Privacy Policy

CHAMELEON VIBES – DATA PROTECTION AND PRIVACY POLICY

Chameleon Vibes takes its responsibility for the security of personal data extremely seriously and our procedures are fully aligned with the safeguarding requirements of the UK Data Protection Act 2018 and the EU General Data Protection Regulations 679/2016. Our core business requires individuals to provide sensitive information about themselves and for us to use that information to make connections between people. Our over-riding principle is that personal information will only be accepted from the individual themselves and we will be sure that express permission has been given for us to use that information only for the purpose that it is given. We do not link with, or otherwise seek from or provide to any personal information held or used by a third party such as a social media platform.

Accountability

 Chameleon Vibes considers itself responsible and accountable for compliance with data protection regulation and best practice and that it is fully able to demonstrate that compliance. Appropriate technical and organisational measures have been established to meet the requirements of accountability, including through our data protection policy which is based on a ‘data protection by design and default’ approach. Accountability it also demonstrated through the maintenance of clear and accurate documentation relating to contracts, individuals, and processes, and the implementation of appropriate and robust data security measures. We also conduct regular and routine data protection impact assessments. Accountability obligations are considered ongoing and we regularly review and where necessary update the measures in place. Chameleon Vibes strives for a culture of privacy across the organisation in order to build trust with our subscribers. The Chief Executive Officer is responsible for all aspects of compliance. The Data Protection Officer is responsible for the daily management of the compliance framework.

Consent

Information provided by individuals to Chameleon Vibes will be stored on a secure company server and will not be shared automatically with any third-party. All data will be collected for specific, explicit, and legitimate purposes and will not be further processed in a manner that is incompatible with these purposes. Data will be limited to that which is adequate and relevant to what is necessary to fulfil individuals’ expectations of the service provided. Based on these principles of assurance, a record will be kept of the individual’s express consent for us to use and store any personal information provided. Consent, supported by contract and legitimate interests, provides the lawful basis from which Chameleon Vibes will store and process personal information provided.

Data Requirements

 Entry Quiz. Entry into Chameleon Vibes platform requires the user to complete a profiling quiz before they can sign up to use the site. The quiz is a way to get to know the user better and to determine whether Chameleon Vibes is the best dating site for them. The answers to the quiz are submitted to Chameleon Vibes and the user will then receive tailored personal feedback and an invitation to join. Other users will be able to view an individual’s overall quiz result but not the specific answers to each question. The results may be used as a matching criteria. If the user does not wish to partake in the quiz, they will not be able to use the Chameleon Vibes service.

Registration Process. To access and use Chameleon Vibes services, users will need to register. At minimum, and in addition to the data associated with the entry quiz, they will be required to submit their email address, gender, and their sexual orientation (in terms of the partner they are looking for). In general, the types of data that we will collect during the registration and profile set up are as follows: country of residence, postal code, gender, sexual orientation, date of birth, marital status, do you have/want children, languages spoken, what countries the user was raised in, parents’ nationality and reasons for living abroad. In addition, the user may choose to provide Chameleon Vibes with other information such as about interests and lifestyle. By sharing this information with Chameleon Vibes, the user acknowledges and agrees that Chameleon Vibes stores and uses this information for matching purposes.

 Necessity of Data. The Chameleon Vibes service works by sharing information between users. This is the information in the user’s ‘profile’.  This will include the user’s age, entry quiz results, personal experiences, personal values, and languages spoken. Such data is then used to generate the most likely matches between users, based on assessments of compatibility. To obtain the best experience from Chameleon Vibes’s services, and to increase the chances of successful connections with others, it is recommended that users complete all fields. Chameleon Vibes requests that in addition to the above text and photographs are included in the user’s Profile. The system has a default request to provide seven photographs including a main Profile picture. At least seven photographs should be uploaded for the user’s Profile to display correctly. When emails are sent to users from Chameleon Vibes with new potential matches, photographs will not be immediately visible unless the user opts to view the profile photo. User-names, ages, and location information are shared together with a link to user Profiles. All information provided by the user to populate a Profile (including photographs and text during the registration process) will be publicly visible to other members on our website. Chameleon Vibes will be unable to process a user’s Profile and not be able to suggest potential matches if a user Profile is missing basic information such as the user’s gender and the desired sex of a potential partner or if the entry quiz has not been completed.

Communication Data. All communication between registered users of the Chameleon Vibes platform will be stored including users’ contact with the Chameleon Vibes administration team. Communication hosted by the platform is end-to-end encrypted. When contacting Chameleon Vibes via the online contact form the content of messages sent will be encrypted in transit and Chameleon Vibes’s reply will be protected in transit, provided that the user’s email provider supports Transport Layer Security (TLS) transfer encryption. When contacting Chameleon Vibes via email the content of the user’s message will only be protected in transit via TLS transfer encryption if the user’s email provider supports TLS transport encryption.

 Video Communications. To support video communications between users Chameleon Vibes has an agreement with Xirsys, a service provider based in Santa Clarita, California, USA. For this encrypted service to work Chameleon Vibes supplies the service provider with the user’s IP address and Profile ID. The service provider stores data about the time and duration of the calls. This data is needed for technical purposes and invoicing. Chameleon Vibes does not keep audio or video recordings and does not share any other personal information with the service provider. If the user does not want Chameleon Vibes to share the details mentioned above, or agree to the service provider keeping records of times and durations of calls, the user should not use the Chameleon Vibes video chat option.

 Use of Email Addresses. When the user provides Chameleon Vibes with an email address either through doing the entry quiz or setting up their profile it will be used to send an invitation to join the site, to notify the user of new matches and for other communication associated with the Chameleon Vibes service and service platform. On occasion, personalised promotions, administrative information, and newsletters will be sent to the same email address. The user can manage messages and mail notifications and unsubscribe from administrative communication (including newsletters) in using profile preferences at any time. Providing the user’s email provider supports TLS transport encryption, such emails are protected in transit via TLS transfer encryption.

 Usage Data. Every time the Chameleon Vibes website is accessed, usage data will be collected. This means that even if an individual has not registered with and subscribed to Chameleon Vibes, usage data will be recorded. This data is sent to Chameleon Vibes by the individual’s internet browser and is stored on internet log files. This data includes information about the individual’s browser type, the individual’s operating system (and its screen resolution), and the Internet Protocol (IP) address provided by their ISP.Chameleon Vibes may also compare the individual’s IP address against any number of freely available geo-databases to collect information about the individual’s ISP location. Information will also be recorded about the date and time that the website was accessed, any referral URL that linked the individual to Chameleon Vibes, the amount of data transmitted during the individual’s use of the website, a status message about the success or otherwise of access, a session identifier, and the individual participant’s pseudonym.

 Additional User Data for Chameleon Vibes Subscribers. Each time a Chameleon Vibes subscriber logs in to our network, we also collect their Chameleon Vibes user identifier in addition to the data mentioned in Paragraph 6 above. While using the website cookies or pseudonym IDs (such as user-ID, ad-ID) are also stored on the user’s device.

 Information Processing. The primary offering of the Chameleon Vibes service includes notifying subscribers of potential matches. These matches are delivered to the user’s Profile under ‘my Matches’ and also by an email notification. The notification email will inform the user of potential matches’ username, sex, age, location, compatibility level, a link to their profile, and a blank box instead of their profile photo. The same information about the user is sent to other Chameleon Vibes subscribers that are considered to be a potential match. Chameleon Vibes will also notify the user of any new activity associated with the user’s Profile, ‘winks’ sent, and new messages. If the user does not wish to receive such notification this can be managed in their Profile under ‘system preferences’. It should be noted that other subscribers who have this option activated will still receive notifications even if a user has deactivated this service. 

The Necessity to Process Information. Chameleon Vibes’s services are described in our General Terms and Conditions. To be able to provide these services to users we need a legal contractual agreement whereby the user consents to Chameleon Vibes’s use of information provided to enable the full use of the services available. Information will also be processed to ensure Chameleon Vibes’s full compliance in relation to data security (including the security of our systems and to identify and track unauthorised attempts to access our system), to safeguard and protect Chameleon Vibes’s own rights and legal responsibilities, and to send tailored promotional material directly related to the Chameleon Vibes product.

 Prevention of Abuse and Misuse. To prevent and safeguard against abuse and misuse of data Chameleon Vibes automatically collects, processes and verifies data entered during the completion of the entry quiz, registration, and Profile set-up. If there is evidence of misuse through our automated data processing, then Chameleon Vibes will investigate. Additionally Chameleon Vibes undertakes profile checks against any subscribers that are reported by use of the ‘Suspicious Profile’ button and/or have been deemed to have breached our General Terms and Conditions. Chameleon Vibes acknowledges and accepts it is its obligation and interest to safeguard its platform and its subscribers from any breach of our General Terms and Conditions and/or legislation.

 Data Transfer to Third Parties. Chameleon Vibes will only share user data with third-party providers if it is required as part of the legitimate and declared service to the user or if the user gives their express consent. It should be noted that the exercise of law through a Court Order is also considered a ‘Third Party’. Chameleon Vibes uses third-party providers to help support the service provided to the user, including external payment facilitators, invoice settlement and debt resolution agencies. In this regard, all invoices associated with user subscriptions are expected to be settled promptly, if any outstanding instalments are still not settled after reasonable reminder, Chameleon Vibes is obliged to share all relevant data with a debt resolution agency. It is the responsibility of all third-party providers to manage personal data for their own purposes and in accordance with their own policy. The user should therefore also familiarise themselves with these third-party policies.

 List of Third-Party Providers. Chameleon Vibes acknowledges relationships with the following fully vetted third-party providers in accordance with the terms and provisions of this policy: Xirsys, Cloudflare, Cloudways, Google Analytics, woo-commerce, CCBill, and Mailchimp. We also provide access to our website for a third-party moderator. Full details of all third-party relationships can be provided following enquiry to [email protected]. Chameleon Vibes has entered relationships with these providers solely in order to deliver the core services it offers to subscribers. Only the minimal amount of information that is necessary to support specific functions will be shared with third-party providers. Please note that CCBill/woo-commerce, as third-party providers, are engaged to process subscription payments. As such they will process and store necessary credit and debit card account information to enable transactions in accordance with their own privacy policies and independently from Chameleon Vibes, which does not receive, manage, process, or store such financial information.

 Cookies and Tracking Technology. Almost every website uses cookies. A Cookie is a plain text file that is sent to a device when a user is surfing the internet. It is stored in the device’s browser. Cookies are used to personalise browsing experiences by tracking user activities. When a user revisits a website their browser will recognise the user as having returned to the site. Some cookies are automatically deleted at the end of a browser session (these are called session cookies). Others are stored for a certain period of time or permanently on a browser before they self-delete or are manually removed (these are called persistent cookies). Chameleon Vibes uses certain cookies to make sure that our website and our services are easy, secure, and safe to use. Without these cookies, services that users demand (such as a secure website and service) would not be possible. This category of cookies includes cookies that:

  •       Identify or authenticate our users to ensure that our service is secure;
  •       Ensure the security of our information system;
  •       Control abuse;
  •       temporarily store certain user entries;
  •       Store certain user preferences (such as language choices).

Consent is not required to use ‘necessary’ cookies. They cannot be deactivated. Chameleon Vibes also uses ‘functional’ cookies to record usage data about our users (such as which users have visited which of our subpages) and to analyse and evaluate this information. We use this statistical information about use of our website to improve its performance, to tailor our platform to users’ needs, and to make it more user-friendly.

Managing the Use of Cookies. Chameleon Vibes provides users with a consent management (‘cookie banner’) that informs them that the website uses “essential cookies” on their website. It is the choice of the User to accept these essential cookies or not. Most browsers allow the management of cookies by either accepting or rejecting all cookies or by agreeing to only certain types of cookies. To learn how to manage and erase cookies, users should refer to the help function on their browser. It should be noted that if a user chooses to disable or remove cookies, doing so may prevent certain features on our website from working properly and therefore affect the user’s experience on our website. 

Google Analytics

Chameleon Vibes has integrated components of Google Analytics into its website. This includes the gathering, collection, and analysis of data about the behaviour of visitors to the website. Among other things the analysis collects data on which website has referred the user to our website (so-called referrers), which sub-pages of our website have been accessed, and how often and for how long a sub-page has been viewed. Web analysis is mainly used to optimise our website and to understand the cost and benefits of internet advertising. The operator of the Google Analytics component is Google Inc, 1600 Amphitheatre Parkway, Mountain View, California, 94043-1351, USA. Google Analytics uses cookies and the information generated about user behaviour is usually stored on a Google server in the USA. Some information collected via this technical procedure may be transferred to third parties.

IP addresses collected by Google Analytics will usually be shortened by Google but in exceptional cases, the full IP address may be stored on the Google server in the USA. No information, including the IP address, will ever be combined with other data held by Google from other sources. User IDs will be encrypted and anonymised and will not be combined with data from other sources.

Users can prevent the storage of cookies through their browser settings, however in some cases this may mean that the user does not enjoy full utilisation of our website. In addition, users may prevent collection of data related to their use of our website by downloading and installing the browser plug-in available at https://tools.google.com/dlpage/gaoptout?hl=en. This browser add-on informs Google Analytics via JavaScript that no data about website visits may be transmitted to Google Analytics.

Further information about Google’s own privacy policies can be found at https://policies/google.com/privacy?hl=en.        

 

Data Handling

All personal data provided will be processed lawfully, fairly, and in a transparent manner in relation to the requirements and intention of individuals subscribing to the Chameleon Vibes platform. Every effort will be made to ensure that data is accurate and up to date, and every reasonable measure will be taken to ensure that any personal data that is identified to be inaccurate or out of date is erased or rectified without delay. Personal data will be kept in a form which permits identification of individuals for no longer than is necessary for the purposes for which the data was provided, stored, and processed. Data will be stored and processed with technical and organisational measures that ensure its appropriate security, including protection against unauthorised access, loss, destruction, amendment, or damage.

Security

Under the daily management of the Data Protection Officer, and through its physical, technical, and organisational information security procedures, Chameleon Vibes will ensure the confidentiality, integrity, and availability of data such that:

  1.                Data can be accessed, altered, disclosed, or deleted only by those authorised to do so (and that those people only act within the scope of the authority given to them).
  2.                Data you held is accurate and complete in relation to the reason it is required.
  3.                Data remains accessible and usable and can be recovered if it is accidentally lost, altered or destroyed, whilst preventing any damage or distress to the individuals concerned.
  4.                Third-party service providers will be subject to reasonable due diligence including that they are governed by data protection legislation and regulation such as that noted in Paragraph 1 above and/or mechanisms such as the EU-US Privacy Shield certification.

Chameleon Vibes advises users to familiarise themselves with its general security tips and recommendations for the use of its services.

Individuals’ Rights to be Informed

Before individuals are asked to consent to the storage and processing of personal information, they will be assured of their rights to be informed of the following matters:

 

  1.                The name and contact details of Chameleon Vibes’s company officers and representatives.
  2.               The legitimate interests and purposes of Chameleon Vibes’s processing of information and their lawful basis.
  3.                The categories of personal data to be obtained, stored, and processed.
  4.               The recipients of all data provided and/or those with authorised access.
  5.                The details of transfers of the personal data to any third parties or international organisations.
  6.                 The retention period of all data.
  7.                The rights of individuals in regard to processing of data.
  8.               The right to withdraw consent.
  9.                 The right to lodge a complaint with an appropriate authority.
  10.                 The individual’s contractual obligation to provide information.
  11.                Details of the use of information for automated decision-making, including profiling.

Individuals’ Rights to Access

Before individuals are asked to consent to the storage and processing of personal information, they will be assured of their rights to access to data. Individuals have the right to obtain the following from Chameleon Vibes:

  1.                Confirmation that their personal data is subject to processing and the purpose of processing.
  2.               A copy of all personal data stored and the categories under which it is stored and processed.
  3.                All information referred to in the above paragraph concerning the ‘Right to be Informed’.

An individual is only entitled to their own personal data as defined by the UK Government Information Commissioner’s Office.  Requests for information (subject access) can be made verbally, electronically, or in writing and to any part of the Chameleon Vibes organisation. Details of subject access requests will referred to the Chameleon Vibes Data Protection Officer for action and be recorded in a suitable database. Unless it is considered manifestly unfounded or excessive, subject access requests will be answered without undue delay and within two calendar weeks of receipt, conditional on the need to confirm the identity of the person making the request or clarification of the information requested. If appropriate, individuals may be referred to their remote access personal ‘dashboard’ or ‘profile’ page. Subject access requests will be satisfied by providing the information held at the time of the request. 

Individuals’ Rights to Rectification

Before individuals are asked to consent to the storage and processing of personal information, they will be assured of their rights to request inaccurate data is rectified. Whilst all reasonable steps will be taken by Chameleon Vibes Data to ensure that information is accurate when provided, individuals retain the right to have the accuracy of information reconsidered upon request. Details of requests for rectification will be referred to the Chameleon Vibes Data Protection Officer for action and be recorded in a suitable database. Unless it is considered manifestly unfounded or excessive, requests for rectification will be answered without undue delay and within two calendar weeks of receipt, conditional on the need to confirm the identity of the person making the request or clarification of the information involved. If appropriate, individuals may be referred to their remote access personal ‘dashboard’ or ‘profile’ page and requested to amend the information themselves as required.

Individuals’ Rights to Erasure

Before individuals are asked to consent to the storage and processing of personal information, they will be assured of their rights to request data is erased from storage by Chameleon Vibes (‘The Right to be Forgotten’). Should an individual request the erasure of a specific piece of information which does not manifestly prejudice their continued subscription and benefit from services provided, requests for erasure will be answered without undue delay and within two calendar weeks of receipt, conditional on the need to confirm the identity of the person making the request or clarification of the information involved. If appropriate, individuals may be referred to their remote access personal ‘dashboard’ or ‘profile’ page and requested to erase the information themselves as required.

The termination of an individual’s subscription will be considered to be a request for the erasure of all personal information held by Chameleon Vibes relating to that individual. Should an individual request erasure of all information held without expressing the wish to terminate their subscription, then Chameleon Vibes will consider the subscription terminated and the individual will be appropriately informed. Termination of subscription, withdrawal of consent to hold personal information, and request for full erasure of information will usually be considered co-existent.

Following a request for erasure Chameleon Vibes will take all necessary steps to erase data from back-up systems as well as ‘live’ systems. All back-up data will be put ‘beyond use’ even if it cannot be over-written. Such data will not be used within the back-up for any other purpose until it is replaced in line with an established update schedule.

Individuals’ Right to Restrict Processing

 Before individuals are asked to consent to the storage and processing of personal information, they will be assured of their rights to request restriction of data processing using the data they have provided. Requests for restriction may be made if the individual contests the accuracy of the data provided and the data is in the process of being verified, or if the individual alleges that the data has been unlawfully processed in breach of the legitimate nature of the processing necessary. In such cases subscription will most likely be suspended until the issue is rectified and/or the subscription is reinstated or terminated.

Individuals’ Right to Data Portability

Chameleon Vibes recognises an individual’s right to data portability (given the lawful basis for processing the information provided is consent) but does not envisage a situation when it might be reasonably exercised. No data will be stored that is additional to ‘inferred’ or ‘derived’ from personal information provided. Should a request for data portability be received by representatives of Chameleon Vibes it will be considered in alignment with Articles 13, 20, and Recital 68 of GDPR 679/2016.

Individuals’ Right to Object

 Chameleon Vibes will not use personal information for direct or indirect marketing purposes. This does not affect an individual’s right to object to their information being processed but if such a right is exercised subscription will most likely be suspended until the issue is rectified and/or the subscription is reinstated or terminated.

Users have the right to file a complaint about this policy or its implementation to

The Information Commissioner’s Office,

Wycliffe House,

Water Lane,

Wilmslow,

Cheshire.

SK9 5AF,

Telephone Number: + 44 (0) 303 123 1113

Email: [email protected]

Automated Decision Making

 Chameleon Vibes uses personal information provided by individuals to suggest appropriate connections with other subscribers. This includes a limited amount of automated decision making / profiling as defined by Article 22 of GDPR. In processing information in this way we are complying with our contractual obligation to individuals and using the legal basis of consent to process information in this way. The outcome of the processing / automated decision making / profiling is in no way binding on the individual and is subject to his / her choices following our suggestions. All data used in profiling activities is anonymised, we carry out regular and routine data processing impact assessments, and the process is transparent to all subscribers in providing specific information about the manner and influence of automated decision making and profiling.

Liability 

Chameleon Vibes accepts liability for the loss, or damage resulting from the loss of, individuals’ personal data and will not transfer risk inappropriately to individuals by seeking to indemnify itself against claims for loss or damage.

Regulation.

This policy is ultimately regulated by the Information Commissioner’s Office, part of the UK Government Competition and Markets Authority.