Privacy Policy

Who we are

S2 CONNECT AI LTD, a company incorporated in London under company number 15792062 and located at 39 Atlantis Avenue, London, England, E16 2UD is the controller responsible for your personal data.

UDAA has designated a Data Protection Officer and they can be reached by emailing info@udaa.ai or by post at the address above.

Who can use UDAA?

You must be aged 18 or over to use the App. When you sign up to use the App you will be asked to confirm your age so that we can check that you are 18 or over. If you are not aged 18 or over you are not permitted to use the App.

How is my personal information collected and used by UDAA?

UDAA recognizes information from any images and photos: screenshots of social networks, chats, photos of someone else's phone screen, personal photos etc. Advanced algorithms extract critical information from images, making meaningful connections just a tap away. With UDAA the journey from an intriguing image to a meaningful connection is just a tap away making it an indispensable tool for the modern dater seeking efficiency and excitement in their dating life.

Registration

When you sign up for an User Account after downloading the UDAA App, we will collect certain information to create your account (“Account Information”) and create your profile (“Profile Information”) from, which may include your:

Account Information:

• Your phone number;
• Email address (if you have ever provided one, as further set out below);
• Age

Profile Information:

• Location (whether by providing location access from your phone, telling us your location or telling us where you grew up and where you are currently living in your profile information);

Location settings

If you have given the App access to your location in your device settings, when you use the App we will collect information about WiFi access points as well as other location information about your longitude and latitude and may save your device’s coordinates to offer certain features to you as part of the Services.

The location you share on your profile will be shown at city level in your profile in the App.

If you have given the App access to your location, but wish to stop, you can do so by the following methods:

1. iPhone app — settings, privacy, location services, UDAA
2. Android — settings, security and location, location, UDAA

Email verification

For security purposes and to provide the best user experience, we require users to verify the email address they use to register for a user account. To do this, we send a code to the email provided to register in the application. We want to make sure you are not a robot! And we also want to avoid creating fake UDAA accounts that can be used for malicious activities and cybercrime - they threaten the app's network and ruin everything.

Subscribing to marketing communications

From time to time, we may offer you the ability to subscribe to marketing communications by email. If you subscribe to marketing communications by email (including our newsletter, insights and any other marketing-related communications), the email address you provide will be linked to your User Account to enable its recovery, in case you lose your phone and/or change phone numbers. You can unsubscribe at any time by clicking the ‘unsubscribe’ button at the bottom of the email. After you unsubscribe, we will continue to offer you the ability to recover your User Account using the email address you provided. You may also separately provide your email address to us in your account settings, for account recovery, without subscribing to marketing communications.

How else does the App collect and use my data?

Data collected automatically

When you use the App we automatically collect certain information, including the unique device identifier assigned to your device (“Device ID”) and other information regarding your access to or use of the App. We collect information about your browser type, referring domain (this is information about a third party site that you were on before you clicked through to the UDAA site) and mobile carrier. We use this information to check that it is you using the App, to see how you are using the App service so that we can improve our services, to keep track of your preferences and to create a more tailored user experience.

Data we collect from others

In addition to the data you directly provide us, some data may be received from others, including:

• Other users: Users you interact with on the App might provide us with information about you from time to time. For example, another user may upload their address book to the App, and it may contain your phone number and full name, even if you haven’t provided this to us directly.
• Third party partners: When we publish ads with third party advertising partners, those partners may share information about the performance of those ads, and link the data to the users who consumed them (aka ‘tracking’). In some cases, the amount of tracking data our partners share with us will depend on your device settings across the board. In other cases, the amount of data we are able to collect will depend on the information you specifically opt to share with us.

Other data you choose to share with us

• Tracking data: By allowing the App to track you, you are consenting to UDAA obtaining certain more detailed information about you. For more information on the exact information collected when you opt in to track your activity, please consult the ‘App Privacy’ section of the App’s page on the App Store if you are an iPhone user, and the Data safety section on the App’s page in the Google Play Store if you are an Android user.
• For iOS 14.5 (or later) users: If you opt out of tracking on your device, we will not link identifiable information from third-party companies' apps and websites with identifiable information from the App for advertising purposes. Further information on how to control tracking settings is available below.
• Location data: If you are prompted by the UDAA App to share your location, this is optional. If you decline permission for us to collect location data, we will not collect it, and you can still use the app. However, if you give us permission to collect your location data, we will be able to determine your latitude and longitude with a degree of accuracy that depends on the services and device you are using. Your settings may allow us to collect location information only while you are using the app, or to do so at all times. In all cases, this remains optional.

What is the legal basis that allows UDAA to use my data?

We are only permitted to use your data when we have a lawful basis to do so or there is an exception under which UDAA is allowed to use your data. The table below provides an overview of the legal bases that UDAA relies on to use your data, unless you are in Mexico or the US in which case the "Legal basis" column does not apply to you.

How long will UDAA keep my data?

We keep your personal information only as long as we need it for legitimate business purposes (as set out above) and as permitted by applicable law.

In practice, we delete or anonymise (if permitted by applicable law) your information upon deletion of your account, unless:

1. we must keep it to comply with applicable law;
2. we must keep it to evidence our compliance with applicable law;
3. there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or
4. to the extent permitted by law, the information may be kept for our legitimate business interests, such as fraud prevention and enhancing users’ safety and security. For example, information may need to be kept to prevent a user who was banned for unsafe behaviour or security incidents from opening a new account, or to enable you to re-activate and restore your account during the 30 days after you close your account.

Please note that your conversations with other users via the App may not be deleted if you delete your account if these conversations are with other active users of the App. In addition, deleted information may persist for up to 30 days in backup copies, after you close your account, to enable restoration.

Where UDAA uses machine learning, for example, to help us detect and prevent fraudulent card transactions, and to detect and prevent spam communications on the app (as explained above), we may need to keep personal information for a longer period than the retention periods explained above, to enable the machine learning to work properly, and if it is permitted by applicable laws. Where this is the case, we always seek to minimise the amount of personal information that is used and we ensure that it is ring-fenced and kept securely from other user personal information. We regularly review the period for which personal information is required for machine learning purposes and delete any identifiable information when it is no longer required.

What information does UDAA collect about me if I’m under the minimum age to use UDAA?

UDAA does not knowingly collect any information about or market to anyone under the minimum age set out in the “Who can use UDAA?” section above. If we become aware that somebody who is under the minimum age 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 UDAA. If we do delete a profile because you violated our age restriction rules, we may retain your e-mail and IP address to ensure that you do not try to get around our rules by creating a new profile.

Who does UDAA share information with?

We may share aggregated information that includes your personal data (but which doesn’t identify you directly), together with other information including log data with third parties for industry analysis and demographic profiling.

In addition, we share your data with the following categories of third-parties:

1. Information technology companies (hardware and software) which provide services to support our products
2. Fraud prevention and anti-spam providers to protect the service from criminal activity
3. Moderators to monitor activity on the site/apps and approve content
4. Law enforcement agencies, 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

We ensure these parties must adhere to strict data protection and confidentiality provisions that are consistent with this Policy. Measures are taken to ensure that the data shared is non-attributable to the greatest extent possible.

In the event that UDAA 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.

Your data may be shared with other UDAA group companies, for example, to block accounts and suspected fraudulent payment transactions as part of our anti-spam and anti-fraud procedures.

What information can other users access about me?

Following up on reports

If someone reports you for bad behaviour on the App (for example: breaching our Terms of Use), in addition to the actions we may take under our Guidelines, we may provide them with further details on any action taken as a result of their report.

Your rights

UK/EU

Under UK and European law, you have the right to lodge a complaint with data protection regulators. If you are based or the issue you would like to complain about took place in the UK, you can complain to the Information Commissioner’s Office (ICO). You can find out how to raise a concern with the ICO by visiting their website at www.ico.org.uk. If you’re based or the issue you would like to complain about took place within the European Economic Area, you can complain to your local data protection regulator and a list of their contact details can be found here.

You have a number of rights under UK/European data protection law.

1. Right to be informed: what personal data an organisation is processing and why (we provide this information to you in this notice).
2. Right of access: you can request a copy of your data.
3. Right of rectification: if the data held is inaccurate, you have the right to have it corrected.
4. Right to erasure: you have the right to have your data deleted in certain circumstances.
5. Right to restrict processing: in limited circumstances, you have the right to request that processing is stopped but the data retained.
6. Right to data portability: you can request a copy of your data in a machine-readable form that can be transferred to another provider.
7. Right to object: in certain circumstances (including where data is processed on the basis of legitimate interests or for the purposes of marketing) you may object to that processing.
8. Rights related to automated decision making including profiling: there are several rights in this area where processing carried out on a solely automated basis results in a decision which has legal or significant effects for the individual. In these circumstances your rights include the right to ensure that there is human intervention in the decision-making process.

If you want to exercise any of your rights listed above please visit Feedback Page or email us at info@udaa.ai. You can also contact us by post at 39 Atlantis Avenue, London, England, E16 2UD.

California

If you are a California resident, please note the following about how we collect, use and disclose your personal information, including additional rights you may have to your personal information:

• CA Personal Information. Consistent with the “What is the legal basis that allows UDAA to use my data” section above, we may collect certain categories of information about California residents, such as:
  • Identifiers: name, gender, address, data of birth, photo, mobile phone number, e-mail address, IP address, username, device ID and contact list; if a California resident participates in certain programs or contests we administer, we may also ask them to provide social security number, taxpayer identification number, and government-issued number or identification;
  • Commercial Information: PayPal ID, payments received, type of payment, and details of payments;
  • Internet or Other Electronic Network Activity: traffic statistics, clickstream data, mobile carrier, and search terms;
  • Geolocation Data: physical location of a California resident’s mobile device;
  • Audio information: audio streams and recordings;
  • Professional or employment-related information: if a California resident submits an application to work for us, we may collect their professional or employment-related information and work history;
  • Education information: if a California resident participates in certain programs we administer, we may collect information about their educational institution.
  • The above categories of personal information correspond with the categories of personal information listed under Cal. Civ. Code § 1798.140(o)(1)(A), (D), (F), (G), (H), (I) and (J).
• Sources of CA Personal Information. Consistent with the “How is my personal information used by UDAA to provide the UDAA services to me?” section above, we may collect personal information directly from California residents, and automatically when they use UDAA.
• Use of CA Personal Information. We process California residents’ personal information for the purposes outlined in the “What is the legal basis that allows UDAA to use my data” section above.
• CA Personal Information Sold or Disclosed for Business Purposes.
• Sharing Personal Information for Business Purposes: We disclose the following categories of personal information for business purposes: Identifiers, Commercial Information, Internet or Other Electronic Network Activity, Geolocation Data, and other information to information technology, fraud prevention and anti-spam services providers.
• No Sale of Personal Information: We do not sell California residents’ personal information. We do not have actual knowledge that we sell the personal information of minors under 16 years of age.
• CA Privacy Rights. If you are a California resident and subject to certain exceptions, you may have the following rights:
  • Right to Know and Delete: you may have the right to request that we disclose what personal information we collect, use, disclose and sell about you specifically (“right to know”) and/or to delete the personal information we hold about you. To submit a request to exercise these rights, please submit an email request to info@udaa.ai and include “CCPA Request” in the subject line. To protect your and others’ privacy and security, we will verify your identity before responding to any request, and may ask you to provide us with information matching the identifiers and commercial information already maintained by UDAA about you or additional proof where necessary. If you are making this request on behalf of someone else, we may request the authorized agent provide us with a copy of a valid power of attorney or evidence of the written authorization. You will not be penalized or discriminated against for exercising your rights to your personal information.
  • Right to Opt-Out (“Do Not Sell My Personal Information”). You have the right to opt-out of the sale of your personal information by a business. We do not sell your personal information.
  • Shine the Light: California’s “Shine the Light” law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the businesses’ practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes. If you wish to find out about any rights you may have under California Civil Code section 1798.83, you can write to us at info@udaa.ai.
  • “Do Not Track”: Under California law, operators of online services are required to disclose how they respond to “do not track” signals or other similar mechanisms that provide consumers the ability to exercise choice regarding the collection of personal information of a consumer over time and across third party online services, to the extent the operator engages in that collection. At this time, we do not track our users’ personal information over time and across third-party online services. This law also requires operators of online services to disclose whether third parties may collect personal information about their users’ online activities over time and across different online services when the users use the operator’s service. We do not knowingly permit third parties to collect personal information about an individual user’s online activities over time and across different online services when using the app.

Russia

Under Russian law you have the right to obtain information relating to your personal data. You have the right to obtain from us rectification of your personal data, its blocking or erasure where personal data is incomplete, irrelevant, inaccurate or unlawfully processed, or is no longer necessary in relation to the purpose for which it was processed, as well to take any other measures to protect your rights in accordance with the law.

Argentina

Under Argentine law, you have the right to lodge a complaint with the data protection regulator.

If you live in Argentina, you have a number of rights under Argentine Data Protection law, for instance:

1. Right to be informed: what personal data an organisation is processing and why (we provide this information to you in this notice).
2. Right of access: you can request a copy of your data.
3. Right of update/rectification: if the data held is inaccurate, you have the right to have it updated/rectified.
4. Right to erasure: you have the right to have your data deleted in certain circumstances.
5. Rights related to automated decision-making including profiling: there are several rights in this area where processing carried out on a solely automated basis results in a decision which has legal or significant effects for the individual. In these circumstances your rights include the right to request an understandable explanation of the logic applied in the automated decision-making process.

In Argentina the data owner is entitled to exercise the right of access to his/her/its personal data free of charge at intervals of not less than six months, unless a legitimate interest to that effect is established in accordance with article 14, paragraph 3 of Law No. 25,326. THE PUBLIC INFORMATION ACCESS AGENCY, in its capacity as the Control Entity of Law No. 25,326, has the power to attend complaints and claims filed by those whose rights are affected due to breaches of applicable regulations on personal data protection. The data owner may at any time request the removal or blocking of his/her/its name from the databases referred to in this article. Every communication for advertising purposes that is carried out by mail, telephone, email, Internet or any other future remote means, shall state expressly and prominently the possibility of the data owner to request the withdrawal or blockage, in whole or in part, of his/her/its name from the database. At the request of the interested party, the name of the person responsible or user of the database that provided the information must be reported.

Mexico

If you are in Mexico you have at all times the right to access and view the information we have about you: likewise, you have the right to require such information to be corrected or cancelled; you may oppose our use of your personal data for specific purposes and/or revoke at any time the consent you granted us for the processing of your personal data to the extent permitted by the law. In order to exercise such rights or to ask any questions or complain in relation to the processing of your personal data please address your request to the following email: info@udaa.ai.

Your requests will be evaluated in the terms set out in the applicable laws. Our specialist will communicate to you (i) the information required for your identification as well as the documents needed to be sent alongside your request; (ii) the time periods in which you will receive an answer to your request; (iii) how you should file your request, including the forms that you may use to file your request, if any, and; (iv) the form or means in which we will deliver you the information.

In addition, you may limit the use or disclosure of your personal data by sending your request at info@udaa.ai.

If your request is appropriate, our specialist will register you on the exclusion list for the purpose for which the exclusion is applicable.

How does UDAA protect my personal data?

UDAA has implemented security measures intended to protect and prevent the loss, misuse, and alteration of the information under our control, including your personal data. Our technical experts at UDAA work hard to ensure your secure use of our application.

While we take reasonable precautions against possible security breaches of our application, member database and records, no application or internet transmission is completely secure and we cannot guarantee that unauthorised access, hacking, data loss, or other breaches will never occur. We urge you to take steps to keep your personal data safe (including your password) and to log out of your account after use. If you lose your password or give it out, or another service provider that you use suffers a data breach and you have used the same credentials with that service provider as you have with UDAA, your personal data may be compromised. If that happens, please report it to Support via Feedback Page.

Where is my personal data kept?

We want you to be able to access UDAA wherever you happen to be in the world. To enable us to provide that service, we operate a global network of servers including in сentral Europe. The hardware is located in third-party data centres but is owned by Amazon. If your personal information is transferred from the UK or the European Union to other countries outside the UK or European Union respectively, we ensure that the data is adequately protected by ensuring that valid, legal mechanisms are in place, such as approved model clauses (which can be found here), and implementing robust contractual standards. If you want more information relating to the nature of the safeguards we have in place please email info@udaa.ai.

Why did I receive an Apple Tracking Transparency prompt?

If you are an iOS 14.5 (or later) user: Apple’s App Tracking Transparency (ATT) framework requires UDAA (like all app developers) to ask iOS users for permission before collecting data about them from other companies' apps and websites for advertising targeting or measurement purposes.

UDAA will display the ATT prompt prior to connecting identifiable data collected from UDAA with identifiable data from other companies' apps and websites for advertising purposes.

You can opt in or out of tracking at any time as follows:

1. On your iPhone, go to Settings > Privacy & Security > Tracking, where you can see a list of all the apps that have requested to track your activity
2. Tap to turn UDAA’s permission to track on or off.

Does UDAA collect any other personal data about me?

When you submit an enquiry to our Customer Support team through our Contact page, your email address is collected, and your IP address may be monitored. Additionally, any information you provide will be used to assist in addressing your questions or concerns. We will maintain records of our interactions with you, including any complaints you make about other users or that other users make about you, for a period of six years following the deletion of your Account.

Does UDAA use my personal data for any other purpose?

We may use your personal data to resolve disputes, troubleshoot problems and enforce our Terms of Service.

From time to time we may run surveys for research purposes and we may contact you to find out if you would like to take part. Such surveys are optional and more information will be provided at the point of contact. We may also contact you for feedback purposes. If you do not wish to be contacted to take part in a survey, please contact our Customer Support Team at our Feedback Page.

What are ‘cookies’ and what ‘cookies’ does UDAA use?

We collect information by placing cookies on your computer or mobile. A cookie is a piece of text stored on your computer or mobile by your web browser. They are basically a tool that stores information about website visits, recognises you and your preferences each time you visit UDAA, and ensures site functionality and enables us to provide the services our members request.

When you visit the publicly available sections of UDAA, a session ID cookie is placed on your computer that only lasts while you’re visiting. We also place persistent cookies (also known as local storage devices) on your device, so that UDAA remembers you and makes your login experience faster and easier. We may use persistent tracking cookies on your mobile device, mainly for security protection purposes, such as to prevent phishers, scammers, unauthorised log in attempts, and to help you access your hacked account. We do not use any information whilst you are logged off.

You may set your browser and your mobile settings to block cookies and local storage devices, but if you do so, you may not be able to access the features that UDAA offers.

UDAA’s use of cookies and local storage devices basically falls into the following categories:

• cookies related to the performance of UDAA’s site, such as analytics that help us determine how our site is performing and ensuring a smooth and trouble-free experience for our members and visitors;
• cookies related to the functionality of UDAA’s site, such as remembering your preferences at log in or your preferred language or allowing you to chat, add photos and message UDAA users;
  and
• third party cookies which link to other social networks and which you request via social plugins.

UDAA uses cookies and local storage devices so that we know who you are, what interests you have and so that you can do the things online that you want to do, like chat with new people and share your content knowing that your data will be secure. Below is a table to explain UDAA’s cookie functions and why they’re used.

Our use of cookies and local share devices, including the specific cookie names, may change over time, but will generally fall into the above categories. We will notify you of any important changes to our use of cookies and local storage devices. If you would like to know more about cookies, including flash cookies/local storage devices, and/or how to disable them. the following websites provide useful information:

• www.allaboutcookies.org
• www.youronlinechoices.eu
• http://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html

Changes to the Privacy Policy

Any changes to this Privacy Policy or to the purposes for processing your data will be communicated to you by means that are reasonable, such as by email or a notification on our app. To the extent permitted by law, changes will be effective from the day after publication, unless we let you know otherwise. To the extent permitted by law, your use of our site/app after the Privacy Policy has been updated means you consent to the changes, where applicable.

This Privacy Policy was last updated on 9 July 2024.