1. Cupid Media Privacy Statement
(Last Updated 18 October 2021)
CambodianCupid.com (the Website) is owned and operated by Cupid Media Pty Ltd ACN 104 844 564, an Australian registered company (Cupid Media). Cupid Media forms part of the Dating Group of Companies.
Cupid Media is committed to protecting user privacy. We understand that visitors and users of the Website are concerned about their privacy, and the confidentiality and security of any Personal Data that is provided.
We will only collect, use and disclose Personal Data in accordance with this Privacy Statement and the laws applicable in the jurisdictions in which we are collecting Personal Data. If there is any inconsistency between this Privacy Statement and an applicable law, the relevant law will prevail to the extent of any inconsistency.
Our contact details are:
Online support form: Click here (use this option for fastest service)
Telephone: +61 7 5571 1181
Fax Number: +61 7 3103 4000
Post: CambodianCupid.com, PO Box 9304, Gold Coast MC, QLD 9726, Australia
Director: Kristina Sakunts, William Alena
Privacy Issues Email: firstname.lastname@example.org
If you are based in the European Union, VeraSafe has been appointed as Cupid Media’s European Union representative for data protection matters. In addition to contacting us using our above contact information, VeraSafe can be contacted in regard to matters related to the processing of your personal data. To make such an inquiry, please contact VeraSafe using this contact form: https://www.verasafe.com/privacy-services/contact-article-27-representative.
Alternatively, VeraSafe can be contacted at the following addresses:
Name: VeraSafe Czech Republic s.r.o
Address: Klimentsk6 46 Prague 1, 11002 Czech Republic; or
Name: VeraSafe Ireland Ltd
Address: Unit 3D North Point House, North Point Business Park, New Mallow Road, Cork T23AT2P, Ireland.
If you are based in the United Kingdom, VeraSafe has been appointed as Cupid Media’s representative in the United Kingdom for data protection matters, pursuant to Article 27 of the United Kingdom General Data Protection Regulation. In addition to contacting us using our above contact information, VeraSafe can be contacted in regard to matters related to the processing of your personal data. To make such an inquiry, please contact VeraSafe using this contact form: https://verasafe.com/public-resources/contact-data-protection-representative or via telephone at +44 (20) 4532 2003.
Alternatively, VeraSafe can be contacted at the following addresses:VeraSafe United Kingdom Ltd.
1.2 Basis for Collection
Where collect your Personal Data, we will do so on the following basis:
(a) Contractual services
Where you have created an account through our Website, or one of Cupid Media’s Related Websites or a website operated by Dating Group, and requested that we provide services to you, we will need to collect and use your Personal Data to:
(i) enter into our agreement with you; and
(b) Legitimate Business Purposes
Where we are not collecting and using your Personal Data for the purposes of entering into a contract with you, or to deliver to you our services, we may still collect and use your Personal Data where we consider:
(i) you will not be detrimentally impacted by our collection and use;
(ii) such collection and use is in accordance with what you would reasonably expect in the context of our use of your Personal Data; and
(iii) it is necessary to fulfil our legitimate interests.
This may include, for example, use of your Personal Data to improve our Website or the range ofservices that we offer to you.
(c) Legal compliance
There are certain situations in which we may be required to process your Personal Data in order to comply with the law, for example if we are subject to an order of the Court or a regulatory authority requiring such processing.
(d) Your consent
By accessing and using the Website you are consenting to the collection and use of your Personal Data in accordance with the terms of this Privacy Statement. By registering an account or logging on as a member on the Website or a Related Website, you are consenting to the collection and use of your Personal Data and Special Category Personal Data.
You may withdraw your consent to our collection and use of your Personal Data at any time by ceasing to use the relevant Website or Related Website. If you are a member that has created an account, you may withdraw your consent to our collection and use of your Personal Data and Special Category Personal Data by ceasing to use your account and making a request for your account to be suspended or deleted. Requests for suspension or deletion can be made through your account, or by contacting us using the contact information contained in clause 1.1(b) of this Privacy Statement.
Please note that in order to erase any Personal Data that we have already collected from you, a request must be made using the process set out in clause 1.7(f) of this Privacy Statement.
Due to the nature of the services provided by Cupid Media it is impractical for us to deal with you without knowing your full name. When you register for our services you are required to identify yourself and use truthful and accurate information.
1.4 Collection of data
(a) All users
Whenever you (including non-member users) visit our Website, our servers automatically record information for statistical purposes about your usage of the Website such as:
(i) the type of browser used; (ii) the referring URL; (iii) the IP address; (iv) the number and type of pages viewed; (v) the date and time of visits; and (vi) the exit URL.
This information we collect about you is not Personal Data and, in any event, remains anonymous. We do not link the anonymous information to any other Personal Data unless you have either registered as a member or logged on as a member at the time of use. Accordingly, if you have not identified yourself on the Website, such as by registering as a member or logging on as a member, we will not link a record of your usage of our Website to you personally.
Upon your registration as a member we collect information about you in order to provide you with the full benefits of membership. We collect non-identifying information as well as Personal Data from you directly when you first register, and also from time to time thereafter if you provide us with additional information.
Personal Data which may be collected by Cupid Media includes:
(i) your full name; (ii) your email address; (iii) your residential address; (iv) your phone number; (v) a photograph of you; (vi) your age; (vii) your occupation; (viii) a description of your appearance; (ix) your credit card and billing information (if provided by you).
For legal compliance and to properly enable you to utilize our services, we may also collect certain Special Category Personal Data including:
(i) your racial or ethnic origin; (ii) your political opinions; (iii) your religious beliefs or affiliations; (iv) your philosophical beliefs or trade union membership; (v) your health; (vi) your sexual preferences, practices or orientation; and (vii) your criminal record (if you are a resident of the USA).
By accessing and using the Website you are explicitly consenting to the collection and use of your Special Category Personal Data in accordance with the terms of this Privacy Statement. You are explicitly acknowledging and consenting to the transfer of your Special Category Personal Data to our third party service providers, including affiliated dating services controlled and operated by Dating Group
Our Website uses Google Analytics, a service which transmits website traffic data to Google servers in the United States. Google Analytics does not identify individual users or associate your IP address with any other data held by Google. We use reports provided by Google Analytics to help us understand website traffic and web page usage.
You can customize or opt out of Google Analytics for Display Advertising using the Ads Settings for your Google account.
(i) Google Marketing Platform integrations; (ii) Demographic and Interest Reporting; (iii) Display Advertising including Remarketing and Google Display Network Impression Reporting to advertise our services online; (iv) optimizing and personalizing ad services based on your past visits to our Website; and (v) reporting the use of ad services and interactions with ad impressions and how they are related to visits to our site.
Cookies and other tracking technologies may also be used to support analytics by other third parties.
(d) Third party interactions
We may allow third parties, including authorized service providers, advertising companies, data management platforms, and ad networks to serve advertisements on our Websites.
These companies may use tracking technologies (such as cookies, pixel tags, web beacons, device IDs, or advertising IDs) to collect information about users who view or interact with their advertisements. Any information that these third parties collect via cookies is completely anonymous and is non-identifiable. Examples of such third parties include: 360, Adobe, Akamai, Appnexus, Baidu, Bing, Cake, Chargeback.com, Criteo, Dating Group, Ecom Services, Facebook, Firebase, Google Ads, Google Ads Manager, Google Analytics, HotJar, Index Exchange, Naver, Olark, Oracle, Publift, Pubmatic, Pusher, RayGun, Rubicon Project, SDL, Sentient, Taboola, TikTok, Twitter, Urban Airship, Visa Inc. Yahoo, Yandex, Zero Bounce.
You may refuse the use of third party data collection by selecting the appropriate settings on your browser or by switching off your profile.
(e) Social media
1.5 Purposes of collecting, holding, using and disclosing Personal Data
(a) Collect from you only
Where it is reasonable or practical to do so we will only collect Personal Data about you from you directly.
(b) Purposes of collecting Personal Data
We will only collect Personal Data that is reasonably necessary for:
(the "Primary Purpose").
We do not sell Personal Data to any third parties or provide Personal Data to third parties for any business purpose (unless specifically referred to in this Privacy Statement).
(c) Use and disclosure of Personal Data
Use of Personal Data for the Primary Purpose will include the use of Personal Data in automated decision-making processes.
We will only use or disclose Personal Data about you for a purpose other than the Primary Purpose (being a "Secondary Purpose") where the following apply:
(i) the Secondary Purpose is related to the Primary Purpose and, if the Personal Data is Special Category Personal Data, the Secondary Purpose is directly related to the Primary Purpose; and (ii) you would reasonably expect us to use or disclose the Personal Data for the Secondary Purpose; or (iii) you have consented to the use or disclosure for the Secondary Purpose; or (iv) the use or disclosure of the Personal Data is required or authorized under law, regulation or court order.
In order to promote our products and services to you, we may also provide a hash of your email address (and no other Personal Data) to third parties, such as Facebook and other companies within Dating Group, in order to better target our advertising to you, by using products such as Facebook's Custom Audiences.
A comparison of your hashed email address will only be for the purpose of promoting our goods and services to you and will not be used by that third party for any other purpose. The comparison of the hash of your email address will not be used to identify you or your email address, and no further information about you will be provided by us to that third party. In the case of intra‐group transfers of your Personal Data you will be asked to consent for such.
You may withdraw your consent to our use of your Personal Data for the Primary and Secondary Purposes at any time by contacting us using the contact information contained in clause 1.1(b) of this Privacy Statement. However, this may affect or limit your ability to use the Website and Cupid Media's services.
(d) Holding of Personal Data
We will use best practice processes and take all reasonable steps to protect Personal Data that we hold from:
(i) misuse, interference, and loss; and (ii) unauthorized access, modification, or disclosure.
In the unlikely event that there is a serious data breach that is likely to result in a risk to your rights and freedoms, we will without undue delay notify the appropriate supervisory authority in your jurisdiction. Where there is a high risk that a serious data breach will impact upon your rights and freedoms, we will also notify you of that breach.
(e) Overseas disclosures
Any profile information that you have provided to us will be publicly viewable on your profile, irrespective of the location of the viewer. By creating a profile you acknowledge that overseas recipients will be able to view your profile.
In order to provide customer support, perform back office functions, perform fraud prevention tasks, or provide services to you we may need to allow our staff or suppliers (who may be located or whose resources may be located other than your country of residence) to access your profile information, billing information or other Personal Data that you have supplied.
By providing your Personal Data and Special Category Personal Data you are explicitly consenting to the international transfer and processing of such data in accordance with this Privacy Statement, including without limitation to any member of the Dating Group, in full and informed knowledge of the risks associated with such transfers and processing.
You may withdraw your consent at any time by contacting us using the contact information contained in clause 1.1(b) of this Privacy Statement. However, this may affect or limit your ability to use the Website and Cupid Media's services.
In all other circumstances we will only disclose Personal Data to a Third Party Country recipient or International Organization if the disclosure of the information is required or authorized by law, regulation or court order.
(f) Unsolicited information
If we collect Personal Data which we have not sought or requested about you, and if we determine we are legally permitted to collect that information, we will deal with that information in accordance with the terms of this Privacy Statement. In all other circumstances, we will destroy or de-identify the relevant Personal Data as soon as practicable, where it is lawful and reasonable to do so.
(g) Information not confidential
Any material or information provided by you for inclusion in any member profile will be treated as non-confidential and non-proprietary. We may use such material or information without restriction. Specifically, Cupid Media will use such material or information (including any profile information, photographs, video or audio recordings) that you have provided to us in order to copy your profile into any other relevant dating site owned and operated by Cupid Media, or any other relevant dating site forming part of the Dating Group. Any such material or information provided by you will be made available for other members or users of the Website to read.
We reserve the right to send electronic mail to you regarding recommended profile matches, notification alerts of activity such as interest alerts or message alerts, promotions or offers, changes or additions to our services, or any products and services of our affiliated businesses.
If you are a member of our Website you may manage your email preferences by using the settings on the "Notifications" page to customize what type of email communications you wish to receive.
1.6 Destruction of Personal Data
We will keep your Personal Data only for as long as we need it for legitimate business purposes and as required by applicable law. We will take reasonable steps to erase any Personal Data that we hold about you, where:
(i) we no longer need the Personal Data for the purposes for which it was collected and we are not otherwise entitled to retain such data; and (ii) we are not required or obligated by law, regulation or court order to retain the information.
If certain information has been provided to third parties in accordance with this Privacy Statement, retention of that information will be subject to the policies of the relevant third party.
1.7 Access, correction and portability
(a) Access to Personal Data
We will provide you with access upon request to the Personal Data held by us in relation to you except to the extent that:
(i) giving access would be unlawful; or (ii) denying access is required or authorized by or under a relevant law, regulation or court order.
To request access to your Personal Data, please contact us using the details provided in clause 1.1(b) of this Privacy Statement.
Following your request, we will contact you within one (1) month from the date of receipt of your request and provide you with the Personal Data requested, unless we have determined that some reason or obligation exists requiring us to withhold access to the Personal Data.
(b) Third party disclosure
We do not sell your Personal Data to any third parties. Unless specifically referred to in this Privacy Statement, we also do not disclose your Personal Data to any third parties for other business purposes. However, notwithstanding this, you may at any time request that we provide confirmation that your Personal Data has not been sold to a third party, or to request details of any third party to which information has been sold or disclosed for business purposes.
Notwithstanding the above we may in certain circumstances make your Personal Data available to our third party service providers (to enable us to deliver our services to you), to our affiliated entities that operate dating services that we control or to other members of the Dating Group (for example, where you have requested that we port or transfer the profile you have created on one of our websites to an alternative website or dating service).
(c) Data portability
Insofar as it does not adversely affect the rights and freedoms of others and where you have communicated a request to us:
(i) where we have employed an automated means to process your Personal Data, we will provide you with a copy of such Personal Data in a structured, commonly used and machine-readable format; and (ii) after receiving your request, where technically feasible, we will transmit your personal data directly to another data holder.
(d) Commercially sensitive information
Where providing you access to your Personal Data would reveal commercially sensitive information, we are unable to give you access to that information. However, we will provide you with the reasoning behind our determination.
(e) Use of intermediaries
Where we cannot directly provide you with access to your Personal Data we may, if it is reasonable, engage the services of an intermediary to do so.
(f) Correction and erasure of Personal Data
It is your responsibility to ensure that the information you provide to us is accurate and to update your Personal Data as necessary. If for any reason you are unable to correct any Personal Data held by us, please contact us using the details provided in clause 1.1(b).
If after receiving your request we choose not to correct your information, we will notify you within one month of the reason of our refusal and the mechanisms available to you to object to our refusal.
If you wish to have your Personal Data erased, please communicate your request to us using the contact information provided in clause 1.1(b). The only circumstances in which we will not take reasonable steps to erase your Personal Data are where we need to keep it in accordance with another provision of this Privacy Statement, the GDPR, or for any other legal reason. However, our deleting of your Personal Data may result in the deletion of your Cupid Media account and will mean you are unable to access our services.
If we correct or erase Personal Data about you that we previously disclosed to a third party in accordance with our Privacy Statement, we will take reasonable steps to notify the third party of the correction or erasure and to request that they do the same.
(g) Refusal to correct or erase
If at any time we refuse or deny you access to your Personal Data, or refuse to correct or erase your Personal Data, we will provide you with reasons for such denial or refusal.
(h) Restriction of processing
You may request that we limit or restrict the manner in which we deal with and process your Personal Data, in which case we will only process your Personal Data: with your consent; for the establishment, exercise or defense of legal claims against us; or for the protection of the rights of another person.
Access to, erasure and rectification of your Personal Data, including any communications related thereto, will generally be provided free of charge.
Where your requests are manifestly unfounded or excessive in nature (particularly due to repetitiveness) we may charge you a reasonable fee for providing the information or communication, or taking the action requested. Where your requests are manifestly unfounded or excessive in nature, we may also refuse your request.
(j) Specific objection rights
If it becomes necessary for us to process your Personal Data without your consent for reasons of:
(i) performing a task in the public interest; (ii) the exercise of an official authority that has been vested in us; or (iii) where it is in our legitimate interests or the legitimate interests of a third party to do so;
you will have the right to object to such use.
If you object to our use of your Personal Data we will refrain from using your Personal Data unless compelling legitimate grounds exist for us to use that Personal Data, or for the establishment, exercise or defense of legal claims.
If we have collected your Personal Data in accordance with this Privacy Statement and elect to use such Personal Data for the purposes of direct marketing (to which you consent), you have the right to object at any time to such use.
Upon receiving an objection we will, as soon as is reasonably practical, cease using your Personal Data for the purposes of direct marketing.
(a) Making a complaint
If you believe that we have used or disclosed your Personal Data in a manner which is contrary to this Privacy Statement or that otherwise breaches an applicable law, then you should email us at email@example.com.
If you are based in the European Union and have a complaint or enquiry regarding your Personal Data, you may also contact our European representative VeraSafe using the contact information contained in clause 1.1(b) of this Privacy Statement.
You also have the right to lodge a complaint with the relevant supervisory authority in your jurisdiction. If you are unsure who your relevant supervisory authority may be, please contact us so that we may provide you with assistance.
(b) Our response
Within 30 days of receipt of your complaint we will notify you in writing as to what action we propose to take in relation to your complaint and will provide you with details of what further action you can take if you are not satisfied with our response.
"Dating Group" means SOL Holdings Limited (No. HE342740, Cyprus) and any of its affiliated or related entities that it controls and which provide dating services to customers.
"General Data Protection Regulation" and "GDPR" mean Regulation (EU) 2016/679 of The European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC.
"International Organization" means an organization and its subordinate bodies governed by public international law, or any other body which is set up by, or on the basis of, an agreement between two or more countries.
"Personal Data" means any information relating to an identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person and includes Special Category Personal Data.
"Processing" means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
"Special Category Personal Data" means personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, your criminal record, genetic and biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning your sex life or sexual orientation.
"Related Website" means any other website owned, operated or controlled by Cupid Media Pty Ltd ACN 104 844 564 or a member of Dating Group.