PRIVACY POLICY


Last Modified: May 23rd, 2018



1. Acceptance

Your privacy is important to us. This is why we have created this Privacy Policy (the "Policy"). It describes the types of information we may collect from you, or that you may provide, when you visit patook.com (our "Site"), as well as how we collect, maintain, use, protect and disclose your information. This Policy covers the information we collect on or through our Site, or when you contact us for any reason. It does not apply to information collected by any third party, including through any application or content that may link to or be accessible from the Site. Third parties, such as our advertisers, have their own privacy policies different from ours. Please check directly with each such third party to avoid unfair surprises and misunderstandings.


In general, please note that Patook has generally stricter terms of service and a more unusual privacy policy than many other social networks. For example, as outlined below, we may reveal all your private communications to a spouse or domestic partner upon request, if you are suspected of flirting. We may also reveal communications (either privately or publicly) if you are banned or engage in a Terms of Service violation. Please read through this entire document before agreeing to join the site.


Your visits to this Site constitute your acceptance of this Privacy Policy and our Terms and Conditions http://www.patook.com/terms.html . If you do not agree with this Privacy Policy or the Terms and Conditions http://www.patook.com/terms.html, you must exit our Site. This Policy may change from time to time, and the date of last update is indicated at the top of this page. Your continued use of this Site after we revise this Policy is deemed to be acceptance of the revisions, so please check this page from time to time for updates.



2. What information we collect

We may collect several types of information from and about users of our Site, including the following:

a. For all accounts - whatever information you choose to provide to us, any information or content you post or generate, messages you send, and all your activity within the app and site.

b. Analytical Site usage information collected via Google Analytics or Firebase Analytics. This data may include the Site pages you view and other similar information about your behavior on our Site.

c. Analytics site usage information that we collect ourselves.

d. Information from any Social Networks you may have linked and given permission to (e.g. Facebook)

We collect this information:
e. Directly from you when you provide it to us (e.g. when you place an order or contact us for any reason).
f. Automatically as you navigate through the site. Information collected automatically may include, but is not limited to: usage details, IP addresses, GPS location, messages and pictures sent, and information collected through cookies and other tracking technologies.

3. How we use your information

We use information that we collect about you or that you provide to us, including any personal information:
a. To provide the services you requested.
b. To notify you about changes to our Site or any services we offer or provide though it.
c. To allow you to participate in interactive features on our Site.
d. To send our newsletter but you may opt out of it by following the unsubscribe link at the bottom.
e. To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
f. For advertising purposes, as described in section 11.
g. To make sure you adhere to the terms of service
h. In any other way we may describe when you provide the information.

4. Disclosure of your information

We may disclose personal information that we collect or you provide as described in this Policy:
a. To fulfill the purpose for which you provide it.
b. To contractors, service providers and other third parties we use to support our business.
c. To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of the Site's assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information about our Site users is among the assets transferred.
d. We may disclose aggregated information about our users and information that does not identify any individual without restriction.
e. For any other purpose disclosed by us when you provide the information.

We may also disclose your personal information:
f. To comply with any court order, law or legal process, including to respond to any government or regulatory request.
g. To enforce or apply our Terms and Conditions http://www.patook.com/terms.html
h. If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Site, our customers or others.
i. If we believe you used the site to engage in any non-platonic behavior, deceived our users, or otherwise violated the terms of services. This includes but is not limited to, romantic, sexual, business, marketing or other professional relationships established as a result of meeting on the app. In such cases, we use our discretion to decide what information to disclose and it can include, but is not limited to, user profile information and message history. We also use our discretion to decide which requests we will grant and those can include, but are not limited to, spouses, divorce lawyers, people who we believe are genuinely concerned about your intentions.
j. To your spouse, fianc�(e) or other significant other, upon written request and satisfactory proof of relationship, and at our discretion.
k. In the event that you make a suicide threat, to someone who has expressed concern and requested your contact information.
l. If you are banned from Patook, to notify other users of the behavior that caused the ban and caution them against communicating with you further. We may provide those users with as many details as we deem appropriate to ensure their safety, including the contents of messages or behavior that caused your ban.
m. If you are banned, to publicly respond to any public attacks made by you against Patook that we deem untruthful or misleading. This includes but is not limited to: online forums and app store review pages. For example, if you complain online about "being banned for no reason", we may post back that: "this user was banned for trying to flirt with at least three women".


Please note that information you post publicly (such as your user profile information, your public posts) can be visible to everyone. So NEVER publically post any personal information unless you are fine with everyone knowing about it.
Also, users can take pictures or screenshots of messages you send to them and publically share them.

5. Cookies

Cookies are data that a website transfers to an individual's hard drive for record-keeping purposes. The cookie will help our Site, or another website, to recognize your device the next time you visit. For example, cookies can help us to remember your username and preferences, analyze how well our website is performing, or even allow us to recommend content we believe will be most relevant to you.
We may use cookies for the following reasons and purposes:
a. To provide the services you requested. Some cookies are essential so you can navigate through the website and use its features. Without these cookies, we would not be able to provide the services you've requested.
b. To improve your browsing experience. These cookies allow the website to remember choices you make, such as your language or region and they provide improved features. These cookies will help remembering your preferences and settings, remembering if you've filled in certain forms, so you're not asked to do it again, remembering if you've been to the site before, etc. We might also use these cookies to highlight site services that we think will be of interest to you based on your usage of the website.
c. Analytics. To improve your experience on our Site, we like to keep track of what pages and links are popular and which ones don't get used so much to help us keep our sites relevant and up to date. It's also very useful to be able to identify trends of how people navigate through our Site and if they get error messages from web pages. These cookies don't collect information that identifies you. Analytics cookies only record activity on the Site, and they are only used to improve how the Site works.
Most browsers allow you to turn off cookies. To do this, look at the "help" menu on your browser. Switching off cookies may restrict your use of the website and/or delay or affect the way in which it operates.

6. Children's privacy

We are committed to respecting the sensitive nature of children's privacy online. Children under 18 years of age are not allowed to visit our site. We do not knowingly collect personally identifiable information from anyone under the age of 18 and our service is not directed to children. If we learn or have reason to suspect that a Site user is under the age of 18, we will delete that user's account or use that information only to respond directly to that child (or a parent or legal guardian) to inform him or her that he or she cannot use our Site. If we suspect a user to be under the age of 18 but are not able to independently confirm it, or if the user's age is estimated to be under 18 by automated algorithms, we may silently block the user and hide their account. In the case that we believe that person will attempt to create other accounts on the site to evade detection, we may silently block them from interacting with other users and hide their account without notifying them (i.e. soft-block them), instead of deleting them. IF YOU ARE UNDER 18, YOU ARE NOT ALLOWED TO USE THIS WEBSITE OR APP. PLEASE CLOSE IT OR UNINSTALL IT IMMEDIATELY.

7. Data security

Personal information you provide to us is stored on a password protected server accessible only by administrator. We adhere to generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. However, we cannot guarantee the security of your personal information transmitted to our Site because any transmission of information over the Internet has its inherent risks. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site. You are responsible for keeping your login credentials, if any, confidential.

8. Accessing and correcting your personal information

Please send us an e-mail to info@patook.com to request access to, correct or delete any personal information that you have provided to us or to ask questions about this Privacy Policy. We reserve the right to refuse a request if we believe it would violate any law or cause the information to be incorrect.

9. USING PATOOK FROM OUTSIDE THE UNITED STATES

If you are using Patook from outside the United States, please note that your information may be transferred to, stored, and processed in the United States or Canada, where our servers are located and our central database is operated. By using our services, you understand and agree that your information may be transferred to our facilities and those third parties with whom we share it as described in this privacy policy. You also understand that the United States might have less advantageous privacy laws than those in your home country and that we will abide by US law. In general the majority of users are in the US and Canada.

10. Who can see my information/activity

Messages you send are stored on Patook servers. Notwithstanding any data breach or temporary bugs, as described in section 7 above, text messages are visible to both yourself and the recipient(s). However, administrators may view the contents of those messages if they suspect that you or the recipient have violated any of the terms of service, or for any other reason, including but not limited to: debugging an issue with messaging, investigating a problem with the app, if your account has been reported by another user, law enforcement requests, etc.. Similarly, image messages are visible to both yourself and the recipient. However, they may be viewed by administrators at any time. In the case that automated algorithms suspect that the pictures you sent contain inappropriate material, the pictures may also be revealed to third-party moderators who are not affiliated with Patook for manual verification. If your account gets reported by other users, said pictures may also be revealed to said third-party moderators. In the event that automated algorithms suspect that you have broken the terms of service (such as engaging in flirting, spamming, or trying to market products), your entire message history may be made visible to human moderators for verification. Human moderators may be Patook staff or unaffiliated users. In addition, please note that messages are not E2E encrypted - this means that upon governmental or other legal request, your messages may be made visible to the relevant party.

11- Advertising:


We may use the contents of your profile, such as interests, age, location etc. to tailor our ads to you. We may also use the contents of the profiles of the people you are talking to.

Third party vendors, including Google may use cookies to serve ads based on a user's prior visits to your website or other websites. We may provide them with age range and approximate location.

Google's use of advertising cookies may enable it and its partners to serve ads to your users based on their visit to your sites and/or other sites on the Internet.

Users may opt out of personalized advertising by visiting Ads Settings .

12- European Union users:

If European Union (EU) data protection law applies to the processing of your information, you can exercise your right to request access to, update, remove, and restrict the processing of your information. You also have the right to object to the processing of your information or receive a machine-readable copy of your information. To do so, simply e-mail privacy@patook.com to make that request. We will generally ask for identification and verification, as we typically do not require e-mails or other personal information to make an account.

If you have concerns regarding your rights under local law, you can contact your local data protection authority.

We process your information for the purposes described in this policy, based on the following legal grounds:

With your consent
We ask for your agreement to process your information for specific purposes and you have the right to withdraw your consent at any time. You can manage these settings in your Patook account (Under Me -> Privacy Settings (or Data Privacy).

When we're pursuing legitimate interests
We process your information for our legitimate interests while applying appropriate safeguards that protect your privacy. This means that we process your information for things like:
o Providing, maintaining, and improving our Services to meet the needs of our users
o Developing new products and features that are useful for our users
o Understanding how people use our Services to ensure and improve the performance of our Services
o Customizing our Services to provide you with a better user experience
o Marketing to inform users about our Services
o Providing advertising to make many of our Services freely available for users
o Detecting, preventing, or otherwise addressing fraud, abuse, security, or technical issues with our Services
o Protecting against harm to the rights, property or safety of Patook, our users, or the public as required or permitted by law
o Performing research that improves our Services for our users and benefits the public
o Fulfilling obligations to our partners like developers and rights holders
o Enforcing legal claims, including investigation of potential violations of our Terms of Use. In general, the Terms of Use include fines and penalties that we may choose to legally enforce at any time before the statue of limitations expire. For example, this includes fines for sending inappropriate pictures or advertising multi-level marketing schemes. In those cases, our legitimate interests will be to maintain any information about your account that we deem necessary to enforce the fines in court, including the offending pictures.

When we're complying with legal obligations
We'll process your data when we have a legal obligation to do so, for example, if we're responding to legal process or an enforceable governmental request. Please keep in mind that Patook is based in the United States (US) and thereby will respect US law first and foremost, regardless of where you are located. For example, we cannot decline an enforceable US governmental request even when it is not in line with EU law. This is also outlined in the Terms of Service.


EU Data Sharing with 3rd parties:
The in-app consent form has the list of providers with whom we share certain limited information. You can opt out of those using the in-app consent form (Me -> Data Privacy/Privacy Settings). As of May 23rd, 2018 the list is:
1- Microsoft PhotoDNA - to check for illegal exploitation of children. You can opt in/out from within the app. This affects photos shared/uploaded/sent.
2- Microsoft AppCenter - to investigate crashes. You can opt in/out from within the app.
3- Google Ads - for personalizing ads. You can opt in/out from within the app.
4- Google Firebase Analytics - for monitoring performance of our app. You can opt in/out from within the app.
5- GetIPIntel - for checking the IP address for fraud. This only involves sharing the IP address

The list may grow without being reflected here, but we'll ask for consent before sharing data with anyone else. The ultimate list is maintained in the consent form within the app (Me -> Data Privacy/Privacy Settings).

EU Data Retention: in general, while you haven't deleted your account, we will retain your data. We may delete accounts that have been inactive for over two years and have made no submissions whatsoever or kept their profile mostly empty.
If you delete your account, all your information will no longer be visible to other users. For users in good standing, we will generally:
a- Delete all the pictures you uploaded, except for those that were marked as containing pornographic, term of service violations, or illegal material. As the Patook ToS contain explicit fines for people sharing inappropriate pictures, we will retain them for the statute of limitation, should we wish to apply our legitimate interest of enforcing the terms of service. If illegal material is involved, we may retain them until any investigation and court cases have been completed.
b- Hide all your information and generated content. This includes messages to other users that will now disappear.
c- Delete all the content you generated from the main database and backups. This can take up to 6 months until it has also been deleted from the backups - however, certain data will be deleted immediately.


However, sometimes business and legal requirements require us to retain certain information for specific purposes for an extended period of time. For example, if you are caught violating the Terms of Service, or are banned, we may retain this information for a longer period of time to guard against abuse, enforce our Terms of Service fines, or for legal purposes. Reasons we might retain some data for longer periods of time include:

Security, fraud & abuse prevention
Enforcement of ToS fines
Financial record-keeping
Complying with legal or regulatory requirements
Ensuring the continuity of our services

Some examples where we will typically retain information: if you are caught stalking or harassing users; if you are caught sending inappropriate pictures and refuse to pay the fine; if you are caught trying to enlist users in a pyramid scheme or Multi-level marketing scheme; if you use the site illegally, etc.

Information that you posted publicly on your account (such as your user profile, username, etc.) can be seen by all other users and can be captured or screenshotted at any time. This can include any sensitive information you publicly posted such as sexual orientation, political affiliation, etc.
For example, even though it is against the Terms of Service, someone still can take a screenshot of your public profile and post it elsewhere without your permission. Or if you're talking to a user, they can take a picture of your conversation.
While we do not share your information outside of the points described above (in points 12 and 4, etc.), anytime you willingly post information publicly or exchange it with another user, we cannot guarantee that those users will not make or share a copy of the information during the time it was visible to them.

We use encryption technology to encrypt sensitive personal information before it travels over the internet. Credit card numbers are never stored on our database or servers.

13. Breach Reporting
As Patook does not require e-mails, real names, addresses, phone numbers of other identifying information, it may be impossible for us to notify you directly in the case of a breach or hack. Should such a breach occur, we will post it at this link:
Reported potential breaches

Depending on scale, we may also update the homepage to notify users that a breach has occured.

14. Rights of California Residents
If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information to third parties for the third parties� direct marketing purposes. To make such a request, please send an email to privacy@patook.com. Pursuant to California Civil Code Section 1798.83(c)(2), we do not share your personal information with third parties� direct marketing use unless you elect that we do so.

15. Changes to this privacy policy
We may update this Privacy Policy from time to time at our sole discretion. When we post changes to this Privacy Policy, we will revise the "last updated" date at the top of this Privacy Policy. We recommend that you check our Website from time to time to inform yourself of any changes in this Privacy Policy or any of our other policies.