Welcome to the Sugarbeet Labs Privacy Policy. Whether you’re ready to put yourself out there and start dating or just looking for a new friend, at Sugarbeet, we believe every relationship and opportunity should start with respect and equality… especially when it comes to your personal information.

This Policy explains how we process your personal information. It applies any time you’re using the Sugarbeet mobile application or desktop version (“App”), and to your use of our “Sites”, which includes our websites, microsites, and other digital products and services, like our competitions or surveys. We also suggest you read our Terms and Conditions of Use.

We are responsible for taking care of all the personal information we collect and you share with us. According to the General Data Protection Regulation (“GDPR”) of 27 April 2016 and other applicable personal data laws, we are the data “controller” for all personal information collected and processed through our App and Sites. Have any questions about this Policy? Just contact usand we’ll be happy to help.

Good to knowWe will need to change this Policy from time to time, but the most current version controls how we use your information. Be sure to regularly check for updates; we will let you know by email or notice of any material or significant changes.

What do we collect?

You make the first move by using the Sugarbeet App or Sites, which is when we collect some information about you. The type of information collected or shared depends on the specific situation and what exactly you are doing. You will not be able to change your date of birth and, if you give Sugarbeet access to your location in your device settings, your location is automatically updated based on the location of your device.

1. Registration Information

When you download the App and create a Sugarbeet account, we collect certain information about you to help enhance the App and verify the people using it. This can include:

  • Name
  • Username
  • Gender identity
  • Location
  • Email address
  • Date, time and location of birth
  • Photographs
  • Mobile number
  • Sexual preference
  • Login information for social media accounts you connect to your Account, like Facebook or Instagram

After you register, you can change this information at any time through your account. You are responsible for making sure your account details are kept up to date, particularly if your phone number changes.

2. Linked Social Media Information

One way we help simplify and enhance your connecting is by making it possible for you to use your other social media accounts during your Sugarbeet experience. If you choose to register or sign in using your Facebook or Apple account, you give them permission to share certain profile details with us. You can also link your Sugarbeet account with your Instagram, Facebook, or Spotify accounts to share information like your Instagram photos or top Spotify artists.

Good to knowIf you unlink a social media account, this does not automatically delete the information that was already added to your Sugarbeet account. If you’d like this information removed, you must also delete it within your Sugarbeet account.

3. Profile Verification and ID Verification (including biometric information)

We require every person using our App and Sites to verify their accounts. This means we might ask for your phone number and, in some cases, ask that you carry out a photo verification or ID verification. You can choose to (i) verify your photo voluntarily, which adds a grey “verified” badge, and (ii) verify your identity with your ID document, which adds a blue “verified” badge. Photo verification may use facial recognition technology to compare submitted photos to your profile photo. ID checks are carried out on our behalf by our third-party partner, Veriff.

We keep photo verification scans only as long as we need them, but never longer than 3 years after your last interaction with us. Veriff retains your selfie and ID picture for up to 72 hours. For members in South Korea, ID verification is conducted manually.

4. Purchase Information

If you decide to purchase any of our premium services, we will process your payment information and securely keep it for audit/tax purposes and to prevent fraud. To prevent fraudulent payments, we use automated decisions and our systems check payment information and transactions for behaviour that might violate our Terms and Conditions of Use.

5. Geolocation Information

If you give Sugarbeet access to your location in your device settings, we will collect information about your location when you use your mobile device to personalise your App experience and make it easier to connect. This can include information about WiFi access points and your longitude/latitude. You can always turn off geolocation in your device settings if you change your mind.

6. Device Information

When you use the App, we can collect information about your device, including its unique identifier, model, and operating system, as well as log and usage data. You can also choose to give our App access to your device’s address book, which will only be used when you want to add someone to your contacts.

7. Photo Information

We collect data about your profile photos that allows us to arrange them in a way that is favourable to you, such as which photos people spend the most time looking at or which have the best lighting. You can opt out of this feature through our app settings at any time.

8. Link Information

If you use links while using our App or Sites, we can keep track of how you interact with them, including third-party services that we are not responsible for, by monitoring redirecting clicks or other methods.

9. Messages

We review the content of messages sent in the App to identify topics, sentiments, and trends across our Users. We will take steps to remove personally identifying information from such messages, prior to reviewing them. We will not share the content of User messages or information we derive from them with any third party.

10. Success Stories, Surveys, and Other Contributions

From time to time, we may contact you to see if you would like to take part in a research survey, provide feedback or a testimonial, or be part of a marketing campaign. You can always say no and your participation is completely optional.

11. Customer Support Contact Information

If you contact our Customer Support team, we can track your IP address and will receive your email address and the information you share with us to help resolve your request. We keep records of our communications with you for 6 years after your account is deleted.

12. Cookies and Similar Technology Information

When you use our App or visit our Sites, we can collect personal data from you automatically by using cookies or similar technologies. Some cookies are necessary for the App and Sites to function and cannot be switched off, but you do have choices for others. A cookie is a small file placed on your device or internet browser that allows us to recognise and remember your preferences.

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How do we use your information?

Our main goal: give you an enjoyable Sugarbeet experience as you connect.

1. Using Your Information

We use your personal information to:

  • offer our services and features to you;
  • contact you with information about the App, such as updates and new features;
  • personalise the App, Sites, and content we deliver to you;
  • carry out research and analysis about how you use and interact with the App and Sites;
  • test new technologies and processes meant to enhance and improve the App and Sites;
  • resolve disputes, troubleshoot problems, and enforce our Terms and Conditions of Use;
  • investigate fraud and protect our legal rights;
  • protect third parties and the people on our App and Sites from harm; and
  • if you’ve consented, send you information by direct marketing about our promotions and offers.

2. Our Matching Algorithms

We developed matching algorithms to predict your compatibility with others and show you people we think are a good match for you. To do this, our algorithms use the information you share in your profile, information about your activity on the App, whether you’ve verified your photo, and your device coordinates.

3. Moderation Practices

We use a combination of automated systems and a team of moderators to monitor and review accounts and messages for content that suggests a violation of our Terms and Conditions of Use. We will issue a warning to the relevant account if any account or message meets the relevant criteria suggesting a likely violation, and can also restrict or block access.

4. Lawful Basis

According to EU and UK data protection laws, processing personal information must always have a specific lawful basis. If the legal basis is consent, you can withdraw your consent at any time. If the legal basis is legitimate interests, you have a right to object to how we use that information.

Students.We may seek to understand which of our users might be in college or university in order to improve services for students (this applies only to people who identified themselves as being from the US or Canada, except Quebec, and 18–24 years old). We do this using recent location data to see if your device’s coordinates match a general university or college area — a simple “at campus? yes/no” result. We do not track your live movements or store where you are studying, and we do not keep any of the location data used for this activity.

RootRallies. We offer the chance to join Root Rallies, which are groups of local events, challenges and social groups based on specific location or topics, and automatically recommend events for you to join based on your location, activities, and interests.

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What information can others see?

Our App is specifically designed to make it easier for you to connect and interact, which involves making certain information about you available to others. You should always assume that anything you post or submit may be publicly viewable and accessible to people on or off the App. The information you post about yourself is at your own risk — we are not responsible for the information you choose to share with others.

Important things to know when sharing information

We recommend not putting sensitive information that could be used for abuse or misuse on your profile for others to see, such as email addresses, URLs, instant messaging details, phone numbers, full names, addresses, credit card details, national identity numbers, driver’s licence details, or any other sensitive information. Remember that photographs you post can also reveal information about yourself.

RootRallies Profile Sharing

If you use Root Rallies, you should assume that whatever information you share can be seen by any Root Rallies member. If you are in a region where our separate Root Rallies app is available, your Root Rallies profile will automatically be visible both in Root Rallies mode on the main Sugarbeet App and on the separate Root Rallies app.

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Do we share your information?

In order to help you make connections, it might sometimes be necessary to share some personal information with others. We will only ever share your personal information in the limited circumstances described in this Policy. We investigate and verify all of the trusted third parties we work with (“Service Providers”) to make sure they have adequate data protection and information security measures in place.

When we share information, with who, and why

  • Service Providers— to offer functions and services, such as billing (e.g. Google Play), authentication (e.g. Twilio), social media providers, customer support (e.g. Zendesk, Sierra), research (e.g. Typeform or Kantar), and IT services.
  • Moderators— to monitor activity on the App and approve content (name, registration details, profile information, message content, photographs).
  • Payment Processing and Telecommunications Companies— to facilitate payments for our premium services.
  • Marketing Service Providers— to market and advertise our App on third-party websites and applications and measure the effectiveness of our advertising.
  • Legal Enforcement and Preventing Harm— to cooperate with lawful requests from law enforcement and protect people from harm.
  • Our Business Transfers— in the event of a merger, acquisition, re-organisation, sale of assets, insolvency or administration.
  • Anti-Spam and Anti-Fraud Procedures— sharing data such as email, phone, and IP information to block accounts and suspected fraudulent transactions.
  • Aggregated Information— sharing anonymised, aggregated statistics with third parties for industry and demographic analysis.
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What are your rights?

You generally have the following rights regarding your personal information, depending on the specific circumstances:

  • Right to be informed — to know what personal information we process and why.
  • Right to access — to request a copy of the personal information we have about you.
  • Right to rectify — to correct inaccurate personal information.
  • Right to data portability — to retrieve your personal information to transfer it elsewhere.
  • Right to erase — to have your personal information deleted, except where we have compelling reasons to keep it.
  • Right to restrict or object — to limit or stop how we use your personal information.
  • Right to complain — to complain to us or your country’s data privacy authority.
  • Rights related to automated decision-making — not to be subject to decisions made without human involvement that have significant or legal effects on you.

If you want to learn more or exercise your rights, just visit our Feedback Page, email our Data Protection Officer at DPO@sugarbeet.com, or contact us. To protect everyone, we might need to ask you for specific information to confirm your identity before we answer your request.

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US State Privacy Rights

Some US states have their own privacy laws, regulations, and rights, including California, Colorado, Connecticut, New Jersey, Oregon, Texas, Utah, and Virginia. Please read this information along with our Privacy Policy.

Do not track signals

At this time, we do not track the personal information of those using our App or Sites over time or across third-party online services. We also do not knowingly allow third parties to collect personal information about someone’s activities over time and across different online services when using our App.

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What happens when you delete your account?

If you delete your account, we make sure it is no longer viewable on the App. Just in case you delete by accident or change your mind, it’s possible to restore your account for up to 28 days after deleting. We will also begin the process of deleting your personal information if you are no longer actively using your account, i.e. after 4 years of no activity.

After the 28-day period, we start the process of deleting your personal information, unless we must keep it to follow applicable law, to prove we followed applicable law, to resolve an outstanding issue, claim, or dispute, or for our legitimate business interests such as fraud prevention and enhancing safety and security.

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Connecting you around the world

Our App and Sites are global. To make this possible, we operate a global network of servers to provide the App and Sites and store your personal information, including servers in the US, UK, and the EU. Your personal information will be sent to and used in the US and UK, no matter what country you live in. We make sure your personal information is adequately protected — especially when transferred overseas — using valid legal mechanisms such as the EU-approved model clauses. For more information, email DPO@sugarbeet.com.

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Security

Using a website or the Internet is never 100% secure and even we can’t guarantee that unauthorised access, hacking, data loss, or other breaches will never happen. Any transmission is at your own risk. To help keep your data secure:

  • Always log out of your account when you’re done.
  • Never share your password with anyone else.
  • Regularly change your password.
  • If you ever think someone has access to your password or account, take steps to secure it right away.
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Age Restriction Policy

You must be at least 18 years old to use Sugarbeet. We do not knowingly collect any information or market to children, minors, or anyone under 18 years old. If we become aware that someone under 18 has registered a Sugarbeet account and shared personal information with us, we will take steps to terminate that person’s registration.

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California (CCPA)

If you’re a California resident, the California Consumer Privacy Act (CCPA) requires us to disclose information regarding the categories of personal information we collect, the sources, the business or commercial purposes for which it is collected, and the categories of parties to whom we disclose it.

Categories of Personal Information

The data we may collect falls within the following categories of “personal information” as defined by the CCPA:

  • Identifiers, such as name and location;
  • Personal information, as defined in the California customer records law, such as contact (including email and telephone number) and financial information;
  • Characteristics of protected classifications under California or federal law (if you choose to provide them), such as age, gender identity, marital status, sexual orientation, race, ancestry, national origin, religion, and medical conditions;
  • Commercial information, such as transaction information and purchase history;
  • Biometric information;
  • Internet or network activity information, such as browsing history and interactions with our Sites and App;
  • Geolocation data, such as mobile device location;
  • Audio, electronic, visual and similar information, such as photos and videos;
  • Professional or employment-related information, such as work history and prior employer;
  • Non-public education information; and
  • Inferences drawn from any of the personal information listed above to create a profile or summary about, for example, an individual's preferences and characteristics.

The categories of sensitive personal information are account log-in and password, financial data or other credentials allowing access to your account, biometric information, and any other sensitive personal information you may provide in your account or post about yourself.

Your California Rights

  • The right to request that we disclose what personal information we have collected, used, and shared about you over the past 12 months.
  • The right to request that we correct inaccurate personal information we maintain about you.
  • The right to request that we delete your personal information, subject to certain exceptions.
  • The right to be free from unlawful discrimination for exercising your rights under the Act.

“Sales” & “Sharing”

While we do not believe our use of analytics and advertising technologies constitutes a “sale” as that term is defined under the CCPA, you can opt out of any activities that may be considered selling or sharing by clicking “Do Not Sell or Share My Personal Information” on the website homepage or in the Privacy Settings on the app. We also respond to and abide by opt-out preference signals sent through the Global Privacy Control. We do not knowingly “sell” or “share” the personal information of children under 16.

Shine the Light

California’s “Shine the Light” law (Civil Code section 1798.83) requires certain businesses to respond to requests from California customers about their practices related to disclosing personal information to third parties for direct marketing purposes. If you wish to find out about any rights you may have, you can write to us at feedback@sugarbeetlabs.com.

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Questions about your privacy? Email our Data Protection Officer at DPO@sugarbeet.com or contact us.