Privacy Policy

CPG Partners Pty Ltd and its related bodies corporate (defined in the Corporations Act 2001), trading as TwoPeas Matchmaking (“TwoPeas”, “we” or “us”), are committed to protecting your privacy. This Privacy Policy (“Policy”) outlines how your information is collected, used and disclosed when you use TwoPeas’s services, through our websites (located at http://www.twopeasapp.com/ and related URLs) as well as our products and applications including mobile applications, downloadable products and applications and pages operated by TwoPeas on social media websites and other platforms (collectively, the “Services”). This information is collected, used and disclosed in accordance with the Privacy Act 1988 (Commonwealth) (“Privacy Act”).

By accessing, registering, using or subscribing to our Services, you represent to us that you have read and consent to our collection, use and storage of your Personal Information and Sensitive Information as described in this Policy. Please note that this Policy is to be read in conjunction with our Terms of Use.

 

What Information Do We Collect and How is it Collected

Personal Information from you

We lawfully collect Personal Information, as defined in the Privacy Act (including Sensitive Information as defined in the Privacy Act), when you register, use, subscribe for or take part in any of our Services.

We collect information you voluntarily provide to us via use of our Services as well as through any other means used to contact us (such as email or phone). The kinds of Personal Information we collect include your contact and payment information such as your name, email address, phone number, mobile number, password, billing information and credit card information. We ask for your real name and do not allow for anonymity or pseudonyms as it is impracticable under the Australian Privacy Principles, subclause 2.2(b), as this would mislead genuine users of our Services.

As a quality match-making service, we collect additional personal and sensitive information from you including your birth date, age, sex/gender, personal interests, racial or ethnic origin, political opinions, religious beliefs or affiliations, philosophical beliefs, criminal history, genetic information, sexual orientation or practices, sexual life experiences, dating gender preference, criminal record, health information, and genetic information and physical characteristics including eye and hair colour. From time to time we may also ask you for other personal or sensitive information related to our match making Service.

If you have enabled geographical location-based or GPS services on your device in relation to any of our Services, we collect information regarding your geographical location or GPS position based on the location of the device you are using to access our Services.

Photo, video and other content uploads

When you upload or enable access to photos, videos or other content to the Services, we collect and store this information, including additional information about those uploads such as the time, date, place the photo or content was taken or uploaded, geographical location (including GPS) and how you use them, who views them or with whom you share them.

If you have connected your social media accounts on TwoPeas, we may collect and store your social media account information, including your photographs, videos, comments, affiliations, friends lists and any other information we are given access to on your social media account.

Automatically collected Personal Information

We automatically record information from your device and its software when you access our Services, including your IP address, browser and device type, internet service provider, mobile phone carrier, platform type, the site from which you came and the site to which you are going when you leave our website, date and time stamp and cookies that may uniquely identify your browser or account.

When accessing our Services using a mobile device, we may also receive and collect identification numbers associated with your device, mobile carrier, device type and manufacturer, and, if enabled, geographical location data (including GPS). Please note that some of the information we collect, for example an IP address, can sometimes be used to approximate a device’s location.

Additionally, we may collect information about your activity, use and participation in our Services, including pages and profiles you view, when you’ve recently logged into the Service and how you browse and use the Services. This information may also include the functions and features that you use within the Service, such as the answers to your questions, message history, the matches you interact with, other friends or contacts you invite to the Services and any other use of our applications and Services.

Personal Information collected via cookies

Our Services use small pieces of data called cookies to identify a user who engages with our website multiple times and to compile long term records of a user’s history of engaging with our websites. Cookies are stored by a users’ browser while the user browses a website. Each time the user visits the website, the browser sends the cookie data back to the server to notify the system of the user’s previous activity.

Cookies are essential to the basic functions of our Services. We use cookies to identify users during and between browsing sessions and to determine user login status so that users do not need to enter their full payment details every time they make a purchase using our Services. We also use persistent cookies which remain on your computer’s hard drive until you delete them or until your computer deletes them based on the expiry date within the cookie.

If you wish to disable cookies, limit advertising that utilises cookies or similar technologies, find out more about cookies and how to manage their use in connection with advertising, you may do so through your browser settings. Note that cookies are essential to the basic functions of our Services, such as allowing you access to your account. If you disable or limit the cookies on your computer then you may obstruct the functionality of our Services.

Personal Information collected via social media

By accessing or using our Services through third party websites such as social media websites, including those accessed on mobile devices or other applications (for example, Facebook or Twitter) or by connecting your TwoPeas account to a third party social media website, you give us permission to access, collect, store, retain and use any information that is made available to us about you from or through that website in accordance with this Policy. The information that we have access to through these third party websites may vary depending on the website and your privacy settings on that website, but can include information such as your name, gender, age, birthday, language, location, country, schooling, religion, sexual orientation, profile picture, username, user ID, contact list, friends or follower lists and other information. The information we obtain from these third party websites may also include information about your friends, followers or other people associated with you via social media depending on their privacy settings.

You acknowledge and agree that we have no control over, and are not responsible for, any privacy settings on any social media websites (including any settings related to any messages or advertisements about us that the social media website may send to you or your friends). We encourage you to review, and adjust your privacy settings on such website prior to accessing, using or linking applications to your social media accounts. You may unlink your social media account from the Services by adjusting your settings on the social media website. Note that this will only prevent further access to information by us and future posts, but will not remove any information that has already been obtained or posts that have already been made.

Personal Information collected through communication

We collect communications you send whilst using our Services, including any comments, photos, messages or other content or communications you and other users share, post or publish using the Services.

One of the features of our Service may include importing your address book contacts, or enabling you to manually enter email addresses to allow you to locate your contacts on the Service or invite them to join you on the Service. We may store these contacts for the purposes of notifying you when your contacts join TwoPeas.

Personal Information provided by others

Information relating to you or your conduct on the Services may be provided by other users of the Services. For example, your email address may be provided to us if another user has tried to refer our Service to you.

We may also collect information about you from third parties, such as contact details, demographic information, internet browsing history, credit reference or fraud prevention information. Financial institutions or payment processors may also provide us updated payment information or payment methods related to your paid account or subscription.

How Do We Store and Protect Your Information?

We take reasonable steps to protect your Personal Information in an effort to prevent loss, misuse and unauthorised access, modification or disclosure and to deal with your Personal Information in accordance with this Policy. The Personal Information we collect from you is transferred and stored electronically via a secured SSL connection, in secured, password-protected servers located in the United States of America and Australia. Access to files containing your Personal Information is granted to our employees and contractors. Access to files containing your Personal Information is also granted to our third party service providers such as our website host and technical support providers, who have information disclosure agreements in place and act in line with industry best practices when it comes to your privacy. Some information may also be stored in physical form where necessary.

Please note however, that no method of electronic transmission or storage is 100% secure and we, cannot guarantee the absolute security of your Personal Information. It is your responsibility to ensure that you keep your Personal Information safe (including your account login and password). This includes keeping your software up to date to prevent security breaches. If you are aware of any unusual activity or unauthorised access (either actual or potential) to your TwoPeas account, you must notify us immediately so that we may take the necessary steps to mitigate loss and prevent further breaches of security.

Although we may remove inactive accounts from time to time, your Personal Information is generally stored with us indefinitely, unless you choose to remove it by deactivating it or if it is no longer required for the purpose for which it was collected, in accordance with Australian Privacy Principles. If an account is removed, we delete your all your Personal Information or take steps to de-identify your information for our records.

We reserve the right to maintain and store any information or data where, we reasonably believe, in our sole discretion, that such action is required to comply with any legal or regulatory obligations, to prevent criminal or other unlawful activity whether immediate or in the future, or where we have a legitimate business reason to do so, including collection of amounts owed, resolving disputes, enforcing our Terms of Use or for record keeping integrity.

For What Purpose Do We Collect and Use Personal Information?

We collect your Personal Information as outlined in this policy for the purposes described below:

a)  For provision of the requested Services, including the general provision of the functions and features that are part of the Services. These may be tailored to you according to the Personal Information you have provided us (such as your geographical location or demographic) or combined with other third party information (such as social media Personal Information) to help us better understand your needs and provide you with improved service;
b)  For administration and maintenance of your TwoPeas Account and use of our apps;
c)  For communication with you and to provide messaging and/or communications to you in association with the functions and features of the Services;
d)  For communicating to you any announcements and updates, updated terms, conditions and policies, software updates, security alerts, technical notices, purchase confirmation, invoices, support and administrative messages;
e)  For analysis, monitoring, development and improvement of our products and Services, including other applications;
f)  For security purposes, including to protect the Services and our property from abuse, fraud, malicious, unauthorised access or potentially illegal activities, and to protect our rights, safety and property and that of our other users;
g)  For sending marketing communications to you, including notifying you of promotional or advertising offers, contests and rewards, upcoming events and other news about products and services offered by us and use of our Services; and
h)  For the performance of other functions as may be otherwise be described at the time of collection or as consented to in relation to our Services.

How Can You Access or Update Your Personal Information?

Most of the information we hold about you can be viewed directly from your account within the Services or is available from the social media websites that you have connected to the Service. You may access, modify or update certain Personal Information within the Service by clicking on “Edit Profile” and “Settings”. You may also contact us using the details below for assistance in accessing or changing your Personal Information or to close your account. We encourage users to ensure their Personal Information is as accurate, up to date and complete as possible in order to obtain the best value from our Service. However, as users have access to freely edit and update their information, we have little control over the information provided to us. TwoPeas does not accept responsibility for ensuring user information is accurate or up to date including information relating to your potential matches.

If you change the information in your account or opt out of receiving certain communications, this will only affect future communications from us. If your Personal Information has already been provided to a third party prior to your change of preferences or update of information, you may have to change your preferences directly with that third party.

To Whom Your Personal Information is Disclosed

Disclosure of your Personal Information will occur in accordance with the purpose for which it was collected or as outlined in this Policy. Accordingly, your Personal Information may be disclosed to other individuals and companies as outlined below:

TwoPeas and Related Bodies Corporate

Your Personal Information may be accessed by us, including our directors, employees, officers and contractors. You consent to us providing your Personal Information, including Sensitive Information to our Related Bodies Corporate (as defined in the Corporations Act 2001 (Cth)).

Other users, individuals and social media websites

Our Services allow you to share Personal Information about yourself with other individuals and other companies, including other users, including your matches or potential matches, as well as potential users of the Services and third party social media websites. Your Personal Information is viewable by other users that you have connected with through our Services, and may also be accessed through public search or on third party websites that you use. This shared information can include basic information provided at registration, information provided through social media websites, any other information provided by you or your friends or connections as well as information about your use of our Services.

We encourage you to exercise discretion and caution with respect to your sharing of your Personal Information for your own personal privacy and safety, as we cannot control what other parties do with your shared information, nor can we control who has access to it. Also, when sharing information about others, please consider their safety and privacy and get their consent for that sharing. By sharing or providing us with Personal Information of a third party you warrant and represent to us that you have obtained their consent to disclose to us and share their Personal Information.

Parties required by law

Your Personal Information may be disclosed by us to any party to whom we are required by law to provide your Personal Information and to any party to whom disclosure is permitted under the Australian Privacy Principles.

Direct marketing

By accessing, registering, using or subscribing to our Services, you consent to us using or disclosing Personal Information (other than sensitive information) to keep you informed about our products and services and other products and services that we consider may be of interest to you. For this purpose, disclosure may be made to our third party service providers. We may communicate with you via email, social media, SMS, or regular mail. If you have indicated a preference for a method of communication, we will endeavour to use that method wherever practical to do so.

We may use or disclose sensitive information about you for the purpose of direct marketing if you have consented to the use or disclosure of the information for that purpose.

You can opt-out of direct marketing communication activities undertaken by us at any time by clicking the “unsubscribe” or “opt-out” link on email communications from us, or by contacting us at support@twopeasapp.com. Note that you cannot opt-out of non-promotional messages necessary for the provision of Services to you, such as messages regarding your account (including technical notices and purchase information).

Advertising service providers and third party advertising networks

TwoPeas may use or share Personal Information regarding your use of or interactions with our Services to online advertising networks or similar third parties that display ads through our Services, or to other users or visitors of our Services. Generally, the information we share is provided through cookies or similar technologies and is may be used to identify the device you are using. This information is used by TwoPeas or the online advertising networks to ensure that the advertisements you see are more relevant to your interests.

Other third parties

We may share your Personal Information with third parties if it is reasonably related to the provision of our Services. The third parties that we may share your Personal Information with includes consultants and other service providers to us that perform services on our behalf. Such services we procure may include identifying and disseminating advertisements, enforcement of our terms and conditions, providing fraud detection and prevention services, processing payments or providing analytics services. We may also share your Personal Information with our business partners who offer goods or services to you jointly with us (for example, contests or promotions).

We may also share your Personal Information with third parties with your consent in a separate agreement, in connection with any company transaction (such as a merger, sale of assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by another company or third party) or in the event of bankruptcy, dissolution, divestiture or any related or similar proceedings.

Note that we reserve the right to share your Personal Information with other third parties where, in our sole discretion, it is required to:

(i)  Investigate and defend ourselves against any third party claims or allegations;
(ii)  Protect against harm to the rights, property or safety of TwoPeas, its users or the public as required or permitted by law; and
(iii)  Detect, prevent or otherwise address criminal (including fraud or stalking), security or technical issues.

Overseas disclosure

Please note that some of the parties listed above to whom your Personal Information may be disclosed, may be located overseas. We do not take responsibility for the privacy practices of such individuals and cannot guarantee their adherence to Australian Privacy Principles we agree to use reasonable endeavours to take reasonable steps to ensure that the Personal Information which we disclose not be held, used or disclosed by the overseas third party inconsistently with the Privacy Act. By accessing, registering, using or subscribing to our Services, acknowledge and consent to disclosure of Personal Information to such overseas recipients.

Age Restrictions

We restrict use of our Services to individuals 18 years and older. By accessing and using our Services you warrant and represent to us that you are over 18 years of age. Please note that despite this, our site is a general audience website and is accessible by people of all ages. We do not intentionally collect or maintain Personal Information from children under the age of 18. If you become aware that Personal Information about a person under 18 has been provided to us, please contact us immediately using the details below. If you become aware that you are communicating with a person under the age of 18 we require you to cease all communications with that person and to immediately report to us, the details of that person.

Third Party Websites

Our Services may, from time to time, contain links to and from websites which are owned or operated by other parties. These websites are governed by their own privacy policies and we recommend that you make your own enquiries as to their privacy policies. We are not responsible and do not accept any liability for any information on, or the privacy practices of, any third party websites.

Access, Correction and Complaints

At any time, you may request access to Personal Information we hold about you. We may refuse to provide access if the law allows us to do so, in which case we will provide reasons for our decision as required by law.

You may write to our privacy officer to request that your Personal Information is not used for the purposes of direct marketing or provided to third parties for direct marketing.

You may also submit a written complaint about how we handle your Personal Information to our Privacy Officer. If you are not satisfied with our handling of your complaint or we have not replied to you within a reasonable period of time, then you are entitled to make a complaint to the Office of the Australian Information Commissioner.

You may request at any time a digital copy of our Privacy Policy.

All requests for access or corrections to your Personal Information should be directed to our Privacy Officer. If you have any further queries relating to our Privacy Policy, or you have a problem or complaint, please contact us using the following contact details:

support@twopeasapp.com
PO BOX 109 MARULAN NSW 2579

Amendments

We reserve the right to amend this Policy from time to time as we see fit. While we endeavour to notify you as soon as reasonably possible of any changes to our Policies by email or by a notice on our website or mobile app, it is your responsibility to keep up to date with any changes or amendments by checking this page prior to using our Services. This page contains our most accurate and up to date version of our Privacy Policy.

Disclaimer

This Policy does not replace or limit the requirements of the Privacy Act. For more information about privacy issues in Australia and protecting your privacy, visit the Australian Federal Privacy Commissioner’s website; http://www.privacy.gov.au/.

Last updated: 30 July 2016