising identifier associated with your device (Device ID), estimated location (based on your IP address), age, gender and data about your visit to our Sites or App and action taken on those (for example if you downloaded our App or created an account with our App), hashed email address (for ‘custom audiences’ only) (CCPA Categories B, C, G, F and K) |
 | **Anti-Spam and Anti-Fraud** – Your data may be shared with other Bumble Group companies, for example, to block accounts and suspected fraudulent payment transactions as part of our anti-spam and anti-fraud procedures. | Email address, phone number, IP address and IP session information, social network ID, username, user agent string, and transaction and payment data (CCPA Categories B, F and D). |
 
 **Aggregated Information** – We may share aggregated information with third parties that includes your personal data (but which doesn’t identify you directly) together with other information including log data for industry analysis and demographic profiling.
@@ -183,16 +182,17 @@ We partner with providers of marketing services (such as Facebook for example) (
 
 *   to exclude you from advertising campaigns aimed at finding new users, if you already have a Bumble account;
 *   to show Bumble adverts to users who have visited the Bumble App/Sites but haven’t yet created a Bumble account;
-*   to show Bumble adverts to existing Users to encourage them to use the service (for example, when we release new features for the App, we may advertise these features to existing users);
 *   to create an audience for our advertisements of other potential users who have similar characteristics to you based on the information the Marketing Service Providers holds about you (also known as a Lookalike Audience); or
 *   to include you in a ‘custom audience’ that will receive Bumble advertising content (a custom audience is essentially a list of people who we think are most likely to be interested in a particular advertisement).
 
-We share a limited amount of your personal data with these Marketing Services Providers, namely:
+We share a limited amount of your personal data with these Marketing Services Providers, such as:
 
 *   the advertising identifier associated with your device (this is a random number assigned by your mobile device manufacturer (for example Apple or Google) to your device to help advertisers (including the manufacturer) know when an ad has been viewed or clicked in an app, and when an ad causes a ‘conversion’ (for example, downloading the app advertised to you))
 *   your estimated location (based on your IP address)
 *   age and gender
 *   data about your visit to our Sites or App and action taken on those (for example if you downloaded our App or created an account with our App)
+*   a hashed\* version of your email address (to create ‘custom audiences’).
+\*Hashing is a way of encrypting information by turning it into a combination of random numbers and letters - this code cannot be traced back to the email address. When hashed email addresses are sent to a Marketing Service Provider, they’re then matched against the Provider’s own existing list of their own users’ hashed information and our ads are served to those of our users who have successfully been matched with the Provider’s. Matched and unmatched hashes are then deleted by the Provider.
 
 For more information about how we use cookies and other tracking technologies, including how you can set and manage your preferences with regards to such technologies, please see our [Cookie Policy.](https://bumble.com/cookie-policy)
 
@@ -338,4 +338,4 @@ As Bumble evolves, we may revise this Privacy Policy from time to time. The most
 
 ### Effective date
 
-This Privacy Policy was last updated 11 August 2021.
+This Privacy Policy was last updated 27 September 2021.